Text

Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times
	ML17108A253
Person / Time
Site:	Vogtle
Issue date:	04/14/2017
From:	Wheat J; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-17-0447
	Download: ML17108A253 (148)
	v • d • e

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At. Southern Nuclear

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APR 14 2017 Docket Nos.: 50-424 50-425 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Justin T. Wheat Nuclear Lice.~sing Manager 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 5998 tel 205 992 7601 fax jtwheat@southernco.com NL-17-0447 Vogtle Electric Generating Plant, Units 1 and 2 Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times Ladies and Gentlemen:

By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license amendment request to modify the Vogtle Electric Generating Plant (VEGP), Units 1 and 2, Technical Specifications (TS) to implement risk informed completion times into their TS, per the guidelines of Nuclear Energy Institute (NEI) Report NEI 06-09, Revision 0-A, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS)

. Guidelines". Since then, several requests for additional information (RAI) from the Nuclear Regulatory Commission (NRC) staff and subsequent responses from SNC have been docketed.

On February 3, 2017, the NRC issued an RAI via electronic correspondence. Subsequently, the NRC modified three of the questions from the February 3 RAI and provided those to SNC on March 7, 2017. SNC responded to the February 3 NRC RAI on March 13, 2017.

Accordingly, Enclosure 1 to this letter includes the responses to the three revised RAI questions, as well as the response to RAI #5 from the February 3, 2017 correspondence (which was not included in SNC's March 13, 2017 response). Furthermore, continuing discussions between the NRC and SNC resulted in four separate additional requests. rhe responses to these are also included in this letter. Enclosure 2 provides the marked-up and clean pages to the TS. These TS pages supersede all other TS page changes previously submitted to NRC as part of the Risk Informed Completion Time Program for the VEGP. includes the required changes to the Operating License; both marked-up and clean pages are provided. Changes to the License were previously submitted to NRC via letters dated March 16, 2015 and May 5, 2015. All the required changes to the Operating License are included in Enclosure 2 to this letter; consequently, the pages provided via this letter supersede the two previous letters.

Finally, Enclosure 4 includes the marked-up pages of Table E1-1 of SNC's original request for amendment revision. As a result of further discussions with NRC, SNC committed to change portions of that Table for several of the electrical system Limiting Conditions for Operation (LCO).

U. S. Nuclear Regulatory Commission NL-17-0447 Page 2 This letter contains no new NRG commitments.

If you have any questions, please contact Mr. Ken McElroy at 205.992.7369.

Mr. Justin T. Wheat states he is Nuclear Licensing Manager 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, 9w~~

Nuclear Licensing Manager JTW/OCV/

Sworn o and subscrib~e this Jj_ day of ¥ fJ

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'2017.

My commission expires: / () ~ 'if - /;(. 0 I 1

Enclosures:

1. Response to Request for Additional Information

2. Marked-up and Clean Technical Specifications Pages

3. Marked-up and Clean Operating License Pages

4. Marked-up Enclosure 1, Table 1 from September 13, 2012 Submittal cc:

Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. R. D. Gayheart, Fleet Operations General Manager Mr. M. D. Meier, Vice President - Regulatory Affairs Mr. B. K. Taber, Vice President - Vogtle 1 & 2 Mr. B. J. Adams, Vice President - Engineering Mr. D. D. Sutton, Regulatory Affairs Manager - Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager - Vogtle 1 & 2 Mr. M. F. Endress, Senior Resident Inspector - Vogtle 1 & 2 State of Georgia Mr. R. E. Dunn, Director-Environmental Protection Division

I '

I Vogtle Electric Generating Plant Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times Response to Request for Additional Information to NL-17-0447 Response to Request for Additional Information NRC Introduction to Request for Additional Information By letter dated September 13, 2012, as supplemented by letters dated August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, Mays, 2015, February 17, 2016, April 18, 2016, and July 13, 2016 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML12258A055, ML13217A072, ML14198A574, ML14315A051, ML14346A643, ML15075A479, ML15125A446, ML16048A096, ML16109A338, and ML16195A503, respectively), Southern NucleaEr Company, Inc. (SNC), proposed changes to the Technical Specifications (TSs) for the Vogtle Electric Generating Plant (VEGP or Vogtle).

The proposed amendment would modify TS requirements to permit the use of Risk Informed Completion Times (RICTs) in accordance with Topical Report (TR) Nuclear Energy Institute (NEI) 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)Guidelines. The U.S. Nuclear Regulatory Commission (NRC) staff has identified the following information needs associated with your amendment request.

By electronic correspondence dated January 24, 2017 (ADAMS Accession No.ML17027A018),

the NRC staff provided a draft request for additional information (RAI) to Southern Nuclear Operating Company, Inc. (SNC), for discussion at a public meeting. Subsequently, at public meetings dated January 26 and February 2, 2017, the NRC staff discussed these information needs with SNC. By electronic correspondence dated February 3, 2017 (ADAMS Accession No. ML17037A175), the NRC staff provided an updated RAI that addressed issues discussed at the meetings. Another public meeting was held on February 7,2017, to continue discussions. As a result of these discussions, the NRC staff has further modified RAI questions 6, 1 O, and 11 to provide additional clarity and regulatory basis. RAls 6 and 11 have been modified to more clearly convey what information a complete response would contain. RAI 1 O was originally written as a broad question applied to multiple TS actions, however, it has been modified to more specific individual questions for each specification. The other questions from the February 3, 2017, correspondence remain valid.

NRC RAI #5 (From February 3, 2017 NRC RAil While the guidance in NEI 06-09 states that no common cause failure (CCF) adjustment is required for planned maintenance, the NRC approval of NEI 06-09 is based on RG 1.177, as indicated in the NRC safety evaluation to NEI 06-09. Specifically, Section 2.2 of the NRC safety evaluation for NEI 06-09 (ADAMS Accession No. ML071200238) states that, "specific methods and guidelines acceptable to the NRC staff are [... ] outlined in RG 1.177 for assessing risk-informed TS changes." Further, Section 3.2 of the NRC safety evaluation states that compliance with the guidance of RG 1.17 4 and RG 1.177, "is achieved by evaluation using a comprehensive risk analysis, which assesses the configuration-specific risk by including contributions from human errors and common cause failures."

The guidance in RG 1.177, Section 2.3.3.1, states that, "CCF modeling of components is not only dependent on the number of remaining inservice components, but is also dependent on the reason components were removed from service (i.e. whether for preventative or corrective maintenance)." In relation to CCF for preventive maintenance, the guidance in RG 1.177, Appendix A, Section A-1.3.1.1, states:

If the component is down because it is being brought down for maintenance, the CCF contributions involving the component should be modified to remove the component and to only include failures of the remaining components (also see Regulatory Position 2.3.1 of Regulatory Guide 1.177).

E1-1 to NL-17-0447 Response to Request for Additional Information According to RG 1.177, if a component from a CCF group of three or more components is declared inoperable, the CCF of the remaining components should be modified to reflect the reduced number of available components in order to properly model the as-operated plant.

Please confirm and describe how the treatment of CCF either meets the guidance in RG 1.177 or meets the intent of this guidance when quantifying a RICT.

SNC Response to RAI 5 Adjusting the CCF factors for SSC out of service conditions resulting from planned maintenance will cause the delta CDF/LERF to remain the same or decrease slightly. The reason is as follows: if the component is down because it is being brought down for maintenance, the CCF contributions involving the component should be modified to remove the component and to only include failures of the remaining components. As a result, the CCF groups would need to be redefined to a smaller set when a SSC is voluntarily removed from service. On the contrary, it would be conservative to leave the CCF factors at their nominal values which would cause the delta CDF/LERF to remain unchanged and consequently the calculated RICT would remain unchanged.

The failure probability equations for the CCF method used in VEGP PRA model for a two pump CCF group are:

Single pump fails to start = Total failure probability of a single pump

Single pump CCF multiplier Two pumps fail to start due to CCF = Total failure probability of a single pump *Two pumps CCF multiplier MDAFWP B CCF Equations MDAFWP B (P4-002) FAILS TO START DUE TO RANDOM FAILURE (=8.70E-04) = '1-PMAAF'*'QMDAFWPFTS1-2S'*1, where

'1-PMAAF' (=9.1 E-04) is the total failure probability of a single pump and 'QMDAFWPFTS1-2S'

(=0.956) is the one pump CCF multiplier.

AFMDP A & B FAIL TO START DUE TO CCF,1AFPMP4002003ACC (=3.96E-05) ='1-PMAAF'*'QMDAFWPFTS2-2S'*1, where

'1-PMAAF' (=9.1 E-04) is the total failure probability of a single pump and 'QMDAFWPFTS2-2S'

(=4.35E-02) is the two pump CCF multiplier.

As indicated earlier, it would be conservative to leave the CCF equations unchanged and keep their nominal values instead of modifying the common cause groups to remove the component and to only include failures of the remaining components. This approach results in a calculated RICT value to remain unchanged.

NRC RAI #6 (From March 7, 2017 Correspondence)

According to Section A-1.3.2.1 of Appendix A of Regulatory Guide (RG) 1.177, when a component fails, the common cause failure (CCF) probability for the remaining redundant components should be increased to represent the conditional failure probability due to CCF of these components, in order to account for the possibility that the first failure was caused by a CCF mechanism. When a component fails, the calculation of the plant risk, assuming that there E1-2 to NL-17-0447 Response to Request for Additional Information is no increase in CCF potential in the redundant components before any extent of condition evaluation is completed, could lead to a non-conservative extended completion time calculation, as illustrated by inclusion of the guidance in Appendix A of RG 1.177. Much of the discussion in Appendix A describes how configuration specific risk calculations should be performed. In Section 3.2 of the NRC safety evaluation for NEI 06-09, the NRC staff stated that compliance with the guidance of RG 1.174 and RG 1.177, "is achieved by evaluation using a comprehensive risk analysis, which assesses the configuration-specific risk by including co.ntributions from human errors and common cause failures." The limitations and conditions in Section 4.0 of the safety evaluation for NEI 06-09 state that:

The [NRC] staff interprets TR NEI 06-09, Revision O, as requiring consideration of [Risk Management Actions] RMAs [due to the potential for increased risks from common cause failure of similar equipment] whenever the redundant components are considered to remain operable, but the licensee has not completed the extent of condition evaluations [such that a CCF mechanism can be confirmed or excluded].

The requirement to consider RMAs prior to the determination that a CCF mechanism exists or does not exist was included by*the NRC staff in the safety evaluation for NEI 06-09 as a measure to account for the potential that the first failure was caused by a CCF mechanism.

However no exception to the RG 1.177 guidance was taken in the SE for NEI 06-09 for the calculation of the RICT with regards to the quantification of CCF before a CCF can be confirmed or excluded.

Please confirm and describe how that treatment of CCF, in the case of an emergent failure, either meets the guidance in RG 1.177 or meets the intent of this guidance when quantifying a RICT. Addressing CCF in this case could adjust the RICT calculation to numerically account for the increased possibility of a common cause. Alternatively, prior to exceeding the front stop, implement RMAs that are not credited in the RICT calculation sufficient to ensure that any safety function would not be lost if a CCF condition did exist and the remaining train failed to function upon demand.

Either option would need to remain in effect until the possibility of CCF was excluded at which point, a new RICT could be calculated or appropriate RMAs reconsidered.

SNC Response to RAI 6 Southern Nuclear believes the intent of RG 1.177 guidance on treatment of common cause for Technical Specification Completion Time (CT) changes is to account for the increased risk to the plant from potential CC failures by adjusting the CC factors in the risk model when a TS component has failed. However, we believe the specific adjustment of the CC factors in the PRA model was intended for Tier 1 (license amendment) changes and the RICT calculation for 4b is more closely aligned with the RG and NEI guidance associated with Tier 3 contemporaneous configuration risk management changes. Tier 3 changes compensate for the CC failure potential through risk management actions (RMAs) rather than a specific adjustment of the CC factors in the PRA model. Regardless of whether the Risk Informed Completion Time (RICT) is a Tier 1 or Tier 3 change, the intent of RG 1.177 guidance for an emergent failure is to compensate for the increase in plant risk created by a potential common cause failure. As stated above, this common cause risk compensation is appropriate for the period of time before common cause can be confirmed or excluded as the failure mechanism with a high degree of confidence.

E1-3 to NL-17-0447 Response to Request for Additional Information Considering the intent of RG 1.177, the guidance for risk compensation could be met by either adjusting CC factors or ensuring appropriate RMAs are in place to offset risk contributions from common cause failures. It should be noted that adjusting CC factors in the RICT calculation or ensuring appropriate RMAs are in place do not actually reduce the probability of a common cause failure. However, both methods do reduce plant risk as discussed below.

Southern Nuclear proposes to address treatment of common cause for emergent failures as specified below through a combination of Technical Specification requirements added to section 5.5.22 of the Vogtle Technical Specifications and additional guidance in program procedures.

The information in the Technical Specifications is intended to ensure limitations on common cause treatment in the RICT program be treated as an obligation.

Accounting for Common Cause in a RICT When, prior to exceeding the front stop, there is a high degree of confidence based on the evidence collected there is no common cause failure mechanism that could affect the redundant components, the RICT calculation may use nominal CC factor probability.

If a high degree of confidence cannot be established that there is no common cause failure that could affect the redundant components, the RICT shall account for the increased possibility of common cause failure. Accounting for the increased possibility of common cause failure shall be accomplished by one of the two methods below. If one of the two methods below is not used, the TS front stop shall not be exceeded.

1. The RICT calculation shall be adjusted to numerically account for the increased possibility of common cause failure, in accordance with RG 1.177, as specified in Section A-1.3.2.1 of Appendix A of the RG. Specifically, when a component fails, the common cause failure probability for the remaining redundant components shall be increased to represent the conditional failure probability due to common cause failure of these components, in order to account for the possibility the first failure was caused by a common cause mechanism.

2. Prior to exceeding the front stop, the licensee shall implement RMAs not already credited in the RICT calculation, that target the success of the redundant and/or diverse structures, systems or components (SSC) of the failed SSC, and, if possible, reduce the frequency of initiating events which call upon the function(s) performed by the failed SSC. Documentation of RMAs shall be available for NRC review.

Discussion Adjustment of CC factors (Method 1) has the effect of increasing the calculated instantaneous risk and reducing the overall RICT. Adjusting factors does not specifically reduce the probability of having an initiating event nor does it mitigate the subsequent impact of common cause failure. However, this method meets the intent of RG 1.177 by increasing the instantaneous risk and therefore reducing the time the plant can operate in the Condition without confirming the absence of a common cause failure mechanism.

Implementing appropriate RMAs and Protective Actions (Method 2) meets the intent of RG 1.177 by decreasing the actual instantaneous risk but not reducing the overall RICT. The risk reduction impact of the RMAs would not be quantified and not used directly in the RICT calculation (i.e., not credited). Appropriate RMAs typically include actions to decrease the potential for risk-significant initiating events, limit the potential for important SSCs becoming E1-4 to NL-17-0447 Response to Request for Additional Information unavailable due to human error or damage from fire, and prepare operators to respond to risk-significant events, recognizing the specific plant conditions in effect during the TS CT. The RMAs include, but are not limited to, actions that focus on the success of redundant and/or diverse SSCs that perform the function(s) of the failed SSC. Important initiating events will typically include initiating events where event mitigation requires operation of SSCs susceptible to failure by common cause. Important SSCs will typically include SSCs providing redundancy to the failed SSC and diverse SSCs that provide the remaining redundancy for functions performed by the failed SSC. This method also meets the RG 1.177 intent by limiting overall risk through implementation of RMAs during the time when investigations are confirming or excluding the presence of a common cause failure mechanism. It is expected that the RMAs collectively provide equal or greater risk reduction than the risk increase introduced by CC adjustment.

Comparison of Method 1 and 2 Southern Nuclear has prepared an example illustrating the risk reduction from adjusting CC factors in the PRA model (Method 1) and comparing this to implementing RMAs (Method 2).

The attached Figure provides a qualitative comparison of the two methods. For this example, SNC chose the TS Condition associated with an emergent failure of residual heat removal (RHR) pump A. For this TS Condition, a set of RMAs was developed using the Importance Factors from the PRA model and the draft implementing procedures. To the extent practical,*

the risk reduction from some of the RMAs not credited in the RICT calculation was quantified and compared to the risk reduction from adjustment of the CC factors. The results of this comparison in the attached Table show an approximate equivalency of Method 1 and Method 2 in reducing risk. Therefore, SNC concludes both methods meet the intent of RG 1.177.

TS Condition 3.5.2, Condition A-One or more trains [of ECCS] inoperable with at least 100%

of the ECCS flow equivalent to a single OPERABLE ECCS train available. The REQUIRED

ACTION is to restore the train(s) to OPERABLE status within a Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR in accordance with the Risk Informed Completion Time Program.

Upon inoperability of RHR pump A, immediate action is taken by operators to initiate protection (i.e. install barriers/signage) on RHR B in accordance with NMP-OS-010-003, Vogtle Protected Equipment Log. Specifically, the procedure requires protection of the B RHR pump room, the B train 4160V switchgear room, and the pump's control room handswitch. This is considered an RMA which reduces the likelihood of human error induced failures of the remaining RHR train.

RMAs are developed in accordance with draft RICT program procedures by using importance reports generated from quantification of the specific plant configuration. The tables below include Risk Reduction Worth (RRW) and Risk Achievement Worth (RAW) for the RMAs. The RRW provides risk insight if success of the SSC, initiating event, or fire area is guaranteed in the PRA model while the RAW factor provides risk insight assuming guaranteed failure in the PRA model.

RMA1 A) Maintain availability of fire pumps. (This RMA increases the likelihood of adequate pressures in suppression system piping.)

B) For the listed fire zones, maintain availability of suppression, detection, and barriers, and avoid activities that increase fire risk (e.g. hot work, transient combustibles). (This RMA adds assurance that transient fires will not be initiated, increases the likelihood for E1-5 to NL-17-0447 Response to Request for Additional Information suppression of a fire, and decreases the likelihood that a fire will spread between fire zones.) Examples of fire zones in the scope of RMA 1 B are shown below.

Description CDF CDF RRW RAW Control Buildinq Level A Unit 1 Train A Cable Spreading Room A044 11.6 112 Control Building Level A lsolatinq Auxiliary Relay Room A045 11.5 27.7 Control Building Level A Train A Corridor A058 11.5 23.4 Control Buildinq Level B Train BI Channel 2 Equipment Room B047 1.06 16544 Control BuildinQ Level B Train B Penetration Room B065 1.01 29530 RMA 2 - Perform a continuous fire watch at the Train B shutdown panel. Keep the panel open to allow prompt identification of a fire. This RMA increases the likelihood for suppression of a fire in the panel.

Description CDF CDF RRW RAW Control Building Level A Train B Shutdown Panel Room A043 1.5 22.2 RMA3 A) Challenge/preclude activities which could cause the listed initiating events, (e.g.

maintenance, testing). (This RMA reduces the likelihood of human-induced initiating events.)

B) Do not perform switching (i.e. breaker operation) on 4160V bus 1 AA02 and 1 BA03, unless required for transient or event response. (This RMA reduces the likelihood for bus failure because a large percentage of bus failures occur during switching.)

Description CDF CDF RRW RAW Loss of Offsite Power 1.009 19.2 Station Blackout 1.009 5.8 Loss of Nuclear Service CoolinQ Water 1.003 25992 Loss of 4160V Bus AA02 1.003 17.9 Loss of 4160V Bus BA03 1.002 12.9 RMA4 A) Maintain the listed SSCs available (preclude testing and maintenance activities which could impact the availability of the SSCs).

B) Perform non-intrusive inspection of the B RHR pump and support systems to identify any apparent Operability concerns. (This RMA reduces the likelihood for human-induced events affecting availability of redundant SSCs, diverse SSCs which perform the functions of the failed SSC, and other important SSCs.)

E1-6 to NL-17-0447 Response to Request for Additional Information Description GDF GDF RRW RAW 10.4 5.8 1.0 4.2 B Diesel Generator 1.008 1.3 B Se uencer 1.006 21.9 480V Bus 1BB16 1.006 5.9 Aux Closed Coolin Water 1.001 4.5 4160V Bus 1 BA03 1.001 11.8 4160V Bus 1 AA02 1.001 1.6 RMA5 A) Brief operators on configuration risk profile, basis, and RMAs.

B) Perform beginning of shift briefings for control room operators focusing on actions to establish feed and bleed cooling in the event that main feedwater, condensate, and auxiliary feedwater are not available to supply steam generators. {This RMA increases the likelihood that operators will successfully implement a risk significant action. The RRW is 1.014) r The sensitivity study performed for the RHR A pump out of service quantitatively assessed the isk reductiqn from implementation of some RMAs. The majority of RMAs were not credited quantitatively in the sensitivity study. The RMAs credited for the study are as follows:

For RMA 2, performance of a continuous fire watch at the Train B shutdown panel in room A043, a 22.5% reduction is applied to the initiating event frequency for fire in the Train B shutdown panel based on the presence of the continuous fire watch.

For RMA 3A, precluding activities that can cause an initiating event, including loss of offsite power and loss of 4160V bus 1 BA03, which supplies power to the B train RHR system, a 10% reduction is applied to the frequency for loss of offsite power. By data review, a significant percentage of plant-centered and switchyard-centered LOSP events were caused by human interaction (i.e. maintenance, testing, etc.).

RMA 3B, deferral of switching (i.e. breaker operation) on 4160V bus 1AA02 and 1 BA03, a 10% reduction is applied to the frequency for both loss of 4160V bus 1 BA03 and loss of 4160V bus 1 AA02. The majority of bus failures occur during switching activities.

The table below provides a comparison of CC factor adjustment method with the RMA method where no credit is taken in the RICT calculation for RMAs and no factors are adjusted. The sensitivity study results show that the quantification of a limited number of RMAs offset the risk by approximately the same amount as the CC factor adjustment. In this case, the area of the f

boxes" in Figure 1 is essentially the same and it can be concluded the RMAs offset the risk rom a potential common cause failure.

E1-7 to NL-17-0447 Response to Request for Additional Information Sensitivity Study Results - AHR Pump OOS AHR Pump A Failed in all Evaluations CDF Delta CDF Description

(/year)

CC Factor Adjustment Evaluation 4.79E-04 4.30E-04 (Method 1)

SNC RICT Evaluation (Method 2)

No credit for RMAs No CC factor adjustment 4.37E-04 3.88E-04 Sensitivity Study Limited quantitative AMA credit 4.0SE-04 3.56E-04 No CC factor adjustment RICT RICT Change (days)

Relative to Method 2 (days) 8.5

-0.9 9.4 N/A 10.2

+0.8 Fig...e 1 - Method 1 versus Method 2 Comparison Method 1.

CC Factor Method 2.

RI.ti\\ Implementation

=

Southern Nuclear previously responded to an NRC question on treatment of common cause failures on July 17, 2014 (ADAMS No. ML14198A574, RAI #10). Clarification is provided E1-8 to NL-17-0447 Response to Request for Additional Information regarding the potential outcome for extent of condition evaluations for the following scenario. A unit experiences an emergent failure, RMAs are implemented, the front stop expires and the unit enters a RICT. The extent of condition evaluation determines the failure is likely due to a common cause impacting the other train.

When common cause failure is identified as a likely cause, SNC will enter the process for a degraded and non-conforming condition to assess Operability of the other train. During this evaluation, the RMAs implemented before the front stop will remain in place. The evaluation of Operability will either support Operability of the other train or it will not. If the evaluation does not support Operability, the train/component in question will be declared inoperable and the appropriate TS LCO Condition(s) will be entered.

NRC RAI #10 (From March 7, 2017 Correspondence)

The Commission's Policy on Probabilistic Risk Assessment ("Use of Probabilistic Risk Assessment Methods in Nuclear Regulatory Activities," dated August 16, 1995) identifies five key safety principles required for risk-informed decision-making applied to changes to TSs as delineated in Regulatory Guides 1.177 and 1.17 4. They are:

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.

RAI 10.1 NEI 06-09, "Risk Informed Technical Specifications Initiative 4b: Risk Managed Technical Specifications (RMTS)," Revision 0-A, states that Risk Management Actions (RMAs) and compensatory actions for significant components should be predefined to the extent practicable in plant procedures and implemented at the earliest appropriate time in order to maintain defense-in-depth.

Moreover, the NRC staff's safety evaluation for NEI 06-09, Section 4.0, "Limitations and Conditions," (ADAMS No. ML12286A322) states that a licensee's LAA adopting the NEI 06-09 initiative will describe the process to identify and provide compensatory measures and RMAs during extended Completion Times (CT), and provide examples of compensatory measures/RMAs.

In the LAR dated September 13, 2012, Enclosure 10, "Risk Management Action Example,"

pages E10-3 and E10-4, the licensee provided two examples of risk management actions that are considered during a RICT for: (a) inoperable diesel generator, and (b) inoperable battery.

Provide similar examples of RMAs to assure a reasonable balance of defense-in-depth is maintained for the following TS actions:

E1-9 to NL-17-0447 Response to Request for Additional Information TS Condition Description Current Proposed Completion Maximum Time Backstop 3.8.1.C Two required offsite 24 h 30 days circuits inoperable 3.8.1.D One required offsite 12 h 30 days circuit inoperable AND One DG inoperable 3.8.1.F One automatic load 12 h 30 days sequencer inoperable 3.8.4.C One DC electrical 2h 30 days power source inoperable 3.8.7.A One required inverter 24 h 30 days inoperable SNC Response to RAI 10.1 For each TS condition, numerous SSCs are included in the Vogtle 1 & 2 CRMP for which inoperability of the SSC may permit entry into a RICT; however, two conditions must be met prior to RICT entry. First, the calculated RICT must be greater than the front stop. Second, the calculated instantaneous CDF must be less than 1 E-3/yr and the calculated instantaneous LERF must be less 1 E-4/yr. When a SSC is both inoperable and not PRA functional, in some cases the calculated RICT is greater than the front stop; however, the instantaneous CDF is greater than 1 E-3/yr. The example scenarios provided below generate the TS condition's lowest estimated RICT beyond the front stop and generate instantaneous CDF and LERF values below the instantaneous thresholds. All RICTs provided for the example scenarios are generated with the current Vogtle Unit 1 Configuration Risk Management Program (CRMP) tool.

For TS condition 3.8.1.C, two required offsite circuits inoperable, there is not an example scenario that allows RICT entry unless a SSC is PRA functional (i.e. failure of two offsite sources exceeds the instantaneous CDF threshold). The scenario providing the lowest estimated RICT is as follows:

SSC Operable?

PRA Functional?

reserve auxiliary transformer (RAT) 'A' NO YES reserve auxiliary transformer (RAT) 'B' NO NO standby auxiliary transformer (SAT)

N/A NO The RICT for this example emergent scenario is 5.9 days. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example emergent scenario for TS Condition 3.8.1.C are,as follows:

1. Maintain full time monitoring of the running 'B' DG (in this configuration, the 'B' DG would be running to power the 'B' train 4160V AC bus 1 BA03).

2. Limit the potential for a loss of offsite power by terminating all activities in the low voltage and high voltage switchyard.

3. Notify the Power Control Center to defer any planned activities with the potential to generate a grid disturbance.

E1-10 to NL-17-0447 Response to Request for Additional Information

4. Establish 24/7 staffing and response teams to affect repairs.

5. Perform a beginning of shift brief that focuses on actions operators will take in response to a loss offsite power, including the following:

a. Review of actions to reduce DC electrical loads following station blackout per procedures 19100-1 and NMP-OD-019, and

b. Manual operation of turbine driven auxiliary feedwater following battery depletion per procedure 18034-1.

6. Maintain availability of offsite power to/from RAT 'A', maintain Operability of both diesel generators (DGs), and maintain Operability of 4160V safety buses 1 AA02 and 1 BA03.

Perform the following actions:

a. Establish protection of RAT 'A', DGs and DG support systems, sequencers, 1 AA02, and 1 BA03 against inadvertent operation or contact that may impede the SSC from fulfilling its design function.

b. Terminate any in-progress testing or maintenance activities with the potential to impact RAT 'A', DGs, sequencers, 1AA02, or 1 BA03, and

c. Defer any scheduled testing or maintenance activities with the potential to impact RAT 'A', DGs, sequencers, 1AA02, or 1 BA03.

7. Maintain/establish Operability/availability of additional important mitigating SSCs.

Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

8. Limit the likelihood for fires and limit the potential consequences of fires.

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials

9. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, safety buses, and DGs.

10. Evaluate weather predictions and take appropriate actions to mitigate potential impacts of severe weather.

11. Consider staging a portable generator per procedure NMP-OS-019-361, which would accelerate connection to a 4160V AC bus in the event of a station blackout.

E1-11 to NL-17-0447 Response to Request for Additional Information For TS Condition 3.8.1.D, one required offsite circuit inoperable and one DG inoperable, there is not an example scenario that allows RICT entry unless a SSC is PRA functional (i.e. failure of one offsite source and one DG exceeds the instantaneous CDF threshold). The scenario providing the lowest estimated RICT is as follows:

SSC Operable?

PRA Functional?

reserve auxiliary transformer (RAT) 'B' NO NO standby auxiliary transformer (SAT)

N/A NO DG 'A' inoperable and PRA functional NO YES The RICT for the example emergent scenario is 5.9 days. From a PRA functionality standpoint, the scenario is the same as the 3.8.1.C scenario; therefore, RMAs to ensure a reasonable balance of defense-in-depth is maintained are the same as described for the 3.8.1.C scenario.

For TS Condition 3.8.1.F, one automatic load sequencer inoperable, the scenario providing the lowest estimated RICT is sequencer 'A' inoperable and not PRA functional. The RICT for the example scenario is 4.2 days. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example scenario for TS Condition 3.8.1.F are as follows:

1. Limit the potential for a loss of offsite power by terminating all activities in the low voltage and high voltage switchyard.

2. Notify the Power Control Center to defer any planned activities with the potential to generate a grid disturbance.

3. Establish 24/7 staffing and response teams to ensure prompt restoration to Operability of sequencer 'A'.

4. Perform a beginning of shift brief that focuses on actions operators will take in response to a loss offsite power or safety injection. Include review of local emergency start of DG

'A' per procedure 13145-1, manual tie to bus 1AA02 per procedure 13427-1, and manual bus loading.

5. Maintain Operability and availability of redundant and diverse electrical systems by performing the following actions:

a. Establish protection of the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: RAT 'A', RAT

'B', DG 'A', DG 'B', sequencer 'B', bus 1AA02, and bus 1 BA03, and

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

6. Maintain/establish Operability/availability of additional important mitigating SSCs.

Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

7. Limit the likelihood for fires and limit the potential consequences of fires.

E1-12 to NL-17-0447 Response to Request for Additional Information

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials

8. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, safety buses, DGs, and sequencer 'B'.

9. Evaluate weather reports and predictions and take appropriate actions to mitigate potential impacts of severe weather.

For TS Condition 3.8.4.C, one DC electrical power source inoperable for reasons other than Condition A or B, the scenario providing the lowest estimated RICT is battery charger 1AD1CA inoperable and not PRA functional, and battery charger 1 AD1 CB inoperable and not PRA functional. The RICT for the example scenario is 5.7 days. In this scenario, battery 1AD1 B would begin discharging. Operators would transfer vital 120V AC panels from inverter power to regulated transformer power. If no power is established from a battery charger, temporary modification, or portable equipment, then battery 1AD1 B will deplete and 125V DC bus 1AD1 will be lost, which will cause main steam isolation valve closure and main feedwater isolation valve closure, resulting in a reactor trip. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example scenario for TS Condition 3.8.4 C are as follows:

1. Limit the potential for a loss of offsite power by terminating all activities in the low voltage and high voltage switchyard.

2. Establish 24/7 staffing and response teams to ensure prompt restoration of operability of 1AD1CA and/or 1AD1CB.

3. Perform a beginning of shift brief that focuses on actions operators will take to safely shutdown the unit under the following circumstances:

a. Prior to total loss of DC bus 1AD1, and

b. Following unexpected loss of DC bus 1 AD1 and the resulting reactor trip from main steam isolation valve closure and main feed isolation valve closure.

4. Work to establish alternate power to the 125V DC bus by temporary modification or by implementation of FLEX procedures.

5. Maintain Operability and availability of redundant and diverse electrical systems.

Perform the following actions:

a. Establish protection of the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: battery 1 BD1 B, 125VDC bus 1 BD1,.battery chargers 1 BD1 CA and 1 BD1 CB, AC busses 1BBA, 1BBE, 1ABC, 1ABB, and 1BA03, battery 1CD1B, 125VDC bus 1CD1, battery chargers 1CD1CA and 1CD1CA, bus 1M02, regulating transformers 1 ABC09RX and 1 ABB40RX, and E1-13 to NL-17-0447 Response to Request for Additional Information

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

6. Maintain/establish Operability/availability of important mitigating SSCs. Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports.

Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

7. Limit the likelihood for fires and limit the potential consequences of fires.

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials.

8. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, safety buses, DGs, sequencer 'B', and 'B' DC electrical systems.

9. Evaluate weather predictions and take appropriate actions to mitigate potential impacts of severe weather.

For TS Condition 3.8.7.A, one required inverter inoperable, the scenario providing the lowest estimated RICT is inverter 1AD1111 inoperable and not PRA functional. The RICT for the example scenario is 4.2 days. The vital 120V AC panel 1 A Y2A supplied by 1AD1111 will be transferred to power from a regulating transformer. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example scenario for TS Condition 3.8.7 A are as follows:

1. Limit the potential for a loss of offsite power by terminating all activities in the low voltage and high voltage switchyard.

2. Notify the Power Control Center to defer any planned activities with the potential to generate a grid disturbance.

3. Perform a beginning of shift brief that focuses on actions operators will take in response to loss of offsite power per procedure 19100-1 and concurrent loss of 1AY2A per procedure 18032-1.

4. Maintain Operability and availability of 'B' and 'C' train DC electrical systems, 480V bus 1 ABB, and regulating transformer 1 ABB40RX. Perform the following actions:

E1-14 to NL-17-0447 Response to Request for Additional Information

a. Establish protection of the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: 'B' and 'C' train batteries, battery chargers, inverters, and panels, 480V bus 1 ABB, and regulating transformer 1 ABB40RX, and

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

5. Maintain/establish Operability/availability of important mitigating SSCs. Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports.

Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

6. Limit the likelihood for fires and limit the potential consequences of fires.

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials

7. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, DGs, 'B' and 'C' train AC and DC electrical systems, 480V bus 1 ABB, and regulating transformer 1 ABB40RX.

8. Establish 24/7 staffing and response teams to ensure prompt restoration of operability of 1AD1111.

9. Evaluate weather predictions and take appropriate actions to mitigate potential impacts of severe weather.

RAI 10.2 As summarized from the Updated Final Safety Analysis Report (UFSAR), Vogtle's TS Bases state: "The AC, DC, and AC vital bus electrical power distribution systems are designed to provide sufficient capacity, capability, redundancy, and reliability to ensure the availability of necessary power to engineered safety features (ESF) systems so that the fuel, Reactor Coolant System, and containment design limits are not exceeded." When the licensee enters TS Conditions 3.8.9.A, 3.8.9.B, or 3.8.9.C, these subsystems carry the potential vulnerability to single failures that will reduce protection against the exceedance of the design limits.

E1-15 to NL-17-0447 Response to Request for Additional Information TS Condition Description Current Proposed Completion Maximum Time Backstop 3.8.9.A One or more AC electrical Sh 30 days power distribution subsystems inoperable 3.8.9.B One or more AC vital bus 2h 30 days electrical power distribution subsystems inoperable 3.8.9.C One or more DC electrical 2h 30 days power distribution subsystems inoperable

1) For each TS condition's lowest estimated RICT (least amount of time available, calculated beyond the front-stop):

a. Describe a scenario/plant configuration for this condition.

b. Explain how each subsystem would retain the ability to defend against vulnerabilities during this scenario (e.g., examples of RMAs to assure a reasonable balance of defense-in-depth is maintained for this TS condition).

2) For each TS condition's highest estimated RICT (most risk significant component(s) that would result in a calculation close to the 30-day back-stop, without Probabilistic Risk Assessment (PRA) functional consideration):

a. Describe a scenario/plant configuration for this condition.

b. Explain how each subsystem would retain the ability to defend against vulnerabilities during this scenario (e.g., examples of RMAs to assure a reasonable balance of defense-in-depth is maintained for this TS condition).

SNC Response to RAI 10.2 For each TS condition, numerous SSCs are included in the Vogtle 1 & 2 CRMP for which inoperability of the SSC may permit entry into a RICT; however, two conditions must be met prior to RICT entry. First, the calculated RICT must be greater than the front stop. Second, the calculated instantaneous GDF must be less than 1 E-3/yr and the calculated instantaneous LERF must be less 1 E-4/yr. When a SSC is both inoperable and not PRA functional, in some cases the calculated RICT is greater than the front stop; however, the instantaneous GDF is greater than 1 E-3/yr. For these reasons, the most risk-significant SSC(s) associated with entry into the TS condition may not constitute the example scenarios. The example scenarios provided in response to part 1 of RAI 10.2 generate the TS condition's lowest estimated RICT beyond the front stop and generate instantaneous GDF and LERF values below the instantaneous thresholds. The example scenarios provided in response to part 2 of RAI 10.2 generate the longest RICT, without exceeding the 30 day backstop and without PRA functionality consideration. All RICTs provided for the example scenarios are generated with the current Vogtle Unit 1 CRMP tool.

E1-16 to NL-17-0447 Response to Request for Additional Information TS Condition 3.8.9 A The Vogtle CRMP includes 65 SSCs that, when inoperable, can result in entry into TS condition 3.8.9 A, "one or more AC electrical power distribution subsystems inoperable". For 1 O of the 65 SSCs, if the SSC is inoperable and not PRA functional, one or more thresholds is exceeded such that RICT entry is not permitted. For 29 SSCs, if the SSC is inoperable and not PRA functional, the RICT is between 4.1 days and 30 days. For 26 SSCs, if the SSC is inoperable and not PRA functional, the RICT is greater than 30 days, thus the 30 day backstop would apply to the RICT.

For TS condition 3.8.9 A, one or more AC electrical power distribution subsystems inoperable, the scenario providing the lowest estimated RICT is DC breaker 18D1104 inoperable and not PRA functional. The breaker supplies DC control power to 480V AC bus 18816. The RICT for this example scenario is 4.1 days. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example scenario for TS Condition 3.8.9 A a,re as follows:

1. Terminate any in-progress maintenance/testing activities and defer any scheduled maintenance testing. activities with the potential to cause the following initiating events:

a. Loss of offsite power,

b. Loss of DC bus 1AD1, and

c. Loss of 4160V AC bus 1 AA02.

2. Avoid switching (i.e. breaker manipulations) on 'A' train AC and DC electrical systems.

3. Notify the Power Control Center to defer any planned activities with the potential to generate a grid disturbance.

4. Evaluate weather predictions and take appropriate actions to mitigate potential impacts of severe weather.

5. Establish 24/7 staffing and response teams to ensure prompt restoration of Operability of 18D1104.

6. If power cannot be readily restored through 18D1104, work to establish a temporary modification providing DC control power to 18816.

7. Perform a beginning of shift brief that focuses on actions operators will take in response to a loss of offsite power, loss of DC bus 1AD1, or loss of 4160V AC bus 1AA02.

8. Maintain Operability and availability of 'A' NSCW, 'A' DG, and 'A' train AC and DC electrical systems. Perform the following actions:

a. Establish protection of the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: 'A' NSCW, 'A' DG, and 'A' train AC and DC electrical systems, and

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

9. Maintain/establish Operability/availability of important mitigating SSCs. Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports.

Perform the following actions:

E1-17 to NL-17-0447 Response to Request for Additional Information

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

10. Limit the likelihood for fires and limit the potential consequences of fires.

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials.

11. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, 'A' NSCW, 'A' DG, and 'A' train AC and DC electrical systems.

For TS condition 3.8.9 A, one or more AC electrical power distribution subsystems inoperable, the scenario providing the highest estimated RICT is 480 V AC bus 1 ABO inoperable and not PRA functional. The RICT for this example scenario is 16.0 days. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example scenario for TS Condition 3.8.9 A are as follows:

1. Terminate any in-progress maintenance/testing activities and defer any scheduled maintenance/testing activities with the potential to cause loss of 4160V AC bus 1 BA03.

Also, avoid unnecessary switching (i.e. breaker manipulations) on 'B' train AC and DC electrical systems.

2. Establish 24/7 staffing and response teams to ensure prompt restoration of operability of 1ABD.

3. If power cannot be readily restored through 1ABD, work to establish temporary modifications providing power to important 1 ABO loads.

4. Perform a beginning of shift brief that focuses on actions operators will take in response to a loss of 4160V AC bus 1 BA03.

5. Maintain Operability and availability of remaining 'A' train electrical SSCs, and 'B' and 'C' train electrical SSCs. Perform the following actions:

a. Establish protection of the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: AC busses 1 BA03, 1BB16, and 1 BBD, and

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

E1-18 to NL-17-0447 Response to Request for Additional Information

6. Maintain/establish Operability/availability of important mitigating SSCs. Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports.

Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

7. Limit the likelihood for fires and limit the potential consequences of fires.

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials

8. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of 'B' and 'C' train electrical SSCs.

TS Condition 3.8.9 B The Vogtle CRMP includes 34 SSCs that, when inoperable, can result in entry into TS condition 3.8.9 B, one or more AC vital bus electrical power distribution subsystems inoperable. For 12 of the 34 SSCs, if the SSC is inoperable and not PRA functional, one or more thresholds is exceeded such that RICT entry is not permitted. For 4 SSCs, if the SSC is inoperable and not PRA functional, the RICT is 4.2 days. For 18 SSCs, if the SSC is inoperable and not PRA functional, the RICT is greater than 30 days, thus the 30 day backstop would apply to the RICT.

For TS condition 3.8.9 B, one or more AC vital bus electrical power distribution subsystems inoperable, a single scenario provides both the lowest estimated RICT and the highest estimated RICT not exceeding 30 days. The scenario is 120V AC distribution panel 1AY2A inoperable and not PRA functional. This scenario is similar to the example scenario for TS condition 3.8.7 A provided in the RAI 10.1 response; however, in this case 1AY2A cannot be powered from the regulating transformer. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example scenario for TS Condition 3.8.9 B are as follows:

1. Limit the potential for a loss of offsite power by terminating all activities in the low voltage and high voltage switchyard.

2. Maintain Operability and availability of remaining 'A' train electrical SSCs, and all 'B' and

'C' train electrical SSCs. Perform the following actions:

E1-19 to NL-17-0447 Response to Request for Additional Information

a. Establish protection of.the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: 'B' and 'C' train batteries, battery chargers, inverters, and panels, and

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

d. Notify the Power Control Center to defer any planned activities with the potential to generate a grid disturbance.

3. Perform a beginning of shift brief that focuses on actions operators will take in response to loss of offsite power or SI concurrent with no power to vital 120V AC panel 1 AY2A.

Review pertinent actions in procedure 18032-1.

4. Maintain/establish Operability/availability of important mitigating SSCs. Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports.

Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

5. Limit the likelihood for fires and limit the potential consequences of fires.

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials.

6. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, DGs, and B' and 'C' train batteries, battery chargers, inverters, and panels.

7. Establish 24/7 staffing and response teams to ensure prompt restoration of operability of 1AY2A.

8. Evaluate weather predictions and take appropriate actions to mitigate potential impacts of severe weather.

TS Condition 3.8.9 C The Vogtle CRMP includes 38 SSCs that, when inoperable, can result in entry into TS condition 3.8.9 C, one or more DC electrical power distribution subsystems inoperable. For 6 of the 38 SSCs, if the SSC is inoperable and not PRA functional, one or more thresholds is exceeded such that RICT entry is not permitted. For 2 SSCs, if the SSC is inoperable and not E1-20 to NL-17-0447 Response to Request for Additional Information PRA functional, the RICT is 20.7 days or 24.2 days. For 30 SSCs, if the SSC is inoperable and not PRA functional, the RICT is greater than 30 days, thus the 30 day backstop would apply to the RICT.

For TS condition 3.8.9 C, one or more DC electrical power distribution subsystems inoperable, the scenario providing the lowest estimated RICT is DC breaker 1AD101 inoperable and not PRA functional. The breaker connects battery 1AD18 to the 125VDC bus 1AD1. The RICT for this example scenario is 20.7 days. Examples of RMAs to ensure a reasonable bC!lance of '

defense-in-depth is maintained during the example scenario for TS Condition 3.8.9 C are as follows:

1. Limit the potential for a loss of offsite power by terminating all activities in the low voltage and high voltage switchyard.

2. Establish 24/7 staffing and response teams to ensure prqmpt restoration of Operability of 1AD101.

3. Maintain Operability and availability of redundant and diverse electrical systems.

Perform the following actions:

a. Establish protection of the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: battery 18D18, 125VDC bus 18D1, battery chargers 1AD1CA, 1AD1C8, 18D1CA, 18D1C8, AC busses 188A, 188E, 18806, 18807, 18A03, 1A8A, 1A8E, 1A804, 1A805, 1AA02, battery 1CD18, 125VDC bus 1CD1, and battery chargers 1 CD1 CA and 1 CD1 CA, and

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

4. Work to establish alternate power to the 125V DC bus by temporary modification or by implementation of FLEX procedures.

5. Perform a beginning of shift brief that focuses on:

a. Actions operators will take to safely shutdown the unit in the event of a loss of DC bus 1AD1 and the resulting reactor trip from main steam isolation valve closure and main feed isolation valve closure, and

b. Cautions in procedure 13405-1 that describe component manipulations to avoid while the battery is disconnected from the bus.

6. Maintain/establish Operability/availability of important mitigating SSCs. Identify risk-significant SSCs, either from a pre-plan or by real-time use of CRMP importance reports.

Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

7. Limit the likelihood for ffres and limit the potential consequences of fires.

E1-21 to NL-17-0447 Response to Request for Additional Information

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CRMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials.

8. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, safety buses, DGs, and '8' DC electrical systems.

9. Evaluate weather predictions and take appropriate actions to mitigate potential impacts of severe weather.

For TS condition 3.8.9 C, one or more DC electrical power distribution subsystems inoperable, the scenario providing the highest estimated RICT is 18D101 inoperable and not PRA functional. The breaker connects battery 18D18 to the 125VDC bus 18D1. The RICT for this example scenario is 24.2 days. Examples of RMAs to ensure a reasonable balance of defense-in-depth is maintained during the example scenario for TS Condition 3.8.9 C are as follows:

1. Limit the potential for a loss of offsite power by terminating all activities in the low voltage and high voltage switchyard.

2. Establish 24/7 staffing and response teams to ensure prompt restoration of operability of 18D101.

3. Maintain Operability and availability of redundant and diverse electrical systems.

Perform the following actions:

a. Establish protection of the following SSCs against inadvertent operation or contact that may impede the SSC from fulfilling its design function: battery 1AD18, 125VDC bus 1AD1, battery chargers 1AD1 CA, 1AD1 CB, 1 BD1 CA, 1BD1CB, AC busses 1ABA, 1ABE, 1AB04, 1AB05, 1AA02, 1BBA, 18BE, 18806, 18807, 18A03, battery 1 CD1 B, 125VDC bus 1 CD1, and battery chargers 1 CD1 CA and 1 CD1 CA, and

b. Terminate any in-progress testing or maintenance activities with the potential to impact the aforementioned SSCs, and

c. Defer any scheduled testing or maintenance activities with the potential to impact the aforementioned SSCs.

4. Work to establish alternate power to the 125V DC bus by temporary modification or by implementation of FLEX procedures.

5. Perform a beginning of shift brief that focuses on:

a. Actions operators will take to safely shutdown the unit in the event of a loss of DC bus 1 BD1 and the resulting reactor trip from main steam isolation valve closure and main feed isolation valve closure, and

b. Cautions in procedure 13405-1 that describe component manipulations to avoid while the battery is disconnected from the bus.

E1-22 to NL-17-0447 Response to Request for Additional Information

6. Maintain/establish Operability/availability of important mitigating SSCs. Identify risk-significant SSCs, either from a pre-plan or by real-time use of CAMP importance reports.

Perform the following actions:

a. Terminate any in-progress testing or maintenance activities with the potential to impact the availability of important in-service SSCs, and

b. Defer any scheduled testing or maintenance activities with the potential to impact the important in-service SSCs, and

c. Promptly return to service any important out-of-service SSCs.

7. Limit the likelihood for fires and limit the potential consequences of fires.

a. Maintain/establish availability of fire pumps.

b. Identify risk-significant fire zones, either from a pre-plan or by real-time use of CAMP importance reports. Perform the following actions for the risk-significant fire zones:

i. Restrict activities that can impact the availability of fire protection SSCs (fire pumps, detection, suppression, barriers), and ii. Restrict activities that can initiate a fire such as hot work or high energy circuit breaker operation, and iii. Restrict the introduction of transient combustible materials.

8. Every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , senior reactor operators and/or management personnel perform walk downs of switchyards, safety buses, DGs, and 'A' DC electrical systems.

9. Evaluate weather predictions and take appropriate actions to mitigate potential impacts of severe weather.

RAI 10.3 The proposed changes to the TS include Condition 3.4.11.F, Two [Pressurizer Power Operated Relief Valve - PORV] Block Valves inoperable. The current TS require restoring one block valve to operable status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . The proposed change is to permit the option of calculating a RICT for this Required Action. Per the proposed RICT program, the RICT could be calculated to be any length of time between 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months and 30 days. The TS bases state that an OPERABLE block valve may be either open and energized, or closed and energized with the capability to be opened, since the required safety function is accomplished by manual operation. Although typically open to allow PORV operation, the block valves may be OPERABLE when closed to isolate the flow path of an inoperable PORV that is capable of being manually cycled (e.g., as in the case of excessive PORV leakage). A TS loss of function is considered to exist when two redundant SSCs are simultaneously inoperable. Voluntary entry into a condition representing a TS loss of function is prohibited throughout the proposed TSs by a Note which modifies the Condition.

If emergent conditions create a TS loss of function, the RICT is limited to a maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and constraints on PAA functionality are applied. The required position of the PORV block valves could be either open or closed, dependent on the condition of its associated PORV. If the block valves are not repositionable, then inoperability of the block valves could result in a loss of safety function.

E1-23 to NL-17-0447 Response to Request for Additional Information Please provide an explanation of how PRA functionality would be applied in this Condition, why this condition would not be considered a TS loss of function, and how it would be assured that design basis success criteria would be satisfied.

SNC Response to RAI 10.3 Current LCO Condition 3.4.11.F will be made into a Loss of Function Condition.

The block valves may be inoperable but still capable of performing their safety function of preventing excessive leakage from the PORV. For example, a block valve may be inoperable because its stroke time may be outside of the acceptance criteria, but otherwise capable of being cycled open and closed. For the case of LCO 3.4.11.F, if both block valves can be cycled open and close, then PRA Functionality could likely be established.

If the block valves are incapable of closing, then they would be unable to fulfill their safety function and entering the RICT would not be possible. If the block valves are incapable of opening, the PO RVs would be essentially incapacitated in performing their safety function of an RCS depressurization.

For the block valves and the PORVs, the PRA success criteria and the design success criteria are the same. Therefore, in the cases of the block valves being incapable of opening or closing, neither the PRA nor the design success criteria could be met. Consequently, PRA Functionality could not be established.

RAI 10.4 The proposed changes to the TS include Condition 3.5.1.B, One Accumulator Inoperable (for reasons other than Boron Concentration).

The current TS require restoring the accumulator to operable status within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The proposed change is to permit the option of calculating a RICT for this Required Action. Per the proposed RICT program, the RICT could be calculated to be any length of time between 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and 30 days.

Section 6.3.2 of the Vogtle FSAR states that ECCS components are designed such that a minimum of three accumulators, one charging pump, one safety injection pump, one residual heat removal pump, one Residual Heat Removal (RHR) heat exchanger, together with their associated valves and piping will ensure adequate core cooling in the event of a design basis accident.

The Vogtle TS Bases states that the need to ensure that three accumulators are adequate for this function is consistent with the loss-of-coolant accident (LOCA) assumption that the entire contents of one accumulator will be lost via the reactor coolant system (RCS) pipe break during the blowdown phase of the LOCA.

It is not clear to the staff how the assumptions in the accident analysis would be satisfied for a LOCA in which the contents of one accumulator is lost through the break, and a second accumulator is inoperable at the time of the event.

E1-24 to NL-17-0447 Response to Request for Additional Information Please provide an explanation of how PRA functionality would be applied in this condition, why this condition would not be considered a TS loss of function, and how it would be assured that design basis success criteria would be satisfied.

SNC Response to RAI 10.4 LCO 3.5.1.B will be removed from the VEGP RICT Program.

The current VEGP TS recognizes the scenario identified in RAI 10.4. The TS Bases state for LCO Condition 3.5.1.B (one accumulator inoperable):

"In this Condition, the required contents of three accumulators cannot be assumed to reach the core during a LOCA. Due to the severity of the consequences should a LOCA occur in these conditions, the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time... ensures that prompt action will be taken to return the inoperable accumulator to OPERABLE status.

11 The Bases go on to state:

"The 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months allowed to restore an inoperable accumulator to OPERABLE status is justified in WCAP-15049-A, Rev. 1.

11 The VEGP TS were revised to increase the Completion Time for one accumulator inoperable from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months in November of 2003. The change was based on TSTF-370, which used the above referenced WCAP to justify increasing the CT to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; it was a risk informed argument.

Since the 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is already a risk-informed CT, LCO Condition 3.5.1.B will be removed from the RICT Program.

RAI 10.5 The proposed changes to the TS include Condition 3.6.3.B, Containment Penetrations with more than one inoperable containment isolation valve, and Condition 3.6.3.C, Containment Penetrations with Purge Valves Leakage outside limits.

The Required Action for Condition B is to isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

The current Completion Time to isolate the penetration flow path is one hour, which is consistent with the time specified to restore containment leakage to within its limits in TS LCO 3.6.1. Additionally, there is a requirement to verify the affected penetration flow path is isolated once per 31 days for devices outside containment.

Condition C applies when one or more penetration flow paths have one or more containment purge valves not within purge valve leakage limits. The required action is to isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

The proposed change is to permit the option of calculating a RICT for these Required Actions. Per the proposed RICT program, the RICT could be calculated to be any length of time between 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , for Condition B, and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Condition C and 30 days. During this E1-25 to NL-17-0447 Response to Request for Additional Information period, no actions would be required to isolate the affected penetration pathway(s); and automatic actions to isolate the pathway may not be assured.

The containment isolation valves form part of the containment pressure boundary and provide a means for fluid penetrations not serving accident consequence limiting systems to be provided with two isolation barriers that are closed on a containment isolation signal. The containment penetrations covered under conditions 3.6.3.B and C include those penetrations that are connected directly to the RCS or to the containment atmosphere, and are typically isolated using two isolation devices in series. If both of the isolation devices are inoperable in the open position, the safety function of minimizing the loss of reactor coolant inventory and maintaining the containment pressure boundary would not be assured.

Please provide justification to support extension of the Completion Time up to a maximum of 30 days or remove these conditions from the scope of the RICT program. Please include an explanation of how PAA functionality would be applied in this Condition, why this condition would not be considered a TS loss of function, and how it would be assured that design basis success criteria would be satisfied.

SNC Response to RAI 10.5 Conditions B and C will be made loss of function conditions.

For both Conditions, the PAA success criteria and the design basis success criteria are the same.

If the two valves are inoperable such that they are open and neither can be closed, then neither PAA nor design basis success criteria could be satisfied and a RICT could not be taken.

There are, however, cases where a valve could be considered inoperable yet still be able to meet PAA Functionality and design basis success criteria. For example, if an isolation valve is declared inoperable because it will not meet its stroke time criteria, but is closed, then PAA and design basis criteria (to isolate the line in an accident condition) can be met and the valve may be declared PAA Functional.

PAA Functionality would therefore only be applied if the PAA success criteria and the design basis success criteria can be met, i.e., if the valve were capable of closing within its required stroke time.

E1-26 to NL-17-0447 Response to Request for Additional Information Additional NRC RAls Subsequent to SNC's submittal of the March 13, 2017 RAI response, further discussions with NRG generated four additional requests/clarifications.

The first request concerned SNC's response to RAI #9 from the March 13, 2017 RAI response.

The question dealt with LCO 3.4.11.E, "Two PORVs inoperable and incapable of being manually cycled". The NRG asked about FSAR Section 15.5.5.1.2.1, "Inadvertent Operation of the Emergency Core Cooling Systems during Power Operation" (IOECCS). This section indicates that operator action is assumed at ten or eleven minutes to open one PORV for water relief. However, in the response, SNC stated that if the block valves were closed and de-energized, it would take approximately 15 to 30 minutes to re-energize and open the valves.

The NRG asked SNC to reconcile the two numbers.

SNC Response to First Request The operator action for opening a PORV (590 seconds for a low Tave, and 625 seconds for high Tave) is assumed to preclude the IOECCS event from escalating into a more severe event.

Specifically, if the Pressurizer Safety Valves (PSV) opened and passed water due to an overfilled pressurizer, they could potentially fail to reseat leading to a small but non-isolable RCS leak.

The operator action to open the PORV in the VEGP FSAR is intended to avoid this situation. The licensing basis for VEGP assumes that, in the IOECCS event, the PSVs close after a limited number of cycles of passing water. Opening the PORVs within the noted time delay is used to ensure the "limited number of cycles" for the PSVs.

If the VEGP plant were operating under the constraints of proposed LCO Condition 3.4.11.E, i.e., with the block valves closed and de-energized, the 590 second, or 625 second, assumed time frame may be challenged due to having to re-energize and re-open the block valves. While additional cycles would still result in limited water passage through the PSVs, margins would be reduced and that reduction has not been quantified.

Since non-escalation is a part of the design success criteria, the Condition of having "two PORVs inoperable and not capable of being manually cycled", will be removed from the RICT Program.

Second NRG Request The second request dealt with the response to RAI #8 on the March 13, 2017 SNC RAI Response. The NRG asked for clarification on the proposed revision to LCO Condition 3.5.4.B.,

"One or more sludge mixing pump isolation valves inoperable".

SNC Response In that response SNC stated that current LCO Condition 3.5.4.B, "One or more sludge mixing pump isolation valves inoperable" will be split into two Conditions, one Condition for one sludge mixing valve inoperable and another for two valves inoperable. It is still SNC's intent to split the Condition into two Conditions. However, in our response to RAI #8, we stated that the Completion Time (CT) for the Condition of one sludge mixing isolation valve inoperable would be set at 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , rather than the current 24-hour CT for one or more valves inoperable. The E1-27 to NL-17-0447 Response to Request for Additional Information NRG pointed out that increasing the CT would require a review beyond that which is performed for the Risk Informed Technical Specifications. Consequently, the CT for the LCO Condition of one sludge mixing pump isolation valve inoperable will be set at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . As stated in the response to RAI #8, the Condition for one sludge mixing isolation valve inoperable will be included in the RICT Program. The LCO for two valves inoperable will also have a CT of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , but will not be included in the RICT Program.

Third NRG Request The third verbal request was on SNC's response to RAI #11 from the March 13, 2017 RAI Response, which concerned a proposed VEGP license condition.

SNC Response In this RAI, the NRG proposed a license condition to address the scope of the PRA methods approved by the NRG staff for use in the VEGP Risk Managed Technical Specifications Program. In the response to the RAI, SNC proposed a license condition slightly different than that proposed by the NRG. Subsequently, discussions were held between the NRG and SNC on alternative phrasing for the license condition. As a result, SNC proposes the following to be included as a license condition for the VEGP.

The risk assessment approach and methods, shall be acceptable to the NRG, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRG for generic use. If SNG wishes to change its methods, and the change is outside the bounds of this license condition, SNG will seek prior NRG approval, via a license amendment. contains the marked-up and clean Operating License pages. All the changes to the Operating License required for the VEGP Risk Informed Technical Specifications Program are included. These changes supersede the license pages previously submitted to the NRG via letters NL-15-0381 and NL-15-0812, submitted on March 16, 2015 and May 5, 2015, respectively.

Fourth NRG Request The NRG requested clarification on how electrical LCO Sections 3.8.4, "DC Sources -

Operating", 3.8.7, "Inverters - Operating", and 3.8.9, "Distribution Systems - Operating" will be applied in practical use by the Operations Control Room staff. NRG also requested clarification of some of the terms such as "sources", "subsystems", "trains", "channels", etc. not only as they apply to those specifications, but also with regard to how they were used in Enclosure 1, Table 1, of the original SNC VEGP submittal for the Risk Managed Technical Specifications (TS),

provided to NRG on September 13, 2012.

SNC Response to Fourth Request Following is a brief description of the proposed Electrical Specifications Risk Informed Technical Specifications LCO 3.8.4, "DC Sources - Operating", LCO 3.8.7, "Inverters - Operating", and LCO 3.8.9, "Electrical Distribution Systems - Operating", and how they will be applied by the Control Room staff.

E1-28 to NL-17-0447 Response to Request for Additional Information LCO 3.8.4 For LCO 3.8.4, "DC Sources - Operating", there are a total of four Class 1E125 VDC sources as indicated in the LCO 3.8.4 statement, each supplying one safety related DC bus.

Each of the four sources has one 125 VDC battery, two battery chargers and associated support equipment. One of the two battery chargers must be Operable per the TS, the other is a spare.

Sources 'A and 'C' comprise Train 'A'; Sources 'B' and 'D' comprise Train 'B'.

TS Conditions 'A' and 'B' are entered in the case of inoperable batteries. For example, if the Source 'A' battery is inoperable, Condition A is entered. If the source 'C' battery is inoperable, Condition Bis entered. If, for example, both a battery and battery charger are inoperable in one source, Condition C is entered. If a battery charger in one source is inoperable, Condition C is also entered.

A new Condition D is being proposed for the risk informed LCO 3.8.4. It will be a loss of function Condition. The Condition is proposed as "Two DC electrical sources inoperable". If any two sources are inoperable, this Condition will be entered and, it (the LCO Condition) being a loss of function, a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months backstop will be in force.

Depending on the specific combination of DC sources inoperable, an actual loss of safety function may or may not occur. Nevertheless, as stated above, the loss of function Condition D will be entered regardless of which two DC sources become inoperable.

LCO 3.8.7 With respect to LCO 3.8.7, "Inverters - Operating", there are a total of six inverters, that supply six AC Vital buses.

There are four channels associated with the inverters, Channels I, II, Ill, IV.

Two inverters are assigned to Channel I, and one inverter is assigned to Channel Ill. This is designated as the 'A' Train.

There are two inverters assigned to Channel II and one inverter is assigned to Channel IV. This is designated as the 'B' Train.

Proposed Condition 'A' of the VEGP risk informed TS will be entered when any one of the six required inverters becomes inoperable; a RICT may be calculated for that Condition. This is the same as the current Condition 3.8.7.A, except that the proposed Condition A will be included in the RICT program. A new Condition, Condition 3.8.7.B, is proposed for any two (or more) inverters inoperable. This will be a loss of function Condition, regardless of which two inverters are out of service.

Just like the "DC Sources-Operating" LCO, a loss of function will occur for some combination of two inverters out of service, but not all. Nevertheless, if any two inverters become inoperable, proposed loss of function Condition B will be entered, limiting the plant to a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months backstop.

E1-29 to NL-17-0447 Response to Request for Additional Information LCO 3.8.9 The proposed risk-informed LCO will contain four LCO Conditions, each of them included in the Risk Informed Technical Specifications (RICT) program. Conditions A, B, and Care entered for one or more inoperable AC, AC Vital, and DC subsystems, respectively. Table 3.8.9-1 of the Technical Specifications Bases lists the train 'A' and 'B' components for each of these systems.

The Table contains a footnote which states:

"Each train of the AC and DC electrical power distribution systems is a subsystem."

An example of how the Table is used in actual practice may help in understanding:

Suppose one of the 480 V Train 'A' (or subsystem 'A') switchgear, listed in Table B 3.8.9-1, say Unit 1 AB04, were to become inoperable. Further suppose that a Train 'B' (or subsystem 'B')

480 V switchgear, Unit 1 8806 were to also become inoperable. This would result in entry into Condition 3.8.9.A, "One or more AC electrical power subsystems inoperable".

As a separate scenario, suppose a Train 'B' AC Vital channel, say Unit 1 BY1 B, were to become inoperable, resulting in entry into LCO Condition 3.8.9.B "One or more AC Vital electrical power distribution subsystems inoperable". Additionally, if the Unit 1 Train 'A' 480 V switchgear AB04 were to become inoperable, this would result in entry into Condition 3.8.9.A, "One or more AC electrical power subsystems inoperable". Again, there are two trains (or subsystems) affected.

Furthermore, in both the above cases, the control room staff will begin a loss of function evaluation per procedure 10008-C, "Recording Limiting Conditions for Operation". Step 2.5 of the "Precautions and Limitations" section of the procedure states:

"A loss of Safety Function Evaluation must be performed for each inoperability of a SCC impacting a required SUPPORT or SUPPORTED SYSTEM(s)".

(The loss of safety function evaluation will be performed if any Train 'A' AC bus is affected, and if any Train 'B' AC bus is affected, or, for that matter, if any Train 'A' DC bus and a Train 'B' DC bus is affected).

With respect to the above examples, the inoperability of safety related AC electrical power distribution subsystems affects safety related supported systems. The control room f:1taff will therefore initiate the Loss of Safety Function evaluation. If that evaluation determines that a loss of safety function exists, Condition D (of the proposed risk informed TS), "Two or more electrical power distribution subsystems inoperable that result in a loss of safety function" will be entered. In that case, if the Train 'A' and Train 'B' 480 V switchgear are inoperable, Conditions A and D apply. If a Train 'A' 480 V switchgear and a Train 'B' AC Vital bus are inoperable, and again, a loss of safety function exists, Conditions A, B, and D would apply.

Since Condition D is a loss of function Condition, its 24-hour backstop makes it a potentially more restrictive Condition then Conditions A or B.

If the calculated RICT is more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the actual RICT will be limited by the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months backstop of Condition D, as enforced by proposed Section 5.5.22 of the Risk Informed VEGP TS. Therefore, the RICT for the loss of function Condition may be less than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , but never more than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

E1-30 to NL-17-0447 Response to Request for Additional Information The above example is given with AC subsystem components. The inoperability of DC subsystem components may result in similar loss of function evaluations and applicable Condition entries.. Table 1 of the August 15, 2012 original VEGP Risk Informed Technical Specifications revision request The "Design Success Criteria" column of Table E1-1 has been revised for Co'nditions 3.8.4.,

"DC Sources - Operating", Condition C, and Condition 3.8.7, "Inverters - Operating", Condition B. The marked-up pages to the table are included as Enclosure 4 to this letter.

For Condition 3.8.4.C, the current version of the Table states:

1 of 2 DC sources per each of 2 trains.

The above statement is incorrect because the four sources are not perfectly equivalent with respect to the safety related equipment they support. In actuality, when sources are lost, determining the success criteria, or rather, determining if a loss of safety function exists, will be performed at the time of the actual inoperability evaluating the configuration of Operable and inoperable components. Consequently, the Design Success Criteria column is being changed to state:

1 of 2 DC trains.

For Condition 3.8.7.A, the current version of the Table states:

1 of 2 inverter channels in 1 of 2 trains.

Like the design success criteria statement in the DC source portion of the table, the inverter statement is likewise incomplete because the six inverters, and the four channels, are not perfectly equivalent with respect to the safety related equipment they support. Therefore, for the same reasons as Condition 3.8.4.C, the "Design Success Criteria" block will be revised to state:

1 of 2 inverter trains.

Furthermore, the "SSCs Covered by TS LCO Condition" columns are being revised for LCO Conditions 3.8.9.A, "One or more AC electrical power distribution subsystems inoperable",

Condition 3.8.9.B, "One or more AC Vital electrical distribution subsystems inoperable", and Condition 3.8.9.C "One or more DC electrical distribution subsystems inoperable". The changes are being made to more closely align with TS Bases Table 3.8.9-1, which defines each train as a subsystem, per the first footnote at the bottom of the page.

Additionally, the "Design Success Criteria" column for these LCOs are also being revised for the same reasons the changes are being made to Conditions 3.8.4.C and 3.8.7 A, but also for Glaser alignment to Bases Table 3.8.9-1, as well. The Design Success Criteria block for Condition 3.8.9.B is being changed from:

1 of 2 AC Vital subsystems in 1 of 2 trains to:

E1-31 to NL-17-0447 Response to Request for Additional Information 1 of 2 AC Vital subsystems.

The Design Success Criteria block for Condition 3.8.9.C is being changed from:

1 of 2 DC subsystems in 1 of 2 trains to:

1 of 2 DC subsystems

' provides a marked-up page of Table E1-1.

Change to Remove Obsolete Footnote One additional revision to the VEGP Technical Specifications is being made to remove an unnecessary footnote.

Currently, LCO 3.7.14 contains the following footnote, applicable to Condition A:

"For the VEGP Unit 2 August 16, 201 O 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."

This footnote is clearly obsolete and no longer needed. Consequently, the footnote itself and the asterisk in the COMPLETION TIME column of Condition 3.7.14.A is being removed.

This change has no effect on the technical evaluations performed for the VEGP risk-informed TS in the original September 13, 2012, submittal, or any subsequent correspondence. Neither does it affect the Significant Hazards Consideration evaluation or the Environmental Considerations evaluation of the September 13, 2012, submittal.

E1-32

L__

Vogtle Electric Generating Plant Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times Marked-Up and Clean Technical Specifications Pages

1.3 Completion Times Completion Times 1.3 EXAMPLES EXAMPLE 1.3-7 (continued)

If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or any subsequent 8-hour interval from the previous performance (plus the extension allowed by SR 3.0.2),

Condition B is entered. The Completion Time clock for Condition A does not stop after Condition Bis entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may Insert 1 continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.

IMMEDIATE When "Immediately" is used as a Completion Time, the COMPLETION TIME Required Action should be pursued without delay and in a controlled manner.

Vogtle Units 1 and 2 1.3-13 Amendment No. W (Unit 1)

Amendment No. +4 (Unit 2)

I Pressurizer Safety Valves 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 O Pressurizer Safety Valves LCO 3.4~ 1 O Three pressurizer safety valves shall be OPERABLE with lift settings

~ 2410 psig and:::;; 2510 psig.

APPLICABILITY:

MODES 1, 2, and 3.

MODE 4 with all RCS cold leg temperatures > the COPS arming temperature specified in the PTLR.

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

The lift settings are not required to be within the LCO limits during MODE 3 and MODE 4 with all RCS cold leg temperatures > the COPS arming temperature specified in the PTLR for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. This exception is allowed for 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months following entry into MODE 3 provided a preliminary cold setting was made prior to heatup.

ACTIONS Insert 4

~CONDITION A.

One pressurizer safety A.1 valve inoperable.

B.

Required Action and B.1 associated Completion Time not met.

AND OR B.2 Two or more pressurizer safety valves inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore valve to 15 minutes OPERABLE status.

Insert Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 4 with any 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months RCS cold leg temperature

s; the COPS arming temperature specified in the PTLR.

3.4.10-1 Amendment No. 4-ae (Unit 1)

Amendment No. 44.a (Unit 2)

Pressurizer PORVs 3.4.11' 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

Separate Condition entry is allowed for each PORV and each block valve.

CONDITION A.

One or more PORVs A.1 inoperable and capable of being manually cycled.

B.

One PORV inoperable B.1 and not capable of being manually cycled.

AND B.2 AND B.3 Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Close and maintain power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to associated block valve.

Close associated block valve.

Remove power from associated block valve.

Restore PORV to OPERABLE status.

I Insert 2 3.4.11-1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

/

(continued)

Amendment No. 4W (Unit 1)

Amendment No. ~

(Unit 2)

Vogtle Units 1 and 2 3.4.11-2 Amendment No. 4-W (Unit 1)

Amendment No. 4e4- (Unit 2)

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators LCO 3.5.1 Four ECCS accumulators shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2, MODE 3 with pressurizer pressure > 1000 psig.

ACTIONS CONDITION REQUIRED ACTION A.

One accumulator A.1 Restore boron concentration to within limits.

inoperable due to boron concentration not within limits.

B.

One accumulator inoperable for reasons Insert 6 her than Condition A.

G.

Required Action and associated Completi n Time of Condition A D

D.

PNO OF more accumulators inoperable.

B.1 '

Restore accumulator to OPERABLE status.

, B, ore

. 1 D.1 Be in MODE 3.

Reduce pressurizer pressure to::; 1000 psig.

Enter LCO 3.0.3.

Accumulators 3.5.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 24 hours 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Immediately Vogtle Units 1 and 2 3.5.1-1 Amendment No. ~

(Unit 1)

Amendment No. 4 (Unit 2)

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ECCS - Operating 3.5.2

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

1 n MODE 3, either residual heat removal pump to cold legs injection flow path may be isolated by *closing the isolation valve to perform pressure isolation valve testing per SR 3.4.14.1.

ACTIONS CONDITION A.

One or more trains A.1 inoperable.

AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.

B.

Required Action and B.1 associated Completion Time not met.

AND B.2 Vogtle Units 1 and 2 REQUIRED ACTION Restore train(s) to OPERABLE status.

I Insert 2 Be in MODE 3.

Be in MODE 4.

3.5.2-1 COMPLETION TIME NG+e A eRe time eRly el=laR§e ef tl=le GempletieR +ime te 7 Elays is peFmitteEI feF tl=le 1A Rl=IR p1:1mp meteF FeplaeemeRt El1:1FiR§ Ve§tle ldRit ~,

Gyele 19. +l=le iReFeaseEI GempletieR

+ime is applieaele eRly te tl=le 1A Rl=IR

~

~hours 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No. 479 (Unit 1)

Amendment No. 4W (Unit 2)

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS Insert 7 CONDITION A.

RWST boron A.1 B.

concentration not within limits.

RWST borated water temperature not within limits.

REQUIRED ACTION Restore RWST to OPERABLE status.

Restore the valve~ to OPERABLE status.

. RWST 3.5.4 COMPLETION TIME 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 24 hours Required Action and associated Completion Time of Condition not

.1 Isolate the sludge mixing 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Insert 8 met.

ore RWST inoperable for reasons other than Condition ei:

Vogtle Units 1 and 2 G.1

, or C system.

Restore RWST to OPERABLE status.

3.5.4-1 (continued)

Amendment No. W (Unit 1)

Amendment No. +4 (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION Required Action and associated Completion Time of Condition A or Be in MODE 3.

F not met.

E

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

L CO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

SURVEILLANCE REQUIREMENTS SR 3.5.4.1 SR 3.5.4.2 SR 3.5.4.3 SR 3.5.4.4 SURVEILLANCE

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

0 n ly required to be performed when ambient air temperature is < 40°F.

Verify RWST borated water temperature is

~ 44°F and::::; 116°F.

Verify RWST borated water volume is ~ 686,000 gallons.

Verify RWST boron concentration is ~ 2400 ppm and ::::; 2600 ppm.

Verify each sludge mixing pump isolation valve automatically closes on an actual or simulated RWST Low-Level signal.

RWST 3.5.4 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.5.4-2 Amendment No. 4-79 (Unit 1)

Amendment No. 4-eG (Unit 2)

ACTIONS (continued)

CONDITION C.

One or more C. 1 containment air locks inoperable for reasons other than Condition A or B.

AND C.2 AND C.3 D.

Required Action and D.1 associated Completion Time not met.

AND D.2 Vogtle Units 1 and 2 REQUIRED ACTION Containment Air Locks 3.6.2 COMPLETION TIME Initiate action to evaluate Immediately overall containment leakage rate per LCO 3.6.1.

Verify a door is closed in the affected air lock.

Restore air lock to OPERABLE status.

Be in MODE 3.

Be in MODE 5.

3.6.2-4 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

~

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

>E I Ins 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No..Qe (Unit 1)

Amendment No. +4 (Unit 2) ert 2

Containment Isolation Valves 3.6.3 3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS

N 0 TES-----------------------------------------------------------

1.

Penetration flow path(s) (except for 24 inch purge valves) may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more penetration A. 1 flow paths with one containment isolation

. valve inoperable except for purge valve leakage not within limit Vogtle Units 1 and 2 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

3.6.3-1 Insert 2 (continued)

Amendment No. 00 (Unit 1)

Amendment No. +4 (Unit 2)

ACTIONS CONDITION A.

(continued)

A.2 I Insert 20 ~ "

B.

One or more penetration B.1 flow paths with two containment isolation valves inoperable except for purge valve leakage not within limit.

Vogtle Units 1 and 2 Containment Isolation Valves 3.6.3 REQUIRED ACTION COMPLETION TIME

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

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected Once per 31 days for penetration flow path is isolation devices isolated.

outside containme'nt AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment Isolate the affected 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months penetration flow path by use of at least one closed and de-activated automatic valve, closed lnse manual valve, or blind flange.

(continued) rt 2 3.6.3-2 Amendment No. ~ (Unit 1)

Amendment No. IHI (Unit 2)

ACTIONS continued Insert 21 CONDITION C.

One or more penetration C.1 flow paths with one or more containment purge valves not within purge valve leakage limits.

AND C.2 Vogtle Units 1 and 2 Containment Isolation Valves 3.6.3 REQUIRED ACTION COMPLETION TIME Isolate the affected 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

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

1 solation devices in high radiation areas may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

Insert 2 Once per 31 days for isolation devices outside containment*

Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment (continued) 3.6.3-3 Amendment No..Q9 (Unit 1)

Amendment No. +4 (Unit 2)

3.6 CONTAINMENT SYSTEMS Containment Spray and Cooling Systems 3.6.6 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One containment spray A.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable.

spray train to OPERABLE status.

~

I Insert 2 72hours I I

B.

One containment B.1 cooling train inoperable.

C.

Required Action and C. 1 associated Completion Time of Condition A or B AND not met.

C.2 Vogtle Units 1 and 2 Restore containment cooling train to OPERABLE status.

Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 3.6.6-1 Amendment No. 4-79 (Unit 1)

Amendment No. 400 (Unit 2)

I I

I

I 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

MS IVs 3.7.2 LCO 3.7.2 Two MSIV systems per steam line shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when one MSIV system in each steam line is closed.

ACTIONS

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

S e pa rate Condition entry is allowed for each steam line.

CONDITION REQUIRED ACTION A.

One or more steam line A.1 Restore MSIV to with one MSIV system OPERABLE status.

inoperable in MODE 1.

Insert 9

h. '

B.

One or more steam lines B.1 Restore one MSIV with two MSIV systems system to OPERABLE inoperable in MODE 1.

status in affected steam line.

C.

Required Action and C.1 Be in MODE 2.

associated Completion Time of Condition A or B not met.

Vogtle Units 1 and 2 3.7.2-1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months

~

Insert 2 4hours /

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months (continued)

Amendment No. W (Unit 1)

Amendment No. +4 (Unit 2)

I

I 3.7 PLANT SYSTEMS

3. 7.4 Atmospheric Relief Valves (ARVs)

A RVs 3.7.4 LCO 3.7.4 Three ARV lines shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3 ACTIONS CONDITION A.

One required ARV line A.1 inoperable.

Insert 10 I

I B.

Two or more required B.1 ARV lines inoperable.

C.

Required Action and C.1 associated Completion Time not met.

AND C.2 Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore required ARV line 30 days to OPERABLE status.

Restore at least two ARV 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months lines to OPERABLE status.

Be in MODE 3.

Be in MODE 4 3.7.4-1 Insert 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 18 hours Amendment No..:t..J.7 (Unit 1)

Amendment No. 44-e (Unit 2)

3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System AFWSystem 3.7.5 LCO 3.7.5 Three AFW trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

LCO 3.0.4b is not applicable.

CONDITION A.

One steam supply to turbine driven AFW pump inoperable.

OR

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

On ly applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

B.

One AFW train inoperable for reasons other than Condition A.

Vogtle Units 1 and 2 A.1 B.1 REQUIRED ACTION COMPLETION TIME Restore affected 7 days equipment to OPERABLE status.

Restore AFW train to OPERABLE status.

3.7.5-1 Insert 2 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued)

Amendment No. 400 (Unit 1)

Amendment No. 4e4 (Unit 2)

Insert 11

~G.

Two AFW trains inoperable.

G.

Three AFW trains E

Vogtle Units 1 and 2

, or C G.2 G.1 REQUIRED ACTION D

Be in MODE 4.

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

L CO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one AFW train to OPERABLE status.

AFW System

. 3.7.5 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Immediately 3.7.5-2 Amendment No. W (Unit 1)

Amendment No. -74 (Unit 2)

3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCW trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION A.

One CCW train inoperable.

Insert 12 or B Required Action an associated Comple *on Time of Condition A not c

A.1

.1 REQUIRED ACTION

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

Ente r applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"

for residual heat removal loops made inoperable by CCW.

Restore CCW train to OPERABLE status.

Be in MODE 3.

.2

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

CCWSystem 3.7.7 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Insert 2 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Vogtle Units 1 and 2 3.7.7-1 Amendment No. 4+-9 (Unit 1)

Amendment No. 4-eG (Unit 2)

3.7 PLANT SYSTEMS 3.7.8 Nuclear Service Cooling Water (NSCW) System LCO 3.7.8 Two NSCW trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION A.

One NSCW train inoperable.

Insert 13 Required Action and associated Completion Time of Condition not met.

or B REQUIRED ACTION

N 0 TES-------------------

1.

Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," for emergency diesel generator made inoperable by NSCW system.

2.

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," for residual heat removal loops made inoperable by NSCW system.

A.1 Restore NSCW system to OPERABLE status.

Be in MODE 3.

c

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

L CO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

NSCW 3.7.8 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ~

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Vogtle Units 1 and 2 3.7.8-1 Amendment No. +79 (Unit 1)

Amendment No. 4W (Unit 2)

J

3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

UHS 3.7.9 LCO 3.7.9 The UHS shall be OPERABLE. The fans/spray cells shall be as specified in Figure 3.7.9-1.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Nuclear A. 1 Restore water 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Service Cooling Water temperature(s) and water (NSCW) basins with level(s) to within limits.

water temperature and/or water level not within limits.

B.

One NSCW cooling B.1 Restore fan to 7 days tower with one required OPERABLE status.

fan/spray cell inoperable when operating in four

~

fan/spray cell required Insert 2 region of Figure 3.7.9-1.

C.

One NSCW cooling C.1 tower with one or more required fans/spray cells inoperable for reasons other than Condition B.

Vogtle Units 1 and 2 Restore fan(s)/spray cell(s) to OPERABLE status.

3.7.9-1 72hour/

(continued)

Amendment No..:t..:ro (Unit 1)

Amendment No. 4.§2 (Unit 2)

I I

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.

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

0 n e 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 A.

One ESF room cooler A.1 and safety-related chiller train inoperable.

Insert 14

~-

Required Action and Associated Completion Time ot met.

REQUIRED ACTION COMPLETION TIME Restore the ESF room 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months s~

cooler and safety-related chiller train to OPERABLE status.

c Be in MODE 5.

of Condition A or B 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours

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.

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

Amendment No.~ (Unit 2)

ACTIONS CONDITION A. (continued)

A.2 A.3 Vogtle Units 1 and 2 REQUIRED ACTION Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

Restore required offsite circuit to OPERABLE status.

I lnsert2 V AC Sources - Operating 3.8.1 COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (continued) 3.8.1-2 Amendment No..:te-9 (Unit 1)

Amendment No. M (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION AC Sources - Operating 3.8.1 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 I

Vogtle Units 1 and 2 ANG B.2 required offsite circuit(s).

Verify SAT available.

ANyill B.~

Declare required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable.

~-1 3K

~ OR B.111.2 Determine OPERABLE DG is not inoperable due to common cause failure.

Perform SR 3.8.1.2 for OPERABLE DG.

Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours (continued) 3.8.1-3 Amendment No. 00 (Unit 1)

Amendment No. +s (Unit 2)

ACTIONS CONDITION B.

(continued)

Vogtle Units 1 and 2 REQUIRED ACTION NOTE Required Action B.5.1 is only applicable if the combined reliability of the enhanced black start combustion turbine generators (CTG) and the black start diesel generator is> 95%. OthenNise, Required Action B.5.2 applies.

AC Sources - Operating 3.8.'1 COMPLETION TIME B.5.1 Verify an enhanced black 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months start CTG is functional by verifying the CTG and the GR black start diesel generator starts and Within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months achieves steady state prior to entry into voltage and frequency.

Condition B B.5.2 Start and run at least one 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months CTG 'Nhile in Condition B.

3.8.1-4 Prior to entry into Condition B for preplanned maintenance (continued)

Amendment No. 400 (Unit 1)

Amendment No. -Jg (Unit 2)

ACTIONS CONDITION B.

(continued) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months REQUIRED ACTION Restore DG to OPERABLE status.

AC Sources - Operating 3.8.1 discovery of failure to meet LCO Insert 2 C.

Required Actions B.2, C.1 Restore DG to OPERABLE 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months status.

B.5.1, OF B.5.2 and associated Completion Times not met.

Q.

Two required offsite circuits inoperable.

c D

One required offsite circuit inoperable.

One DG inoperable.

Vogtle Units 1 and 2

.1 AND

.2 Declare required feature(s) inoperable when its redundant feature(s) is inoperable.

Restore one required offsite circuit to OPERABLE status

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

E nte r applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating,"

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

D c

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months fr m discovery f Condition concurrent with inoperability of redundantrequ* ed features 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued) 3.8.1-5 Amendment No..:t.W (Unit 1)

Amendment No. ~

(Unit 2)

ACTIONS CONDITION E.

(continued)

E.1

.2 Insert 15 E

H.

equired Action and H.1 Insert 16 associated Completion Time of Condition A, C, AND D, E, F, or G not me H.2 GR ReEJuiFeEl AstioA B. 1, B.3, B.4.1, B.4.2, OF B.e aAEl assosiateEl Goffi13letioA +:iffie Rot met:-

REQUIRED ACTION Restore required offsite circuit to OPERABLE status.

Restore DG to OPERABLE status.

Restore one DG to OPERABLE status.

Restore automatic load sequencer to OPERABLE status.

Be in MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

AC Sources - Operating 3.8.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 2 hours Insert 2 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours I.

+:hFee OF ffiOF8 F8EJUiFeEl r.-l.+1---1E=iA-tttt:i18FHL'='<b=>'O;::f-d3.,....0r..3cr..

I ffiffieEliately AG sournes iA013ernble.

Vogtle Units 1 and 2 3.8.1-6 Amendment No. 79 (Unit 1)

Amendment No. 4-W (Unit 2)

3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating DC Sources - Operating 3.8.4 LCO 3.8.4 Four class 1 E 125 V DC electrical power sources shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION A.

One DC electrical power source inoperable due to inoperable battery A or B.

REQUIRED ACTION

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

Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," for emergency diesel generator made inoperable by inoperable battery A or B.

A.1 Restore DC electrical power source to OPERABLE status.

COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B.

One DC electrical power B.1 Verify SAT available 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months source inoperable due to inoperable battery C or D.

Vogtle Units 1 and 2 Insert 2 B.2 Restore DC electrical power source to OPERABLE status.

AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter (continued)

Amendment No. ~(Unit 1)

Amendment No. 4-42 (Unit 2)

ACTIONS continued CONDITION C.

One DC electrical power source inoperable for reasons other than Condition A or B.

Insert 17 Required Action and ssociated Completion T1 not met.

E C.1

.2 SURVEILLANCE REQUIREMENTS REQUIRED ACTION Restore DC electrical power source to OPERABLE status.

Be in MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

SURVEILLANCE SR 3.8.4.1 Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

DC Sources - Operating 3.8.4 COMPLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months ~

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.4-2 Amendment No. 4-7Q. (Unit 1)

Amendment No. 4-eG (Unit 2)

Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating LCO 3.8.7 APPLICABILITY:

ACTIONS The required Class 1 E 120 V inverters shall be OPERABLE.

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

T wo inverters may be disconnected from their associated DC bus for

~ 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an equalizing charge on their associated common battery, provided:

a.

The associated AC vital bus( es) are energized from their Class 1 E regulating transformers; and

b.

All other AC vital buses are energized from their associated OPERABLE inverters.

MODES 1, 2, 3, and 4.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One required inverter inoperable.

Insert 18 Required Action and associated Completion ime not met.

Vogtle Units 1 and 2

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

E n te r applicable conditions and required actions of LCO 3.8.9 "Distribution Systems - Operating" with any vital bus deenergized.

A.1

.1 Restore inverter to OPERABLE status.

Be in MODE 3.

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

L CO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ~

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 3.8.7-1 Amendment No. 4-79 (Unit 1)

Amendment No. 400 (Unit 2)

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 The required AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

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

Th e redundant emergency buses of 4160 V switchgear 1/2AA02 and 1/2BA03 may be manually connected within the unit by tie breakers in order to allow transfer of preferred offsite power sources provided SR 3.8.1.1 is successfully performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to the interconnection. The interconnection shall be implemented without adversely impacting the ability to simultaneously sequence both trains of LOCA loads.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION

. REQUIRED ACTION COMPLETION TIME A.

One or more AC A.1 Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months electrical power power distribution distribution subsystems subsystems to inoperable.

OPERABLE status.

I

~

Insert 2 B.

One or more AC vital bus B.1 electrical power distribution subsystems inoperable.

Vogtle Units 1 and 2 Restore AC vital bus electrical power distribution subsystems to 2hou/

OPERABLE status.

3.8.9-1 (continued)

Amendment No. +es (Unit 1)

Amendment No. 4§.4. (Unit 2)

I I

I

Distribution Systems - Operating 3.8.9 ACTIONS continued Insert 19 CONDITION C.

One or more DC electrical power distribution subsystems inoperable.

E.

Two or more electrical power distribution subsystems inoperable that result in a loss of function.

REQUIRED ACTION C.1 Restore DC electrical power distribution subsystems to OPERABLE status.

.1 Be in MODE 3.

.2

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

E.1 LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

Enter LCO 3.0.3.

SURVEILLANCE REQUIREMENTS SR 3.8.9.1 SURVEILLANCE Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

COMPLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months 6 hours 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program Insert 2 Vogtle Units 1 and 2 3.8.9-2 Amendment No..:t-79 (Unit 1)

Amendment No. 4-W (Unit 2)

Programs and Manuals

5.5 5.5 Programs and Manuals 5.5.20 5.5.21 Control Room Envelope Habitability Program (continued)

f.

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

Surveillance Frequency Control Program This program provides controls for Surveillar:ice 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.

Insert 3 Vogtle Units 1 and 2 5.5-20 Amendment No.~ (Unit 1)

Amendment No. 44G (Unit 2)

~~------ ---------

r INSERT 1 EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem A.1 Restore subsystem to 7 days inoperable.

OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program B ------------NOTES------------

B.1 Restore subsystems to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. Not applicable when OPERABLE status.

second subsystem OR intentionally made inoperable.

In accordance with the Risk

2. The following Section Informed Completion Time 5.5.22 constraints are Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two subsystems inoperable.

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 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition C must also be entered.

If a second subsystem is declared inoperable, Condition B may also be entered. The Condition is modified by two Notes. The first note states it is not applicable if the second subsystem is intentionally made inoperable. The second Note provides restrictions applicable to these "loss of function" Conditions. The Required Actions of Condition B are not intended for voluntary removal of redundant subsystems from service. The Required Action is only applicable if one subsystem is inoperable for any reason and the second subsystem is found to be inoperable, or if both subsystems are found to be inoperable at the same time. If Condition B is applicable, at least one subsystem must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or Condition C must also be entered. The licensee may be able to apply a RICT or to extend the Completion Time

beyond 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , but not longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if the requirements of the Risk Informed Completion Time Program are met. If two subsystems are inoperable and Condition B is not applicable (i.e., the second subsystem was intentionally made inoperable), LCO 3.0.3 is entered as there is no applicable Condition.

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

If the 7 day Completion Time clock of Condition A or the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time clock of Condition B have expired and subsequent changes in plant conditions result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition C is also entered and the Completion Time clocks for Required Actions C.1 and C.2 start.

If the RICT expires or is recalculated to be less than the elapsed time since the Condition was entered and the inoperable subsystem has not been restored to OPERABLE status, Condition C is also entered and the Completion Time clocks for Required Actions C.1 and C.2 start. If the inoperable subsystems are restored to OPERABLE status after Condition C is entered, Conditions A, B, and C are exited, and therefore, the Required Actions of Condition C may be terminated.

INSERT2 In accordance with the Risk Informed Completion Time Program INSERT 3 5.5.22 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEl-06-09, Revision 0-A, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a. The RICT may not exceed 30 days.

b. A RICT may only be utilized in MODE 1 and 2.

c. When a RICT is being used, any plant configuration change within the scope of the Configuration Risk Management Program must be considered for the effect on the RICT.

1. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT} or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function, or inoperability of all required trains of a system required to be OPERABLE, if one of more of the trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09. The RICT for these loss of function conditions may not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

f.

Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be

OPERABLE if one or more trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09. However, the following additional constraints shall be applied to the criteria for "PRA Functional".

1. Any SSCs credited in the PRA Functionality determination shall be the same SSCs relied upon to perform the specified Technical Specifications safety function.

2. Design basis success criteria parameters shall be met for all design basis accident scenarios for establishing PRA Functionality, during a Technical Specifications loss of function condition, where a RICT is applied.

g. Upon entering a RICT, the potential for common cause failure (CCF) must be addressed. This can be accomplished in one of two ways:

1. Adjusting the common cause factors in the configuration risk management tool, OR

2. Implementing risk management actions (RMA) which specifically address the potential for the CCF. If RMAs are chosen as the method for addressing CCFs, those RMAs must be in effect prior to reaching the front stop.

If it is determined that a CCF is not likely, the RMAs or common cause adjustment factors may be discontinued.

h.

A RICT entry is not permitted, or a RICT entry made shall be exited, for any condition involving a TS loss of Function if a PRA Functionality determination that reflects the plant configuration concludes that the LCO cannot be restored without placing the TS inoperable trains in an alignment which results in a loss of functional level PRA success criteria.

INSERT 4

f\\J()TE:S------------------------------------------------------

1. f\\Jot applicable when pressurizer safety valve intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT 5 THIS INSERT NOT USED INSERT 6 c;. --------------f\\J()TE:S------------

1. f\\Jot applicable when two or more accumulators are intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two or more accumulators inoperable for reasons other than boron concentration not within limits.

INSERT7 c;. Two sludge mixing pump isolation valves ino arable.

INSERT 8 c;.1 Restore accumulators to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

()PE:RABLE: status.

c;.1 Restore one valve to

()PE:RABLE: status.

()R In accordance with the Risk Informed (;ompletion Time Program 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months

f\\J()TE:S-----------------------------------------------------

1. f\\Jot applicable when the RWST is intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT 9

N()"fE::S------------------------------------------------------

1.

Not applicable when the second MSIV in one steam line is intentionally made inoperable.

2. "fhe following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT 10

N()"fE::S-------------------------------------------------------

1. Not applicable when the second required ARV line is intentionally made inoperable.

2. "fhe following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT 11 C. -----------N ()"f E::S--------------

C.1 Restore AFW trains to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. Not applicable when

()PE::RABLE:: status.

second AFW train intentionally

()R made inoperable.

2. "fhe following Section In accordance with the Risk 5.5.22 constraints are Informed Completion "fime applicable: parts b, c.2, c.3, d, Program e, f, g, and h.

"f wo AFW trains inoperable.

INSERT 12 B. --------------N()"fE::S------------

B.1 Restore CCW trains to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. Not applicable when

()PE::RABLE:: status.

second CCW train

()R intentionally made inoperable.

2. "fhe following Section In accordance with the Risk 5.5.22 constraints are Informed Completion "fime applicable: parts b, c.2, c.3, d, Program e, f, g, and h.

"f wo CCW trains inoperable.

INSERT 13 l3. -------------1\\l()l"E:S-------------

l3.1 Restore l\\ISCW trains to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. l\\lot applicable when

()PE:RAl3LE: status.

second l\\ISCW train

()R intentionally made inoperable.

2. "The following Section In accordance with the Risk 5.5.22 constraints are Informed Completion "Time applicable: parts b, c.2, c.3, d, Program e, f, g, and h.

"Two l\\ISCW trains inoperable.

INSERT 14 l3. ---------1\\l()l"E:S--------------

l3.1 Restore one E:SF room 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. l\\lot applicable when two cooler and safety-related E:SF room cooler and safety chiller train to ()PE:RAl3LE:

()R related chiller trains status.

intentionally made inoperable.

In accordance with the Risk

2. "The following Section Informed Completion "Time 5.5.22 constraints are Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

"Two E:SF room cooler and safety related chiller trains inoperable.

INSERT 15

1\\l()l"E:S-------------------------------------------------------

1. l\\lot applicable when second DG intentionally made inoperable.

2. "The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT 16 G. ---------------1\\l()l"E:S-----------

G.1 Restore required 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. l\\lot applicable when three inoperable AC sources to or more required AC sources

()PE:RAl3LE: status.

()R intentionally made inoperable.

2. "The following Section In accordance with the Risk 5.5.22 constraints are Informed Completion "Time applicable: parts b, c.2, c.3, d.

Program e, f, g, and h.

"Three or more required AC sources inoperable.

INSERT 17

[)_ --------------1\\J()l"E:S------------

[).1 Restore at least one [)C 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. l\\lot applicable when electrical power source to second [)C electrical power

()PE:RABLE: status.

()R source intentionally made inoperable In accordance with the Risk

2. l"he following Section Informed Completion l"ime 5.5.22 constraints are Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

l"wo [)C electrical power sources inoperable.

INSERT 18 B. -------------1\\J()l"E:S-------------

B.1 Restore required inverters 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1. l\\lot applicable when two or to ()PE:RABLE: status.

more inverters intentionally

()R made inoperable.

2. l"he following Section In accordance with the Risk 5.5.22 constraints are Informed Completion l"ime applicable: parts b, c.2, c.3, d, Program e, f, g, and h.

l"wo or more required inverters inoperable.

INSERT 19

[). ------------1\\1 ()"f E:S--------------

D.1 Restore electrical power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. l\\lot applicable when,two or distribution subsystems to more electrical power

()PE:RABLE: status to restore OR subsystems intentionally safety function.

made inoperable.

In accordance with the Risk

2. l"he following Section Informed Completion l"ime 5.5.22 constraints are Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

l"wo or more electrical power distribution subsystems inoperable that result in a loss of safety function.

INSERT20

1\\J()TE:S-------------------------------------------------------

1. !\\Jot applicable when the second containment isolation valve is intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT21

1\\J()TE:S-------------------------------------------------------

1. !\\Jot applicable when the second containment purge valve is intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT22

1\\J()TE:S-------------------------------------------------------

1. !\\Jot applicable when second block valve intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

1.3 Completion Times EXAMPLES Vogtle Units 1 and 2 EXAMPLE 1.3-7 (continued)

Completion Times 1.3 If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or any subsequent 8-hour interval from the previous performance (plus the extension allowed by SR 3.0.2),

Condition Bis entered. The Completion Time clock for Condition A does not stop after Condition Bis entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition Bis entered, Condition Bis exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.

(continued) 1.3-13 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

1.3 Completion Times EXAMPLES (continued)

Vogtle Units 1 and 2 EXAMPLE 1.3-8 ACTIONS CONDITION A.

One subsystem inoperable.

B.

NOTES----

1. Not applicable when second subsystem intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable:

parts b, c.2, c.3, d, e, f, g, and h.

Two subsystems inoperable.

C. Required Action and associated Completion Time not met.

1.3-14 Completion Times 1.3 REQUIRED ACTION COMPLETION TIME A.1 B.1 C.1 C.2 Restore 7 days subsystem to OPERABLE OR status.

In accordance with the Risk Informed Completion Time Program Restore 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months subsystems to OPERABLE OR status.

In accordance with the Risk Informed Completion Time Program Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND Be in MODE 5.

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

Amendment No.

(Unit 1)

(Unit 2)

Completion Times 1.3 1.3 Completion Times EXAMPLES Vogtle Units 1 and 2 EXAMPLE 1.3-8 (continued)

When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2.

However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition C must also be entered.

If a second subsystem is declared inoperable, Condition B may also be entered. The Condition is modified by two Notes. The first note states it is not applicable if the second subsystem is intentionally made inoperable. The second note provides restrictions applicable to these "loss of function" Conditions. The Required Actions of Condition B are not intended for voluntary removal of redundant subsystems from service. The Required Action is only applicable if one subsystem is inoperable for any reason and the second subsystem is found to be inoperable, or if both subsystems are found to be inoperable at the same time. If Condition B is applicable, at least one subsystem must be restored to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or Condition C must also be entered. The licensee may be able to apply a RICT or to extend the Completion Time beyond 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , but not longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , if the requirements of the Risk Informed Completion Time Program are met.

If two subsystems are inoperable and Condition B is not applicable (i.e.,

the second subsystem was intentionally made inoperable), LCO 3.0.3 is entered as there is no applicable Condition.

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

If the 7 day Completion Time clock of Condition A or the 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time clock of Condition B have expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition C is also entered and the Completion Time clocks for Required Actions C.1 and C.2 start.

1.3-15 Amendment No.

Amendment No.

(continued)

(Unit 1)

(Unit 2)

Completion Times 1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-8 (continued)

If the RICT expires or is recalculated to be less than the elapsed time since the Condition was entered and the inoperable subsystem has not been restored to OPERABLE Status, Condition C is also entered and the Completion Time clocks for Required Actions C.1 and C.2 start. If the inoperable subsystems are restored to OPERABLE status after Condition C is entered, Conditions A, B, and C are exited, and therefore, the Required Actions of Condition C may be terminated.

IMMEDIATE When "Immediately" is used as a Completion Time, the COMPLETION TIME Required Action should be pursued without delay and in a controlled manner.

Vogtle Units 1 and 2 1.3-16 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.10 Pressurizer Safety Valves Pressurizer Safety Valves 3.4.10 LCO 3.4.1 O Three pressurizer safety valves shall be OPERABLE with lift settings

2410 psig and

s; 2510 psig.

APPLICABILITY:

MODES 1, 2, and 3.

MODE 4 with all RCS cold leg temperatures > the COPS arming temperature specified in the PTLR.

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

The lift settings are not required to be within the LCO limits during MODE 3 and MODE 4 with all RCS cold leg temperatures > the COPS arming temperature specified in the PTLR for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. This exception is allowed for 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months following entry into MODE 3 provided a preliminary cold setting was made prior to heatup.

ACTIONS CONDITION A.

NOTES----------

A.1

1. Not applicable when pressurizer safety valve intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

One pressurizer safety valve inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION Restore valve to OPERABLE status.

3.4.10-1 COMPLETION TIME 15 minutes In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION B.

Required Action and associated Completion Time not met.

B.1 REQUIRED ACTION Be in MODE 3.

Pressurizer Safety Valves 3.4.10 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR B.2 Be in MODE 4 with any 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months RCS cold leg temperature Two or more pressurizer safety valves inoperable.

s; the COPS arming temperature specified in the PTLR.

SURVEILLANCE REQUIREMENTS SR 3.4.10.1 SURVEILLANCE Verify each pressurizer safety valve is OPERABLE in accordance with the lnservice Testing Program. Following testing, lift settings shall be within +/- 1 %.

Vogtle Units 1 and 2 3.4.10-2 FREQUENCY In accordance with the I nservice Testing Program Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

Se pa rate Condition entry is allowed for each PORV and each block valve.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more PORVs A.1 Close and maintain power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable and capable to associated block valve.

of being manually cycled.

B.

One PORV inoperable B.1 Close associated block 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months and not capable of being valve.

manually cycled.

AND B.2 Remove power from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated block valve.

AND B.3 Restore PORV to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program (continued)

Vogtle Units 1 and 2 3.4.11-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION C.

One block valve C.1 inoperable.

AND C.2 D.

Required Action and D.1 associated Completion Time of Condition A, B, AND or C not met.

D.2 E.

Two PORVs inoperable E.1 and not capable of being manually cycled.

AND E.2 AND E.3 AND E.4 Vogtle Units 1 and 2 REQUIRED ACTION Place associated PORV in manual control.

Restore block valve to OPERABLE status.

Be in MODE 3.

Be in MODE 4.

Close associated block valves.

Remove power from associated block valves.

Be in MODE 3.

Be in MODE 4.

3.4.11-2 Pressurizer PORVs 3.4.11 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours (continued)

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION F.

NOTES-----------

1. Not applicable when second block valve intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

Two block valves inoperable.

G.

Required Action and associated Completion Time of Condition F not met.

Vogtle Units 1 and 2 REQUIRED ACTION F.1 Restore one block valve to OPERABLE status.

G.1 Be in MODE 3.

AND G.2 Be in MODE4.

3.4.11-3 Pressurizer PORVs 3.4.11 COMPLETION TIME 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS SR 3.4.11.1 SR 3.4.11.2 SURVEILLANCE

N 0 TES-----------------------------

1. Not required to be performed with block valve closed in accordance with the Required Actions of this LCO.

2. Only required to be performed in MODES 1 and 2.

Perform a complete cycle of each block valve.

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

0 n ly required to be performed in MODES 1 and 2.

Perform a complete cycle of each PORV.

Vogtle Units 1 and 2 3.4.11-4 Pressurizer PORVs 3.4.11 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.1 Accumulators LCO 3.5.1 Four ECCS accumulators shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2, MODE 3 with pressurizer pressure > 1000 psig.

ACTIONS CONDITION REQUIRED ACTION A.

One accumulator A.1 Restore boron inoperable due to boron concentration to within concentration not within limits.

limits.

B.

One accumulator B.1 Restore accumulator to inoperable for reasons OPERABLE status.

-~ other than Condition A.

C.

N 0 TES------------

C.1 Restore accumulators to

1.

Not applicable OPERABLE status.

when two or more accumulators are intentionally made inoperable.

2.

The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two or more accumulators inoperable for reasons other than boron concentration not within limits.

Vogtle Units 1 and 2 3.5.1-1 Accumulators 3.5.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months 24 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION D.

Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 D.2 SURVEILLANCE REQUIREMENTS REQUIRED ACTION Be in MODE 3.

Reduce pressurizer pressure to ::; 1000 psig.

SURVEILLANCE SR 3.5.1.1 Verify each accumulator isolation valve is fully open.

Accumulators 3.5.1 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program SR 3.5.1.2 Verify borated water volume in each accumulator is ~ 6555 gallons and ::; 6909 gallons.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.3 Verify nitrogen cover pressure in each accumulator is~ 617 psig and::; 678 psig.

Vogtle Units 1 and 2 3.5.1-2 In accordance with the Surveillance Frequency Control Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE Accumulators 3.5.1 FREQUENCY SR 3.5.1.4 Verify boron concentration in each accumulator is

?: 1900 ppm and ::::; 2600 ppm.

In accordance with the Surveillance Frequency Control Program SR 3.5.1.5 Verify power is removed from each accumulator isolation valve operator when pressurizer pressure is > 1000 psig.

Vogtle Units 1 and 2 3.5.1-3 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 In accordance with the Surveillance Frequency Control Program Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ECCS - Operating 3.5.2

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

1 n MODE 3, either residual heat removal pump to cold legs injection flow path may be isolated by closing the isolation valve to perform pressure isolation valve testing per SR 3.4.14.1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more trains A.1 Restore train(s) to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable.

OPERABLE status.

OR AND In accordance with At least 100% of the the Risk Informed ECCS flow equivalent to Completion Time a single OPERABLE Program ECCS train available.

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 Vogtle Units 1 and 2 3.5.2-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A.

RWST boron A.1 Restore RWST to concentration not within OPERABLE status.

limits.

OR RWST borated water temperature not within limits.

B.

One sludge mixing B.1 Restore the valve to pump isolation valve OPERABLE status.

inoperable.

Vogtle Units 1 and 2 3.5.4-1 RWST 3.5.4 COMPLETION TIME 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months 24 hours OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION C.

Two sludge mixing pump isolation valves inoperable.

D.

Required Action and associated Completion Time of Condition B or C not met.

E.

NOTES----------

1. Not applicable when the RWST is intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

RWST inoperable for reasons other than Condition A, B, or C.

Vogtle Units 1 and 2 REQUIRED ACTION C.1 Restore one valve to OPERABLE status.

D.1" Isolate the sludge mixing system.

E.1 Restore *RWST to OPERABLE status.

3.5.4-2 RWST 3.5.4 COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 6 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION F.

Required Action and F.1 associated Completion Time of Condition A or E AND not met.

REQUIRED ACTION Be in MODE 3.

RWST 3.5.4 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months F. 2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

SURVEILLANCE REQUIREMENTS SR 3.5.4.1 SR 3.5.4.2 SURVEILLANCE

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

0 n I y required to be performed when ambient air temperature is < 40°F.

Verify RWST borated water temperature is

~ 44°F and::;; 116°F.

Verify RWST borated water volume is ~ 686,000 gallons.

Vogtle Units 1 and 2 3.5.4-3 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SR 3.5.4.3 SR 3.5.4.4 SURVEILLANCE Verify RWST boron concentration is :?: 2400 ppm and s 2600 ppm.

Verify each sludge mixing pump isolation valve automatically closes on an actual or simulated RWST Low-Level signal.

Vogtle Units 1 and 2 3.5.4-4 FREQUENCY RWST 3.5.4 In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION

c.

One or more C.1 containment air locks inoperable for reasons other than Condition A or B.

AND C.2 AND I

C.3 D.

Required Action and D.1 associated Completion Time not met.

AND D.2 Vogtle Units 1 and 2 REQUIRED ACTION Initiate action to evaluate overall containment leakage rate per LCO 3.6.1.

Verify a door is closed in the affected air lock.

Restore air lock to OPERABLE status.

Be in MODE 3.

Be in MODE 5.

3.6.2-4 Containment Air Locks 3.6.2 COMPLETION TIME Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 hours OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.6 CONTAINMENT SYSTEMS 3.6.3 Containment Isolation Valves Containment Isolation Valves 3.6.3 LCO 3.6.3 Each containment isolation valve shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS

NOTES-----------------------------------------------------------

1.

Penetration flow path(s) (except for 24 inch purge valves) may be unisolated intermittently under administrative controls.

2.

Separate Condition entry is allowed for each penetration flow path.

3.

Enter applicable Conditions and Required Actions for systems made inoperable by containment isolation valves.

4.

Enter applicable Conditions and Required Actions of LCO 3.6.1, "Containment," when isolation valve leakage results in exceeding the overall containment leakage rate acceptance criteria.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more penetration A.1 Isolate the affected 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months flow paths with one penetration flow path by containment isolation use of at least one closed OR valve inoperable except and de-activated for purge valve leakage automatic valve, closed In accordance with not within limit.

manual valve, blind the Risk Informed flange, or check valve Completion Time with flow through the Program valve secured.

AND (continued)

Vogtle Units 1 and 2 3.6.3-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS CONDITION A.

(continued)

A.2 B.

NOTES-----------

8.1

1. Not applicable when the second containment isolation valve is intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

One or more penetration flow paths with two containment isolation valves inoperable except for purge valve leakage not within limit.

Vogtle Units 1 and 2 Containment Isolation Valves 3.6.3 REQUIRED ACTION COMPLETION TIME

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

Isolation devices in high radiation areas may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

3.6.3-2 Once per 31 days for isolation devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION C. ----------NOTES-----------

1. Not applicable when the second containment purge valve is intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

One or more penetration flow paths with one or more containment purge valves not within purge valve leakage limits.

Vogtle Units 1 and 2 C.1 AND C.2 Containment Isolation Valves 3.6.3 REQUIRED ACTION Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

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

1 so I ati on devices in high radiation areas may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

3.6.3-3 COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months In accordance with the Risk Informed

, Completion Time Program Once per 31 days for isolation devices outside containment Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment (continued)

Amendment No.

(Unit 1)

(Unit 2)

3.6 CONTAINMENT SYSTEMS Containment Spray and Cooling Systems 3.6.6 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One containment spray A.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months train inoperable.

spray train to OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program B.

One containment B.1 Restore containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months cooling train inoperable.

cooling train to OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program 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 A or B AND not met.

C.2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Vogtle Units 1 and 2 3.6.6-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

MS I Vs 3.7.2 LCO 3.7.2 Two MSIV systems per steam line shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when one MSIV system in each steam line is closed.

ACTIONS

"'-------------------------------------------NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each steam line.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more steam line A.1 Restore MSIV to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months with one MSIV system OPERABLE status.

OR inoperable in MODE 1.

In accordance with the Risk Informed Completion Time Program B.

NOTES----------

B.1 Restore one MSIV 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

1. Not applicable when system to OPERABLE the second MSIV in status in affected steam OR one steam line is line.

In accordance with the intentionally made Risk Informed inoperable.

Completion Time

2. The following Program Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

One or more steam lines with two MSIV systems inoperable in MODE 1.

(continued)

Vogtle Units 1 and 2 3.7.2-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION C.

Required Action and C.1 Be in MODE 2.

associated Completion Time of Condition A or B not met.

D.

One or more steam lines D.1 Verify one MSIV system with one MSIV system closed in affected steam inoperable in MODE 2 or line.

3.

E.

One or more steam lines E.1 Verify one MSIV system with two MSIV systems closed in affected steam inoperable in MODE 2 or line.

3.

F.

Required Action and F.1 Be in MODE 3.

associated Completion Time of Condition D or AND E not met.

F.2 Be in MODE 4.

SURVEILLANCE REQUIREMENTS SR 3.7.2.1 SURVEILLANCE

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

0 n ly required to be performed in MODES 1 and 2.

Verify closure time of each MSIV system is

5 seconds on an actual or simulated actuation signal.

Vogtle Units 1 and 2 3.7.2-2 MSIVs 3.7.2 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 7 days AND Once per 7 days thereafter.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months AND Once per 7 days thereafter 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the lnservice Testing Program Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.7 PLANT SYSTEMS A RVs 3.7.4 3.7.4 Atmospheric Relief Valves (ARVs)

LCO 3.7.4 Three ARV lines shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3 ACTIONS CONDITION A.

One required ARV line A.1 inoperable.

B.

N 0 TES----------

B.1

1. Not applicable when the second required ARV line is intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two or more required ARV lines inoperable.

C.

Required Action and C.1 associated Completion Time not met.

AND C.2 Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore required ARV line 30 days to OPERABLE status.

Restore at least two ARV 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months lines to OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Be in MODE 4 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months 3.7.4-1 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

3.7 PLANT SYSTEMS AFW System 3.7.5 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFWtrains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

.----------NOTE--------------------------------------------------------

LCO 3.0.4b is not applicable.

CONDITION A.

One steam supply to turbine driven AFW pump inoperable.

OR

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

Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

Vogtle Units 1 and 2 A.1 REQUIRED ACTION COMPLETION TIME Restore affected 7 days equipment to OPERABLE status.

OR 3.7.5-1 In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION B.

One AFW train inoperable for reasons other than Condition A.

C.

NOTES----------

1. Not applicable when second AFW train intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two AFW trains inoperable.

D.

Required Action and associated Completion Time for Condition A, B, or C not met.

Vogtle Units 1 and 2 REQUIRED ACTION B.1 Restore AFW train to OPERABLE status.

C. 1 Restore AFW trains to OPERABLE status.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

3.7.5-2 AFWSystem 3.7.5 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION E.

Three AFW trains inoperable.

E.1

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

LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SR 3.7.5.1 SURVEILLANCE

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

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

AFWSystem 3.7.5 COMPLETION TIME Immediately FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.7.5-3 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE AFWSystem 3.7.5 FREQUENCY SR 3.7.5.2

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~ 900 psig in the steam generator.

Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

In accordance with the Surveillance Frequency Control Program SR 3.7.5.3

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

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position actuates to the correct position on an actual or simulated actuation signal.

Vogtle Units 1 and 2 3.7.5-4 In accordance with the Surveillance Frequency Control Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.5.4 SR 3.7.5.5 SR 3.7.5.6 SURVEILLANCE

N 0 TES-----------------------------

1. 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.

2. AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW pump starts automatically on an actual or simulated actuation signal.

Verify that each AFW pumphouse ESF supply fan starts and associated dampers actuate on a simulated or actual actuation signal.

Verify that the ESF outside air intake and exhaust dampers for the turbine-driven AFW pump actuate on a simulated or actual actuation signal.

AFWSystem 3.7.5 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.7.5-5 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water (CCW) System LCO 3.7.7 Two CCWtrains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION CCWSystem 3.7.7 COMPLETION TIME A.

One CCW train A.1

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

inoperable.

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4,"

for residual heat removal loops made inoperable by CCW.

Restore CCW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

OR In accordance with the Risk lnforme,d Completion Time Program B.

N 0 TES----------

B.1 Restore CCW trains to 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. Not applicable when OPERABLE status.

second CCW train OR intentionally made inoperable.

In accordance with

2. The following the Risk Informed Section 5.5.22 Completion Time constraints are Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two CCW trains inoperable.

(continued)

Vogtle Units 1 and 2 3.7.7-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION C.

Required Action and C.1 Be in MODE 3.

associated Completion Time of Condition A or B AND not met.

C. 2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

SURVEILLANCE REQUIREMENTS SR 3.7.7.1 SR 3.7.7.2 SURVEILLANCE

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

1 so I a ti on of CCW flow to individual components does not render the CCW System inoperable.

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

Verify each CCW pump starts automatically on an actual or simulated actuation signal.

CCWSystem 3.7.7 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.7.7-2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.7 PLANT SYSTEMS 3.7.8 Nuclear Service Cooling Water (NSCW) System LCO 3.7.8 Two NSCWtrains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION A.

One NSCW train inoperable.

REQUIRED ACTION

NO TES-------------------

1.

Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," for emergency diesel generator made inoperable by NSCW system.

2.

Enter applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops - MODE 4," for residual heat removal loops made inoperable by NSCW system.

A.1 Restore NSCW system to OPERABLE status.

NSCW 3.7.8 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program (continued)

Vogtle Units 1 and 2 3.7.8-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION B.

N 0 TES----------

1. Not applicable when second NSCWtrain intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two NSCW trains inoperable.

C.

Required Action and associated Completion Time of Condition A or B not met.

Vogtle Units 1 and 2 REQUIRED ACTION B.1 Restore NSCW trains to OPERABLE status.

C.1 Be in MODE 3.

AND C.2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

3.7.8-2 NSCW 3.7.8 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS SR 3.7.8.1 SR 3.7.8.2 SR 3.7.8.3 SURVEILLANCE

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

1 so I ati on of NSCW system flow to individual components does not render the NSCW system inoperable.

Verify each NSCW system manual, power operated, and automatic valve in the flow path servicing safety related equipment, that is not locked, sealed, or otherwise secured in position, is in the correct position.

Verify each NSCW system automatic valve in the flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

Verify each NSCW system pump starts automatically on an actual or simulated actuation signal.

NSCW 3.7.8 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.7.8-3 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS)

UHS 3.7.9 LCO 3.7.9 The UHS shall be OPERABLE. The fans/spray cells shall be as specified in Figure 3.7.9-1.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One or more Nuclear A.1 Service Cooling Water (NSCW) basins with water temperature and/or water level not within limits.

B.

One NSCW cooling B.1 tower with one required fan/spray cell inoperable when operating in four fan/spray cell required region of Figure 3.7.9-1.

C.

One NSCW cooling C. 1 tower with one or more required fans/spray cells inoperable for reasons other than Condition B.

Vogtle Units 1 and 2 Restore water 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months temperature(s) and water level(s) to within limits.

Restore fan to OPERABLE status.

Restore fan(s)/spray cell(s) to OPERABLE status.

3.7.9-1 7 days OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

(Unit 2)

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 A.

One ESF room cooler A.1 and safety-related chiller train inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore the ESF room 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months cooler and safety-related chiller train to OPERABLE OR status.

3.7.14-1 In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ESF Room Cooler and Safety-Related Chiller System 3.7.14 ACTIONS (continued)

CONDITION REQUIRED ACTION B.

NOTES----------

B.1 Restore one ESF room

1. Not applicable when cooler and safety-related two ESF room chiller train to OPERABLE cooler and safety-status.

related chiller trains intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two ESF room cooler and safety-related chiller trains inoperable.

C.

Required Action and C. 1 Be in MODE 3.

Completion Time of Condition A or B not AND met.

C.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SR 3.7.14.1 SURVEILLANCE Verify each ESF room cooler and safety-related chiller system manual, power-operated and automatic valve servicing safety-related equipment that is not locked, sealed, or otherwise secured in position, is in the correct position.

COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.7.14-2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ESF Room Cooler and Safety-Related Chiller System 3.7.14 SURVEILLANCE REQUIREMENTS (continued)

SR 3.7.14.2 SR 3.7.14.3 SURVEILLANCE Verify each ESF room cooler and safety-related chiller system automatic valve servicing safety-related equipment that is not locked, sealed, or otherwise secured in position actuates to the correct position on an actual or simulated actuation signal.

Verify each ESF room cooler fan and safety-related chiller system (pump and chiller) start automatically on an actual or simulated actuation signal.

Vogtle Units 1 and 2 3.7.14-3 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS CONDITION A. (continued)

Vogtle Units 1 and 2 A.2 AND A.3 REQUIRED ACTION Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

Restore required offsite circuit to OPERABLE status.

AC Sources - Operating 3.8.1 COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months In accordance with the Risk Informed Completion Time Program (continued) 3.8.1-2 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION B.

One DG inoperable.

B.1 AND B.2 AND B.3.1 OR B.3.2 AND Vogtle Units 1 and 2 REQUIRED ACTION Perform SR 3.8.1.1 for the required offsite circuit(s).

Declare required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable.

Determine OPERABLE DG is not inoperable due to common cause failure.

Perform SR 3.8.1.2 for OPERABLE DG.

AC Sources - Operating 3.8.1 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours (continued) 3.8.1-3 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS CONDITION B.

(continued)

C.

Two required offsite circuits inoperable.

D.

One required offsite circuit inoperable.

AND One DG inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION B.4 Restore DG to OPERABLE status.

C. 1 Declare required feature(s) inoperable when its redundant feature(s) is inoperable.

AND C.2 Restore one required offsite circuit to OPERABLE status

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

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating,"

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

AC Sources - Operating 3.8.1 COMPLETION TIME 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition C concurrent with inoperability of redundant required features 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program (continued) 3.8.1-4 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS CONDITION D.

(continued)

D.1 OR D.2 E.

N 0 TES----------

E.1

1. Not applicable when second DG intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two DGs inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION Restore required offsite circuit to OPERABLE status.

AC Sources - Operating 3.8.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Risk Informed Completion Time Program Restore DG to OPERABLE 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months status.

Restore one DG to OPERABLE status.

3.8.1-5 OR In accordance with the Risk Informed Completion Time Program 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No. 179 (Unit 1)

Amendment No. 160 (Unit 2)

ACTIONS (continued)

CONDITION F.

One automatic load sequencer inoperable.

G.

N 0 TES----------

1. Not applicable when three or more required AC sources intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

Three or more required AC sources inoperable.

H.

Required Action and associated Completion Time of Condition A, B, C, D, E, F, or G not met.

Vogtle Units 1 and 2 F.1 G.1 H.1 AND H.2 REQUIRED ACTION Restore automatic load sequencer to OPERABLE status.

Restore required inoperable AC sources to OPERABLE status.

Be in MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE4.

AC Sources - Operating 3.8.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Risk Informed Completion Time Program 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 3.8.1-6 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

DC Sources - Operating 3.8.4 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 Four class 1 E 125 V DC electrical power sources shall be OPERABLE.

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

ACTIONS CONDITION A.

One DC electrical power source inoperable due to inoperable battery A or B.

Vogtle Units 1 and 2 REQUIRED ACTION

NO TE---------.:. ______ _

Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating," for emergency diesel generator made inoperable by inoperable battery A or B.

A.1 Restore DC electrical power source to COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OPERABLE status.

OR 3.8.4-1 In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION B.

One DC electrical power B.1 source inoperable due to inoperable battery C or D.

AND B.2 C.

One DC electrical power C.1 source inoperable for reasons other than Condition A or B.

D.

,.----------NOTES----------

D.1

1. Not applicable when second DC electrical power source intentionally made inoperable.

2. The following Section

. 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

Two DC electrical power sources inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION Verify SAT available Restore DC electrical power source to OPERABLE status.

Restore DC electrical power source to OPERABLE status.

Restore at least one DC electrical power source to OPERABLE status.

3.8.4-2 DC Sources - Operating 3.8.4 COMPLETION TIME 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 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

L ACTIONS (continued)

CONDITION REQUIRED ACTION E.

Required Action and E.1 Be in MODE 3.

Associated Completion Time of Condition A, B, C, AND or D not met.

E.2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

SURVEILLANCE REQUIREMENTS SR 3.8.4.1 SURVEILLANCE Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

DC Sources - Operating 3.8.4 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.4-3 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.4.2 SR 3.8.4.3 SURVEILLANCE Verify the battery charger supplies:

~ 400 amps for System A and B

~ 300 amps for System C, and

~ 200 amps for System D 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 B and ~ 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.

N 0 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 maintain in OPERABLE status, the required emergency loads for the design duty cycle when subjected to a battery service test.

DC Sources - Operating 3.8.4 FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.4-4 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Inverters - Operating 3.8.7 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating LCO 3.8.7 APPLICABILITY:

ACTIONS The required Class 1 E 120 V inverters shall be OPERABLE.

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

T wo inverters may be disconnected from their associated DC bus for

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an equalizing charge on their associated common battery, provided

a.

The associated AC vital bus( es) are energized from their Class 1 E regulating transformers; and

b.

All other AC vital buses are energized from their associated OPERABLE inverters.

MODES 1, 2, 3, and 4.

CONDITION REQUIRED ACTION COMPLETION TIME A.

One required inverter inoperable.

Vogtle Units 1 and 2

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

Enter applicable conditions and required actions of LCO 3.8.9 "Distribution Systems - Operating" with any vital bus deenergized.

A.1 Restore inverter to OPERABLE status.

3.8.7-1 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS CONDITION REQUIRED ACTION B.

N 0 TES----------

B.1 Restore required inverters

1. Not applicable when to OPERABLE status.

two or more inverters intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

Two or more required inverters inoperable.

C.

Required Action and C.1 Be in MODE 3.

associated Completion Time not met.

AND C.2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.8.7.1 Verify correct inverter voltage and alignment to required AC vital buses.

Inverters - Operating 3.8.7 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.7-2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 The required AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

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

The redundant emergency buses of 4160 V switchgear 1 /2AA02 and 1/2BA03 may be manually connected within the unit by tie breakers in order to allow transfer of preferred offsite power sources provided SR 3.8.1.1 is successfully performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to the interconnection. The interconnection shall be implemented without adversely impacting the ability to simultaneously sequence both trains of LOCA loads.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION A.

One or more AC A.1 electrical power distribution subsystems inoperable.

B.

One or more AC vital bus B.1 electrical power distribution subsystems inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore AC electrical 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months power distribution subsystems to OR OPERABLE status.

In accordance with the Risk Informed Completion Time Program Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months electrical power distribution subsystems to OR OPERABLE status.

3.8.9-1 In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION C.

One or more DC electrical power distribution subsystems inoperable.

D.

N 0 TES----------

1. Not applicable when two or more electrical power subsystems intentionally made inoperable.

2. The following Section 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and

h.

Two or more electrical power distribution subsystems inoperable that result in a loss of safety function.

E.

Required Action and associated Completion Time not met.

Vogtle Units 1 and 2 C. 1 D.1 E.1 AND E.2 Distribution Systems - Operating 3.8.9 REQUIRED ACTION COMPLETION TIME Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power distribution subsystems to OR OPERABLE status.

In accordance with the Risk Informed Completion Time Program Restore electrical power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months distribution subsystems to OPERABLE status to OR restore safety function.

In accordance with the Risk Informed Completion Time Program Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

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

LCO 3.0.4.a is not applicable when entering MODE 4.

Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 3.8.9-2 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Distribution Systems - Operating 3.8.9 SURVEILLANCE REQUIREMENTS SR 3.8.9.1 SURVEILLANCE Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

FREQUENCY In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.9-3 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 5.5.21 5.5.22 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.

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

a.

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

b.

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

c.

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

Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEl-06-09, Revision 0-A, "Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following:

a.

The RICT may not exceed 30 days.

b.

A RICT may only be utilized in MODE 1 and 2.

c.

When a RICT is being used, any plant configuration change within the scope of the Configuration Risk Management Program must be considered for the effect on the RICT.

1.

For planned changes, the revised RICT must be determined prior to implementation of the change in configuration.

(continued)

Vogtle Units 1 and 2 5.5-20 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.22 Risk Informed Completion Time Program (continued)

2.

For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,

not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3.

Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d.

Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e.

Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function, or inoperability of all required trains of a system required to be OPERABLE, if one of more of the trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09.

The RICT for these loss of function conditions may not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

f.

Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09. However, the following additional constraints shall be applied to the criteria for "PRA Functional".

1.

Any SSCs credited in the PRA Functionality determination shall be the same SSCs relied upon to perform the specified Technical Specifications safety function.

2.

Design basis success criteria parameters shall be met for all design basis accident scenarios for establishing PRA Functionality during a Technical Specifications Loss of Function Condition where a RICT is applied.

g.

Upon entering a RICT, the potential for common cause failure (CCF) must be addressed. This can be accomplished in one of two ways:

1.

Adjusting the common cause factors in the configuration risk management tool, OR

2.

Implementing risk management actions (RMA) which specifically address the potential for the CCF. If RMAs are chosen as the method for addressing the potential for the CCF, those RMAs must be in effect prior to reaching the front stop.

If it is determined that a CCF is not likely, the RMAs or common cause adjustment factors may be discontinued.

h.

A RICT entry is not permitted, or a RICT entry made shall be exited, for any condition involving a TS loss of Function if a PRA Functionality determination that reflects the plant configuration concludes that the LCO cannot be restored without placing the TS inoperable trains in an alignment which results in a loss of functional level PRA success criteria.

Vogtle Units 1 and 2 5.5-21 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

1 Vogtle Electric Generating Plant Response to Request.for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times Marked-Up and Clean Operating License Pages

7.

Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders (11) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. ~are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D.

The facility requires exemptions from certain requirements of 1 O CFR Part 50 and 1 O CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph lll.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required.

The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 5.

An exemption was previously granted pursuant to 10 CFR 70.24. The exemption was granted with NRC materials license No. SNM-1967, issued August 21, 1986, and relieved GPC from the requirement of having a criticality alarm system. GPC and Southern Nuclear are hereby exempted from the criticality alarm system provision of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The exemptions in items b and c above are granted pursuant to 10 CFR 50.12. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 162.

F.

GPC shall comply with the antitrust conditions delineated in Appendix C to this license.

Renewed Operating License No. NPF-68 Amendment No. ~

Amendment Additional Condition Implementation Number Date 102 The licensee will implement all applicable crane, load path and Before and height, rigging and load testing guidelines of NUREG-0612 and during ANSI Standard 830.2, as described in the licensee's letters dated re racking September 4, 1997, May 19 and June 12, 1998, and evaluated in operations, as the staffs Safety Evaluation dated June 29, 1998 appropriate.

154 Upon implementation of the Amendment adopting TSTF-448, Revision 3, As stated in the the determination of CRE unfiltered air inleakage as required by SR Additional 3.7.10.5, in accordance with TS 5.5.20.c.(i), and Condition the measurement of CFE pressure as required by Specification 5.5.20.d, shall be considered met. Following implementation:

(a)

The first performance of SR 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b)

The first performance of the periodic assessment of CRE habitability, specification 5.5.20.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

The first performance of the periodic measurement of CRE pressure, specification 5.5.20.d, shall be within 18 months, plus the 138 days allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

173 Southern Nuclear Operating Company (SNC) is approved to implement As stated in the 10 CFR 50.69 using the processes for categorization of Risk-Informed Additional Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, Condition and components (SSCs) specified in the licensee amendment request submittals dated August 31, 2012, May 17, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval, under 10 CFR 50.90, is required for a change to a categorization process that is outside the bounds specified above (e.g.,

change from a seismic margins approach to a seismic probabilistic risk assessment approach).

'Insert OL 1 here.

I Vogtle Unit 1 D-2 Amendment No..:t-7J

OL 1 Insert Southern Nuclear Operating Company (SNC) is As stated in the additional approved to implement the Risk Informed Completion Condition.

Time Program as specified in the license amendment request submittals dated September 13, 2012, August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, May 5, 2015, February 17, 2016, April 18, 2016, July 13, 2016, March 13, 2017, and April 14, 2017.

The licensee shall implement the items listed in, Implementation items of SNC letter NL-15-0381 dated March 16, 2015 prior to the implementation of the Risk Informed Completion Time Program.

The risk assessment approach and methods, shall be acceptable to the NRG, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRG for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRG approval, via a license amendment.

I I_ successfully demonstrated prior to the time and condition specified below for each:

a)

DELETED b)

DELETED c)

SR 3.8.1.20 shall be successfully demonstrated at the first regularly scheduled performance after implementation of this license amendment.

(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)

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 *

7.

Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders (5)

Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. ~. are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D.

The facility requires exemptions from certain requirements of 1 O CFR Part 50 and 1 O CFR Part 70. These include (a) an exemption from the requirements of 1 O CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph lll.D.2(b)(ii) of Appendix J of 1 O CFR 50, the testing of containment air locks at times when containment integrity is not required. The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 8.

Renewed Operating License NPF-81 Amendment No. ~

L Amendment Number 155 Additional Condition Southern Nuclear Operating Company (SNC) is approved to implement 1 O CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the licensee amendment request submittals dated August 31, 2012, May 17, 2013, July 2, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval, under 1 O CFR 50.90, is required for a change to a categorization process that is outside the bounds specified above (e.g.,

change from a seismic margins approach to a seismic probabilistic risk assessment approach.)

---i Insert OL 2 here I

I.____ __

Implementation Date As stated in the Additional Condition Vogtle Unit 2 D-2 Amendment No. ~

OL 2 Insert Southern Nuclear Operating Company (SNC) is As stated in the additional approved to implement the Risk Informed Completion Condition.

Time Program as specified in the license amendment request submittals dated September 13, 2012, August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, May 5, 2015, February 17, 2016, April 18, 2016, July 13, 2016, March 13, 2017, and April 14, 2017.

The licensee shall implement the items listed in, Implementation items of SNC letter NL-15-0381 dated March 16, 2015 prior to the implementation of the Risk Informed Completion Time Program.

The risk assessment approach and methods, shall be acceptable to the NRG, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRG for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRG approval, via a license amendment.

7.

Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders (11) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No.

, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D.

The facility requires exemptions from certain requirements of 1 O CFR Part 50 and 1 O CFR Part 70. These include (a) an exemption from the requirements of 1 O CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph lll.D.2(b)(ii) of Appendix J of 10 CFR 50, the*

testing of containment air locks at times when containment integrity is not required.

The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 5.

An exemption was previously granted pursuant to 10 CFR 70.24. The exemption was granted with NRG materials license No. SNM-1967, issued August 21, 1986, and relieved GPC from the requirement of having a criticality alarm system. GPC and Southern Nuclear are hereby exempted from the criticality alarm system provision of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The exemptions in items b and c above are granted pursuant to 1 O CFR 50.12. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 1 O CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 162.

F.

GPC shall comply with the antitrust conditions delineated in Appendix C to this license.

Renewed Operating License No. NPF-68 Amendment No.

Amendment Additional Condition Implementation Number Date Southern Nuclear Operating Company (SNC) is approved to As stated in implement the Risk Informed Completion Time Program as the additional specified in the license amendment request submittals dated Condition.

September 13, 2012, August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, May 5, 2015, February 17, 2016, April 18, 2016, July 13, 2016, March 13, 2017, and April 14, 2017.

The licensee shall implement the items listed in Enclosure 1,

Implementation items of SNC letter NL-15-0381 dated March 16, 2015 prior to the implementation of the Risk Informed Completion Time Program.

The risk assessment approach and methods, shall be acceptable to the NRG, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRG for generic use. If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRG approval, via a license amendment.

Vogtle Unit 1 D-3 Amendment No.

successfully demonstrated prior to the time and condition specified below for each:

a)

DELETED b)

DELETED c)

SR 3.8.1.20 shall be successfully demonstrated at the first regularly scheduled performance after implementation of this license amendment.

(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)

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

7.

Spent fuel pool mitigation measures (c)

Actions to minimize release to include consideration of:

1.

Water spray scrubbing

2.

Dose to onsite responders (5)

Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No.

, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D.

The facility requires exemptions from certain requirements of 1 O CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph lll.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of,

containment air locks at times when containment integrity is not required. The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 8.

Renewed Operating License NPF-81 Amendment No.

Amendment Additional Condition lmplementatio Number n Date 155 Southern Nuclear Operating Company (SNC) is approved to As stated in implement 1 O CFR 50.69 using the processes for categorization of the Additional Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 Condition structures, systems, and components (SSCs) specified in the licensee amendment request submittals dated August 31, 2012, May 17, 2013, July 2, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval, under 1 O CFR 50.90, is required for a change to a categorization process that is outside the bounds specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach.)

Southern Nuclear Operating Company (SNC) is approved to As stated in implement the Risk Informed Completion Time Program as specified the additional in the license amendment request submittals dated September 13, Condition.

2012, August 2, 2013, July 17, 2014, November 11, 2014, December 12, 2014, March 16, 2015, May 5, 2015, February 17, 2016, April 18, 2016, July 13, 2016, March 13, 2017, and April 14, 2017.

The licensee shall implement the items listed in Enclosure 1, Implementation items of SNC letter NL-15-0381 dated March 16, 2015 prior to the implementation of the Risk Informed Completion Time Program.

The risk assessment approach and methods, shall be acceptable to the NRC, be based on the as-built, as-operated, and maintained plant, and reflect the operating experience of the plant as specified in RG 1.200. Methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods approved by the NRG for generic use.

If the licensee wishes to change its methods, and the change is outside the bounds of this license condition, the licensee will seek prior NRC approval, via a license amendment.

Vogtle Unit 2 D-2 Amendment No.

Vogtle Electric Generating Plant Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times Marked-Up Enclosure 1, Table 1 from September 13, 2012 Submittal to NL-12-1344 List of Revised Required Actions to Corresponding PRA Functions Table E1.1 Revised TS LCO Conditions to Corresponding PAA Functions SS Cs SS Cs TS LCO Condition Covered by Modeled Function Covered by TS LCO Design Success Criteria PAA Success Criteria Disposition TSLCO Condition Condition in PAA 3.8.1 AC Sources - Operating:

See LCO Condition 3.8.1.A and 3.8.1.B H. Three or more required AC sources inoperable 3.8.3 Diesel Fuel Oil, Lube Oil, 1 fuel oil Yes

1)

Provide sufficient fuel to

1) 1 of 1 fuel oil tank per

1) 1 of 1 fuel oil tank per each The impact of low fuel level is not explicitly modeled in the PAA, but can be Starting Air, and Ventilation:

storage tank operate DG for at least 7 days each of 2 DGs for 5.2 of 2 DGs with a mission addressed for the RICT Program by assuming the affected storage tank is per each of 2 while supplying maximum post-days of operation and the time of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months unavailable. Therefore, this LCO condition can be evaluated using the A. One or more DGs with fuel level <

DGs LOCA load ability to transfer fuel oil CAMP tool and EOOS model.

68,000 gal and > 52,000 gal in from other DG's fuel oil storage tank tank for the remaining 1.8 The PAA success criteria differ from the design basis because the mission days of operation time for DG operation in the PAA is 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . Success criteria in PAA are based on plant-specific realistic analyses consistent with the PAA standards for CC 11.

3.8.3 Diesel Fuel Oil, Lube Oil, 2 supply fans Yes

1)

Limit DG building air

1)

(a) 1 of 2 fans per

1) 1 of 2 fans per each of 2 SSCs are modeled consistent with the TS scope and so can be directly Starting Air, and Ventilation:

and temperature to maximum of each of 2 DGs DGs evaluated using the CAMP tool and EOOS model.

associated 120°F to support DG operation F. One or more DGs with one dampers per (b) 2 of 2 fans per The PAA success criteria are based on a realistic room heat-up analysis ventilation supply fan inoperable per each of 2 DG each of 2 DGs performed which show only one fan is required.

DG buildings when ambient temperatures exceed 93'F 3.8.4 DC Sources - Operating:

1 source Yes

1)

Ensure availability of required

1) 1 battery in each train

1)

SAME SSCs are modeled consistent with the TS scope and so can be directly (battery A or EOG starting power to evaluated using the CAMP tool and EOOS model.

A. One DC electrical power source B) per each shutdown the reactor and inoperable due to inoperable battery of 2 trains maintain in a safe condition The success criteria in the PAA are consistent with the design basis criteria.

Aor B after an operational occurrence or OBA 3.8.4 DC Sources - Operating:

1 source Yes

1)

Ensure availability of required

1) 1 battery in each train

1)

SAME SSCs are modeled consistent with the TS scope and so can be directly (battery C or breaker control power and evaluated using the CAMP tool and EOOS model.

B. One DC electrical power source D) per each instrumentation to shutdown inoperable due to inoperable battery of 2 trains the reactor and maintain in a The success criteria in the PAA are consistent with the design basis criteria.

Coro safe condition after an ooerational occurrence or OBA 3.8.4 DC Sources - Operating:

2 sources Yes

1)

Ensure availability of required

1) 1 of 2 DC SOOfOOSil9'

1)

SAME SSCs are modeled consistent with the TS scope and so can be directly (each power to shutdown the reactor eaGR-i>f~rainstrains evaluated using the CAMP tool and EOOS model.

C. One DC electrical power source consisting of and maintain in a safe condition inoperable for reasons other than 1battery,1 after an operational occurrence The success criteria in the PAA are consistent with the design basis criteria.

Condition A or B switchgear. 2 orDBA

chargers, control equipment, cabling and distribution panels) per each of 2 trains 3.8.4 DC Sources - Operating:

See LCO Condition 3.8.4.A through 3.8.4.C D. Two DC electrical power subsvstems inooerable 3.8.7 Inverters - Operating:

2 channels Yes

1)

Provide necessary power to

1) 1 of 2 inverter Ghannels-iA

1)

SAME SSCs are modeled consistent with the TS scope and so can be directly (with 1 or2 RPS and ESFAS

+-Of-2-trainstrains evaluated using the CAMP tool and EOOS model.

A. One required inverter inoperable inverters each) per The success criteria in the PAA are consistent with the design basis criteria.

each of 2 trains E1-12 to NL-12-1344 List of Revised Required Actions to Corresponding PRA Functions Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SS Cs SS Cs TS LCO Condition Covered by Modeled Function Covered by TS LCO Design Success Criteria PRA Success Criteria Disposition TSLCO Condition Condition in PRA 3.8. 7 Inverters - Operating:

See LCO Condition 3.8.7.A B. Two or more required inverters inoperable 3.8.9 Distribution Systems -

2+sub-Yes

1)

Provide necessary power to

1) 1 of 2 AC subsystems

1)

SAME SSCs are modeled consistent with the TS scope and so can be directly Operating:

system§ (4kV ESF systems evaluated using the CRMP tool and EOOS model.

ESF switch-A. One or more AC electrical power

gear, The success criteria in the PRA are consistent with the design basis criteria.

distribution subsystems inoperable secondary 480V switchgear, distribution panels, load centers and MCCs) f'8' easR-oJ..a traiAs 3.8.9 Distribution Systems -

2 sub-Yes

1)

Provide necessary power to

1) 1 of 2 vital AC sub-

1)

SAME SSCs are modeled consistent with the TS scope and so can be directly Operating:

systems pt>f ESF systems systems iA-+-ef-g..lfains evaluated using the CRMP tool and EOOS model.

easR-oJ..a B. One or more AC vital bus traffis The success criteria in the PRA are consistent with the design basis criteria.

electrical power distribution subsvstems inooerable 3.8.9 Distribution Systems -

2 sub-

Yes,

1)

Provide necessary power to

1) 1 of 2 DC sub-systems ifl

1)

SAME SSCs are modeled consistent with the TS scope and so can be directly Operating:

systems fl'*

except ESF systems -0!..a-traifls evaluated using the CRMP tool and EOOS model.

eaGR-el..a distributio C. One or more DC electrical power trains n panel The success criteria in the PRA are consistent with the design basis criteria.

distribution subsystems inoperable DD11 3.8.9 Distribution Systems -

See LCO Condition 3.8.9.A through 3.8.9.C Operating:

D. Two or more electrical power distribution subsystems inoperable that result in a loss of safety function E1-13

__ J

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CAC:ME9555, Revise or Add Actions to Preclude Entry Into LCO 3.0.3 - RITSTF Initiatives 6B and 6C, Provide RISK-INFORMED Extended Completion Times - RITSTF Initiative 4B (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request Acceptance... Supplement Administration Meeting, Meeting, Meeting, Meeting, Meeting Questions 17 December 2015 15 June 2016 7 March 2017 3 February 2017 24 February 2017 Answers 17 February 2016 17 February 2016 18 April 2016 13 July 2016 13 March 2017 14 April 2017 Results Approval Other: ML16172A095, ML16300A245
MONTHYEAR2017-02-03 [Table View]

NL-17-0447, Response to Request for Additional Information on Technical Specifications Change to Adopt Risk Informed Completion Times

Text

Enclosures:

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