NL-17-1026, Revision to Technical Specifications Pages for Limiting Condition for Operation 3.7.14

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Revision to Technical Specifications Pages for Limiting Condition for Operation 3.7.14
ML17153A354
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 06/02/2017
From: Wheat J
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-17-1026
Download: ML17153A354 (19)


Text

~ Southern Nuclear Justin T. Wheat Nuclear Licensing Manager JUN 0 2 2011 40 Inverness Center PJri..wJy Post Oflicc Hox 1295 Birmingham. AI. 35242 205 992 5998 tel 205 992 760 I fax jtwhcat@~outhernco.com Docket Nos.: 50-424 50-425 NL-17-1026 U.S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 and 2 Revision to Technical Specificati 1

ons Pages for Limiting Condition for Operation 3. 7.14 Ladies and Gentlemen:

By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license request to modify the Vogtle Electric Generating Plant (VEGP) Units 1 and 2 Technical Specifications (TS) to implement risk informed completion times, per the guidelines of Nuclear Energy Institute (NEI) Report 06-09, Revision 0-A, "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 April14, 2017, SNC submitted marked-up and clean TS pages to the NRC. The submittal included all the affected TS pages for the VEGP risk informed TS, as well as changes to the VEGP Operating License to support the conversion to the risk informed TS.

On May 4, 2017, a separate correspondence was provided to NRC which modified proposed Section 5.5.22, intended for inclusion in the administrative control section of the TS. Since then, NRC has requested further clarification on a proposed revision to Limiting Condition for Operation (LCO) 3.7.14, "Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System". NRC also requested a slight modification to the VEGP Unit 1 and 2 Operating License pages.

Accordingly, Enclosures 1 and 2 to this letter provide marked-up and clean pages for the proposed revisions to LCO 3.7.14 and the Operating License, respectively.

The TS pages for LCO 3. 7.14 and the Operating License pages provided in this letter completely supersede the pages previously provided in the April 14 correspondence for those sections. All other pages provided in the April 14 and May 4 letters remain valid.

This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at 205.992.7369.

U. S. Nuclear Regulatory Commission NL-17-1026 Page 2 Mr. Justin T. Wheat states he is Regulatory Affairs 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,

~

Justin T. Wheat Regulatory Affairs Manager JTW/OCV I

,~J

~

~

Sworn to and subscribed before me this <?" -" day of __._,~f-F-.::::_:_

____, 2017.

~f.~~

Notary Public My commission expires: I 0 l ~ d-D f 1

Enclosures:

1. Marked-Up and Clean TS Pages
2. Marked-Up and Clean Operating License Pages cc:

Regional Administrator, Region II NRR Project Manager-Vogtle 1 & 2 Senior Resident Inspector-Vogtle 1 & 2 State of Georgia Environmental Protection Division RType: CVC7000

Vogtle Electric Generating Plant, Units 1 and 2 Revision to Technical Specifications Pages for LCO 3.7.14 Marked-Up and Clean TS Pages

ESF Room Cooler and Safety-Related Chiller System 3.7.14

3. 7 PLANT SYSTEMS
3. 7.14 Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System LCO 3.7.14 Two ESF Room Cooler and Safety-Related Chiller trains shall be OPERABLE.

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

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

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

APPLICABILITY:

MODES 1, 2, 3, and 4. I 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />s~

cooler and safety-related chiller train to OPERABLE status.

Be in MODE 5.

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

Insert 2 Vogtle Units 1 and 2 3.7.14-1 Amendment No. Q9 (Unit 1)

Amendment No. 4-aQ (Unit 2)

INSERT 13 E3. -------------~C>lrE:~-------------

E3.1 Restore ~~CW trains to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1. ~ot applicable when OPE:RAE3LE: status.

second ~~CW train C>R intentionally made inoperable.

2. lrhe following ~ection In accordance with the Risk 5.5.22 constraints are Informed Completion lrime applicable: parts b, c.2, c.3, d, Program e, f, g, and h.

lrwo ~~CW trains inoperable.

INSERT 14 E3. ---------~C>lrE:~--------------

E3.1 Restore one E:~F room 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1. ~ot applicable when two cooler and safety-related E:~F room cooler and safety chiller train to C>PE:RAE3LE:

C>R related chiller trains status.

intentionally made inoperable.

In accordance with the Risk

2. lrhe following ~ection Informed Completion lrime 5.5.22 constraints are Program applicable: parts b, c.2, c.3, d, e, f, g, and h. However, for the purposes of compliance with part f, the E:~F room doors may be opened to maintain acceptable temperatures within the room.

lrwo E:~F room cooler and safety related chiller trains inoperable.

INSERT 15


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

1.

~ot applicable when second DG intentionally made inoperable.

2. lrhe following ~ection 5.5.22 constraints are applicable: parts b, c.2, c.3, d, e, f, g, and h.

INSERT 16 G. ---------------~C>lrE:~-----------

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

1. ~ot applicable when three inoperable AC sources to or more required AC sources C>PE:RAE3LE: status.

C>R intentionally made inoperable.

2. lrhe following ~ection In accordance with the Risk 5.5.22 constraints are Informed Completion lrime applicable: parts b, c.2, c.3, d.

Program e, f, g, and h.

lrhree or more required AC sources inoperable.

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 T E -----------------------------------------------

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

~ 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 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 <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> 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)

ACTIONS (continued)

CONDITION B.


NOTES----------

1. Not applicable when two ESF room cooler and safety-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. However, for the purposes of compliance with part f, the ESF room doors may be opened to maintain acceptable temperatures within the room.

Two ESF room cooler and safety-related chiller trains inoperable.

c.

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

Vogtle Units 1 and 2 B.1 C. 1 AND C.2 ESF Room Cooler and Safety-Related Chiller System 3.7.14 REQUIRED ACTION COMPLETION TIME Restore one ESF room 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> cooler and safety-related chiller train to OPERABLE OR status.

Be in MODE 3.

Be in MODE 5.

3.7.14-2 In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ESF Room Cooler and Safety-Related Chiller System 3.7.14 SURVEILLANCE REQUIREMENTS SR 3.7.14.1 SR 3.7.14.2 SR 3.7.14.3 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.

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.

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 3.7.14-3 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

Vogtle Electric Generating Plant, Units 1 and 2 Revision to Technical Specifications Pages for LCO 3.7.14 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 10 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 stolage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of 'i'ppendix 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 1 0 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, as supplemented by a change approved by License Amendment No. 175.

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 descnbed in the licensee's letters dated reracking September4, 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 mel 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

~ost 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. 4-73

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, April14, 2017, May 4, 2017, and June 2, 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 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 NRC 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.

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 strategjes 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 10 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 III.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 Number 155 Additional Condition Southern Nuclear Operating Company (SNC) is approved to implement 10 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 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.)

I I

Insert OL 2 here I

Implementation Date As stated in the Additional Condition Vogtle Unit 2 D-2 Amendment No. -m

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, April18, 2016, July 13, 2016, March 13, 2017, April14, 2017, May 4, 2017, and June 2, 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 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 NRC 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.

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 10 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 III.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, as supplemented by a change approved by License Amendment No. 175.

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, April18, 2016, July 13, 2016, March 13, 2017, April14, 2017, May 4, 2017, and June 2, 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-oper~ted, 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 NRC 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 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 10 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 III.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 10 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 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 pr9babilistic risk assessment approach.)

I 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, April18, 2016, July 13, 2016, March 13, 2017, April14, 2017, May 4, 2017, and June 2, 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 NRC 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.