Text

March 12, 2018, Public Meeting - Draft 4b Application
	ML18065A022
Person / Time
Site:	Farley
Issue date:	03/06/2018
From:	Shawn Williams; Plant Licensing Branch II
To:	;
	Williams S, NRR/DORL/LPLII-1
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ML18065A015	List: ML18065A020; ML18065A022; ML18065A025;
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	Download: ML18065A022 (207)
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DRAFT Documents Farley 4b

Attachment 1 provides a description and assessment of the proposed changes, the requested confirmation of applicability, and plant-specific verifications.

Attachment 2 provides the existing TS pages marked up to show the proposed changes.

Attachment 3 provides revised, clean TS pages.

Attachment 4 provides existing TS Bases pages marked up to show the proposed changes.

Enclosure:

1. List of Revised Required Actions to Corresponding PRA Functions.

2. Information Supporting Consistency with Regulatory Guide 1.200, Revision 2.

3. Information Supporting Justification of Bounding Analysis or Excluding Sources of Risk Not Addressed by the PRA Models

4. Baseline CDF and LERF D

5. PRA Model Update Process

6. Attributes of the CRMP Model

7. Key Assumptions and Sources of Uncertainty RA

8. Program Implementation

9. Cumulative Risk and Performance Monitoring Program

10. Risk Management Action Example FT to NL-18-0039 Basis for Proposed Change

1. Summary Description The proposed amendment would modify the Farley Nuclear Plant (FNP) Technical Specification (TS) requirements related to completion times (CTs) for required actions (RAs) to provide the option to calculate a longer, risk-informed completion time (RICT).

The allowance is described in a new program in Chapter 5, "Administrative Controls,"

entitled the "Risk Informed Completion Time Program."

The methodology for using the RICT Program is described in NEI 06-09, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)

Guidelines," which was approved by the Nuclear Regulatory Commission (NRC) on May 17, 2007. Adherence to NEI 06-09 is required by the RICT Program.

The proposed amendment is consistent with the methodologies presented in TSTF-505, Revision 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b.

Although the proposed amendment is consistent with TSTF-505, SNC is not proposing adoption of TSTF-505 with this License Amendment Request (LAR). This LAR is a site-specific application. Only those required actions described in this attachment and Enclosure 1 are proposed to be changed. This is consistent with the methodology 2.

D described in NEI 06-09.

Detailed Description RA The proposed amendment would modify the Farley Nuclear Plant (FNP) TSs in the following manner to incorporate the RICT Program.

Use and Application Example 1.3-8, which demonstrates the format and use of the RICT Program within an LCO, is added to the TS and reads as follows:

ACTIONS A. One FT CONDITION REQUIRED ACTION A.1 Restore COMPLETION TIME 7 days subsystem subsystem to inoperable. OPERABLE OR status.

In accordance with the Risk Informed Completion Time Program A1-1 to NL-18-0039 Basis for Proposed Change B. ---- NOTES ---- B.1 Restore 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

1. Not applicable subsystems to when second OPERABLE OR subsystem status.

intentionally In made accordance inoperable. with the Risk

2. The following Informed Section 5.5.20 Completion constraints are Time applicable: Program parts b, c.2, c.3, d, e, f, g, D and h.

Two subsystems RA inoperable.

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

C.2 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, one stating it is not applicable if the second subsystem is intentionally made inoperable. The second Note indicates those parts of Section 5.5.20 that are 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 A1-2 to NL-18-0039 Basis for Proposed Change 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 to extend the Completion Time beyond 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 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. For these loss of function conditions, the RICT may not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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 D

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 RA 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.

FT Administrative Controls Section 5.5.20, which describes the RICT Program, is added to TSs and reads as follows (this is consistent with TSTF-505 and NEI 06-09 as amended for the adjustments made to the Vogtle Electric Generating Plant (VEGP) Risk Informed TS Program during its NRC review):

Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09, Revision 0, 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 used in MODE 1 and 2.

A1-3 to NL-18-0039 Basis for Proposed Change

c. When a RICT is being used, any plant configuration 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 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 D a specified safety function or inoperability of all required trains of a system required to be OPERABLE if one or more of the trains are considered PRA Functional as defined in Section 2.3.1 of NEI 06-09. However, the following RA additional constraints shall be applied to the criteria for PRA Functional:

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

f.

FT 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 (LOF) condition where a RICT is applied.

Use of a RICT for LOF conditions may not exceed 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

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 A1-4 to NL-18-0039 Basis for Proposed Change

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.

g. 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.

Individual LCO Required Actions (RA) modified by the proposed amendment to be included in the RICT program are identified below. (Mentions of TSTF-505 refer to TSTF-505-A, Rev. 1).

DRA 3.4.10 Pressurizer Safety Valves Required Action A.1 - Restore valve to OPERABLE status (Condition A: One pressurizer safety valve inoperable).

(This deviates from the TSTF-505 LCO Condition in that a loss of function Condition is assigned to Condition A of the FNP LCO.

This is because the FNP safety analysis assumes operation of all FT three pressurizer safety valves to limit increases in RCS pressure).

3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

Required Action B.3 - Restore PORV to OPERABLE status (Condition B: One PORV inoperable and not capable of being manually cycled)

Required Action C.2 - Restore block valve to OPERABLE status (Condition C: One block valve inoperable)

Required Action F.2 - Restore one block valve to OPERABLE status (Condition F: Two block valves inoperable; this is a Loss of Function Condition.)

A1-5 to NL-18-0039 Basis for Proposed Change (This LCO deviates from TSTF-505 in the following manner:

Condition F is a loss of function Condition in the FNP TS; it is not in the corresponding TSTF-505 Condition. Condition F in the FNP TS differs from the corresponding Condition in the NUREG in that there are two Required Actions in the FNP Condition as opposed to one in the TSTF; consequently, a RICT is assigned to Required Action F.2. This is consistent with the VEGP 4b program).

3.5.1 Accumulators Required Action C.1 - Restore one accumulator to OPERABLE status.

(Condition C: Two or more accumulators inoperable for reasons other than boron concentration not within limits. This Condition is being added to LCO 3.5.1 as a Loss of Function Condition) 3.5.2 ECCS - Operating DRA Required Action A.1 - Restore train(s) to OPERABLE status (Condition A: One or more trains inoperable AND at least 100% of the ECCS flow equivalent to a single Operable ECCS train available)

(A deviation from the TSTF is taken in that Condition B in the TSTF, Less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available is not used in FNP LCO 3.5.2.

FT 3.5.4 During the review of the VEGP RICT Program submittal, NRC indicated that design parameters must be met to be able to credit PRA Functionality in a Loss of Function Condition).

Refueling Water Storage Tank (RWST)

Required Action B.1 - Restore RWST to OPERABLE status (Condition B: RWST inoperable for reasons other than Condition A, this is a Loss of Function condition).

(FNP LCO 3.5.4 deviates from the TSTF in that Condition A is not given a RICT in the FNP Program. This is due to the NRC indicating, in their review of the VEGP RICT Program, that design A1-6 to NL-18-0039 Basis for Proposed Change parameters must be met to be able to credit PRA Functionality for Loss of Function Conditions and Condition A in the proposed FNP TS is a loss of function).

(FNP LCO 3.5.4 also deviates from the TSTF in that, Condition B is identified as a Loss of Function Condition since with the RWST inoperable, neither the ECCS nor the Containment Spray system can perform its design function. The TSTF does not identify this Condition as a Loss of Function).

3.6.2 Containment Air Locks Required Action C.3 - Restore air lock to OPERABLE status (Condition C: One or more containment air locks inoperable for reasons other than Condition A or B) 3.6.3 Containment Isolation Valves Required Action A.1 - Isolate the affected penetration flow path by DRA 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.

(Condition A: One or more penetration flow paths with one containment isolation valve inoperable except for purge valve penetration leakage not within limit. Note: Only applicable to penetration flow paths with two containment isolation valves)

Required Action B.1 - Isolate the affected penetration flow path by use of at least one closed and deactivated automatic valve, closed FT manual valve, or blind flange.

(Condition B: One or more penetration flow paths with two containment isolation valves inoperable except for purge valve penetration leakage not within limit. Note: Only applicable to penetration flow paths with two containment isolation valves. This is a Loss of Function Condition).

Required Action C.1 - Isolate the affected flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange.

(Condition C - One or more penetration flow paths with one containment isolation valve inoperable. Note: Only applicable to penetration flow paths with only one containment isolation valve and a closed system. This is a Loss of Function Condition).

A1-7 to NL-18-0039 Basis for Proposed Change 3.6.6 Containment Spray and Cooling Systems Required Action A.1 - Restore containment spray train to OPERABLE status.

(Condition A: One containment spray train inoperable)

Required Action B.1 - Restore one containment spray train to OPERABLE status.

(Condition B: Two containment spray trains inoperable. This is a TS Loss of Function Condition).

Required Action D.1 Restore containment cooling train to OPERABLE status.

(Condition D: One containment cooling train inoperable).

Required Action E.1 Restore one containment cooling train to OPERABLE status.

(Condition E: Two containment cooling trains inoperable)

Required Action G.1 - Restore one containment spray or cooling train to OPERABLE status.

DRA (Condition G: Any combination of three or more trains inoperable.

This is a Loss of Function Condition).

(FNP LCO 3.6.6 deviates in format from the TSTF-505 mark-up but the effect is the same. FNP has added Condition B, Two containment spray trains inoperable, and Condition G is Any combination of three or more trains inoperable. Both are Loss of Function Conditions. SNC FNP believes that separating the two containment spray trains inoperable Condition from the any FT combination of three or more trains inoperable Condition is clearer and more concise than the TSTF-505 Condition G where both situations are considered in one TS Condition.)

3.7.2 Main Steam Isolation Valves (MSIVs)

Required Action A.1 - Restore MSIV to OPERABLE status.

(Condition A: One or more steam lines with one MSIV inoperable in MODE 1).

A1-8 to NL-18-0039 Basis for Proposed Change Required Action B.1- Restore one MSIV to OPERABLE status in affected steam line.

(Condition B: One or more steam lines with two MSIVs inoperable in MODE 1. This is a TS Loss of Function Condition).

3.7.4 Atmospheric Relief Valves (ARVs)

Required Action A.1 - Restore required ARV line to OPERABLE status.

(Condition A: One required ARV line inoperable).

Required Action B.1 - Restore one ARV line to OPERABLE status.

(Condition B: Two required ARV lines inoperable.

Required Action C.1 - Restore one ARV line to OPERABLE status.

Condition C: Three required ARV lines inoperable. (This is a Loss of Function Condition).

DRA (Conditions B and C are deviations from the TSTF. For the purposes of the Risk Informed Completion Time Program, the Condition of Two or more required ARV lines inoperable is being split into two Conditions. Condition B will be Two required ARV lines inoperable and Condition C will be Three required ARV lines inoperable. Condition C is a Loss of Function Condition, but Condition B is not. This is why they were split. Otherwise Condition B would have been a Loss of Function, with its restrictions, with just 2 ARVs inoperable).

FT 3.7.5 Auxiliary Feedwater System (AFW)

Required Action A.1 - Restore affected equipment to OPERABLE status.

(Condition A: One steam supply to turbine driven AFW pump inoperable).

Required Action B.1 - Restore AFW train to OPERABLE status.

(Condition B: One AFW train inoperable for reasons other than Condition A).

Required Action C.1 - Restore one AFW train to OPERABLE status.

(Condition C : Two AFW trains inoperable. This is a TS Loss of Function condition)

A1-9 to NL-18-0039 Basis for Proposed Change 3.7.6 Condensate Storage Tank (CST)

Required Action A.2 - Restore CST to OPERABLE status.

(Condition A: CST inoperable. This is a Loss of Function condition).

(This is a deviation from TSTF-505 in that Condition A, CST Inoperable, is identified as a Loss of Function Condition in the FNP proposed TS. This is because the CST provides cooling water to remove decay heat and to cool down the unit following all events in the accident analysis. If this source of water is unavailable, it may not be possible to mitigate these events).

3.7.7 Component Cooling Water (CCW) System DRA Required Action A.1 - Restore CCW train to OPERABLE status (Condition A - One CCW train inoperable)

Required Action B.1 - Restore one CCW train to OPERABLE status.

(Condition B: Two CCW trains inoperable. Condition B is a new Condition, added as a Loss of Function) 3.7.8 Service Water System (SWS)

FT Required Action A.1 - Restore SWS train to OPERABLE status.

(Condition A: One SWS train inoperable)

Required Action B.1 - Restore one SWS train to OPERABLE status.

(Condition B: Two SWS trains inoperable. Condition B is a new Condition, added as a TS Loss of Function).

3.7.11 Control Room Air Conditioning System (CRACS)

Required Action E.1 - Restore one CRACS train to OPERABLE status.

(Condition E: Two CRACS trains inoperable in MODE1, 2, 3, or 4.

This is a Loss of Function Condition)

A1-10 to NL-18-0039 Basis for Proposed Change (Condition F for the FNP TS is a deviation from the TSTF in that, if the CT of the Loss of Function Condition E is not met, LCO 3.0.3 is entered. This is the current licensing basis for the FNP Loss of Function Condition and FNP chooses to retain it. There is little difference between it and the TSTF-505 Condition for not meeting the Loss of Function CT, Condition B, which requires being in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and Mode 5 in 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ).

3.7.19 Engineered Safety Feature (ESF) Room Coolers Required Action A.1: - Restore the affected ESF Room Cooler subsystem Train to OPERABLE status.

Condition A: One required ESF Room Cooler subsystem Train inoperable.

Required Action B.1: - Restore one of the same ESF Room Cooler subsystems to OPERABLE status.

Condition B: Two trains of the same ESF Room Cooler subsystem DRA 3.8.1 inoperable. (This is a new Condition, added as a loss of function).

(This LCO does not exist in NUREG-1431. Consequently, this represents a deviation from TSTF-505).

AC Sources - Operating Required Action A.3 - Restore required offsite circuit to OPERABLE status.

FT (Condition A: One required offsite circuit inoperable)

Required Action B.4 - Restore DG set to OPERABLE status.

(Condition B: One DG Set inoperable)

Required Action C.2 - Restore one required offsite circuit to OPERABLE status.

(Condition C: Two required offsite circuits inoperable)

Required Action D.1 - Restore required offsite circuit to OPERABLE status.

Required Action D.2 - Restore DG set to OPERABLE status.

(Condition D: One required offsite circuit inoperable AND One DG set inoperable).

Required Action E.1 - Restore one DG set to OPERABLE status.

(Condition E: Two DG Sets inoperable)

A1-11 to NL-18-0039 Basis for Proposed Change Required Action G.1 - Restore automatic load sequencer to OPERABLE status.

(Condition G: One automatic load sequencer inoperable)

Required Action H.1 - Restore one required AC source to OPERABLE status.

(Condition H: Three or more required AC sources inoperable).

(Condition E is a deviation from TSTF-505. This is due to the structure of the LCO Condition differing between the FNP TS and the Standard TS, marked up for TSTF-505. The FNP Condition is two DG sets inoperable. There are three Completion Times in the current FNP Required Action but only one in the TSTF. The FNP CTs are dependent on which combination of individual DGs is affected. The CT increases depending on the severity in the combinations of DGs that are inoperable. The first combination listed in the current FNP CT for Condition E is 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months for all three DGs inoperable. The next two are 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for different inoperable combinations of 2 DGs. A RICT is being DRA 3.8.4 assigned to the 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months and 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CT. The first CT is being eliminated; it will be covered in proposed Condition H).

DC Sources - Operating Required Action A.1 - Restore the Auxiliary Building DC electrical power subsystem to OPERABLE status.

(Condition A: One auxiliary building DC electrical power subsystem inoperable).

FT Required B.1 - Restore the battery connection resistance to within limit.

(Condition B: One auxiliary building DC electrical power subsystem with battery connection resistance not within limit).

Required Action D.1- Restore the battery connection resistance to within the limit.

(Condition D: One required SWIS DC electrical power subsystem battery connection resistance not within limit).

Required Action F.1 - Restore at least one DC electrical power subsystem to Operable status.

(Condition F: Two or more DC electrical power subsystems inoperable that result in a loss of function. This is a new Condition, added as a loss of function)

A1-12

Attachment 1 to NL-18-0039 Basis for Proposed Change (This Condition deviates from TSTF-505 in that NUREG-1431, which was used as the generic mark-up for the Risk Informed Tech Specs, incorporates TSTF-500, DC Electrical Re-write.

The FNP TS was never revised for TSTF-500).

3.8.7 Inverters - Operating Required Action A.1 - Restore inverter to OPERABLE status.

(Condition A: One required inverter inoperable).

Required Action B.1 - Restore one required inverter to OPERABLE status.

(Condition B: Two or more required inverters inoperable. This is a new Condition, added as a loss of function).

3.8.9 Distribution Systems - Operating Required Action D.1 - Restore AC electrical power distribution DRA subsystem(s) to OPERABLE status.

(Condition D: One or more AC electrical power distribution subsystems inoperable).

Required Action E.1 - Restore AC Vital bus subsystem(s) to OPERABLE status.

(Condition E: One or more AC Vital buses inoperable).

Required Action F.1 - Restore auxiliary building DC electrical power distribution subsystem to OPERABLE status.

(Condition F: One auxiliary building DC electrical power FT

3. Technical Evaluation distribution subsystem inoperable).

Required Action G.1 - Restore one train to OPERABLE status.

(ConditionG: Two trains with inoperable distribution subsystems that result in a loss of safety function. This is a loss of function Condition).

The proposed modification to the Farley Nuclear Plant (FNP) Units 1 and 2 TS would add Section 5.5.20, Risk Informed Completion Time (RICT) Program to Chapter 5, Administrative Controls, add Example 1.3-8 to Chapter 1, Use of Application, and modify selected Required Action (RA) Completion Times (CT), provided risk is assessed and managed as described in NEI 06-09. In accordance with NEI 06-09-0-A, PRA methods are used to justify each extension to a RA CT based on the specific plant configuration, which exists at the time of the applicability of the RA, and are updated when plant configurations change. This application includes A1-13 to NL-18-0039 Basis for Proposed Change documentation regarding the technical adequacy of the PRA models used in the Configuration Risk Management Program (CRMP), consistent with the requirements of RG 1.200 (Enclosure 2).

Most TS LCOs identify one or more Conditions for which the LCO may not be met, to permit a licensee to perform required testing, maintenance, or repair activities. Each Condition has associated RAs for restoration of the LCO or for other actions, each with some fixed time interval, referred to as the Completion Time, which identifies the time interval permitted to complete the Required Action. Upon expiration of the CT, the licensee is required to shutdown the reactor or follow the remedial action(s) stated in the TS. The RICT program provides the necessary administrative controls to permit extension of CTs and thereby delay reactor shutdown or remedial actions, if risk is assessed and managed within specified limits and programmatic requirements. The specified safety function of performance levels of TS required structures, systems, and components (SSCs) are unchanged, and the remedial actions, including the requirement to shut down the reactor, are also unchanged; only the CTs for the RAs are extended by the RICT program.

NEI 06-09 allows the application of a RICT to emergent conditions which represent D

inoperability of all required trains or divisions of a system required to be Operable provided one or more of the trains or divisions are considered PRA functional as defined in Section 2.3.1 of NEI 06-09. In order to avoid intentional entry to these loss of function RA conditions, they are modified by a Note similar to: Not applicable when the second system

[train] [division] is intentionally made inoperable. A second Note, added to these loss of function conditions, lists the restrictions on these conditions, as given in Section 5.5.20.

Furthermore, any SSCs credited in the PRA Functional determination shall be the same SSCs relied upon to perform the specified Technical Specifications safety function and design basis parameters will be met.

FT The Bases for each specific loss of function Condition are expanded to discuss the Note, similar to:

The Condition is modified by two Notes. The first Note stating it is not applicable when the second system [train] [division] is intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from service.

The Required Action is only applicable if one system [train] [division] is inoperable for any reason and a second system [train] [division] is found to be inoperable, or if two systems

[trains] [divisions] are found to be inoperable at the same time. The second Note lists the restrictions, per TS Section 5.5.20, that are applicable to these loss of function conditions.

In Section 4, Limitations and Conditions, of the Safety Evaluation for NEI 06-09, there are thirteen aspects listed that describe required, plant-specific information to support a license amendment request to adopt NEI 06-09. They are as follows:

A1-14 to NL-18-0039 Basis for Proposed Change (1) The LAR will include proposed changes to the administrative controls of TS to add a Configuration Risk Management Program (CRMP) in accordance with NEI 06-09-A, Revision 0.

This information can be found in Attachment 1.

(2) The LAR will provide identification of the TS LCOs and Action requirements to which the Risk Managed Technical Specifications (RMTS) will apply, with a comparison of the TS functions to the PRA modeled functions of the SSCs subject to those LCO Actions. The comparison should justify that the scope of the PRA model, including applicable success criteria such as number of SSCs required, flowrate, etc., are consistent licensing basis assumptions (i.e., 50.46 ECCS flowrates) for each of the TS requirements, or an appropriate disposition or programmatic restriction will be provided.

This information can be found in Enclosure 1.

D (3) The LAR will provide a discussion of the results of peer reviews and self assessments conducted for the plant-specific PRA models which support the RMTS, including the resolution or disposition of any identified deficiencies (i.e., findings and observations RA from peer reviews). This will include a comparison of the requirements of RG 1.200 using the elements of ASME RA-Sb-2005 for capability Category II for internal events PRA models, and for other models for which RG 1.200 endorsed standards exist. If additional standards have been endorsed by revision to RG 1.200, the LAR will provide similar information for those PRA models used to support the RMTS program.

FT This information can be found in Enclosure 2.

(4) The LAR will provide a description, in terms of scope, level of detail, technical adequacy, and methods applied, for all PRA models used in calculations of risk used to support the RMTS for risk sources for which NRC endorsed standards are not available.

This item is not applicable to this license amendment request.

(5) The LAR will provide a justification for excluding any risk sources determined to be insignificant to the calculation of configuration -specific risk, and will provide a discussion of any conservative or bounding analysis to be applied to the calculation of RICTs for sources of risk not addressed by the PRA models.

This information can be found in Enclosure 3.

(6) The LAR will provide the plant-specific total CDF and total LERF to confirm that these are less than 10-4/year and 10-5/year, respectively.

A1-15 to NL-18-0039 Basis for Proposed Change (7) This assures that the potential risk increases allowed under the RMTS program are consistent with RG 1.174, Revision 1.

The information can be found in Enclosure 4.

(8) The LAR will provide appropriate plant-specific justification for using at-power PRA models in shutdown modes to which the RMTS applies.

This item is not applicable to this license amendment request.

(9) The LAR will provide a discussion of the licensees programs and procedures which assure the PRA models which support the RMTS are maintained consistent with the as-built, as-operated plant.

This information can be found in Enclosure 5.

(10) The LAR will provide a description of the PRA models and tools used to support the RMTS, including identification of how the baseline PRA model is modified for use in the CRMP tools, quality requirements applied to the PRA models and CRMP tools, D

consistency of calculated results from the PRA model and the CRMP tools, and training and qualification programs applicable to personnel responsible for development and use of the CRMP tools. The scope of SSCs within the CRMP will be RA provided. This item should also confirm that the CRMP tools can be readily applied for each TS LCO within the scope of the plant-specific RMTS submittal This information can be found in Enclosure 6.

10) The LAR will provide a discussion of how the key assumptions and sources of 11)

FT uncertainty were identified, and how their impact on the RMTS was assessed and dispositioned.

This information can be found in Enclosure 7 The LAR will provide a description of the implementing programs and procedures regarding the plant staff responsibilities for the RMTS implementation, and specifically discuss the decision process for RMA implementation during a RICT.

This information can be found in Enclosure 8 (12) The LAR will include a description of the implementation and monitoring program as described in RG 1.174, Revision 1, Section 2.3, Element 3, and TR NEI 06-09, Revision 0, Section 2.3.2, Step 7.

This information can be found in Enclosure 9.

13) The LAR will describe the process to identify and provide compensatory measures and RMAs during expected CTs. Provide examples of compensatory measures/RMAs for planned activities which exceed risk A1-16

Attachment 1 to NL-18-0039 Basis for Proposed Change levels identified in NUMARC 93-01 (RMA threshold) that involve an extended CT.

This information can be found in Enclosure 10.

4. Summary of Vogtle Electric Generating Plant (VEGP) Responses to Requests for Additional Information This section provides a summary of selected responses to NRC requests for additional information received by SNC during the VEGP Risk Informed Completion Time (RICT) program review process. These summaries are with respect to how they pertain to the FNP RICT Program. Those responses in which commitments were made by SNC are included in this section. Reviews and confirmations which were made, for FNP, as a result of the VEGP RAI responses are also included. Those VEGP responses which were only applicable to VEGP are not included. Also not included are those responses which only provided clarification on existing SNC practices, procedures, and processes.

In each case, only the relevant portions of the NRC question are provided. However, the SNC RAI response letter number and the date of the letter are included in each case should reviewers want to see the entire VEGP RAI response for the particular question.

D In general, any response to a VEGP RAI which discusses SNC fleet procedures, processes, and guidelines pertaining to the Risk Informed Completion Time Program and RA makes clarifications regarding those processes were not included in this section. It is understood that the clarifications made in the VEGP submittal regarding these general items will apply to the FNP Risk Informed Completion Time Program as well.

The following SNC responses are provided as they pertain to FNP.

FT The SNC letter number and date of issuance is also provided.

1) NRC Question #4, from SNC letter NL-13-1540, August 2, 2013 Please address how the VEGP updated final safety analysis report will be revised to reflect the new conditions and required actions.

SNC Response for FNP:

SNC will include a summary of the Risk Informed Completion Time Program in the FNP FSAR. This will include a section on PRA Functionality which will list those conditions which must be satisfied before declaring a component as PRA Functional per the NEI 06-09 guidelines. The section will explicitly state that for a TS component to be considered PRA Functional, its PRA success criteria, among other things, must be satisfied. Additionally, for loss of function, the SSCs design basis criteria for parameters must also be satisfied.

A1-17 to NL-18-0039 Basis for Proposed Change The FNP FSAR discussion will also include a section on PRA adequacy. It will state that the on-record PRA model that forms the basis for the VEGP Configuration Risk Management (CRM) tool has been developed to the requirements of Reg Guide 1.200, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, and is subjected to Peer Reviews per the requirements of NRC endorsed PRA standards and SNC procedures. Those Peer reviews are formally documented along with the findings and observations of the review, and their corresponding resolutions.

2) NRC Question #5, from SNC letter NL-14-1016, dated July 17, 2014 An oversight occurred during the NRC review of TSTF-505, Revision 1, and a specific scenario was not satisfactorily addressed. SNC is requested to address the following scenario.

For this scenario, the TS system is comprised of train A and train B and performs two associated Probabilistic Risk Assessment (PRA) success criteria, called PRA function 1 and PRA function 2.

D In an emergent condition, with both TS system train A and train B TS inoperable and the associated PRA success criteria considered PRA functional with train A able to perform RA PRA function 1 and train B being able to perform function 2 (i.e., neither train by itself can perform PRA functions 1 and 2 but both trains together maintain PRA functionality). The NEI 06-09 guidelines will allow a risk informed completion time to be entered in this scenario, however, there is no way to repair either train A or train B without losing PRA functionality.

scenario.

FT Please provide changes to the proposed Risk Informed Completion Time Program, in VEGP TS 5.5.22, which prevents entry into a risk informed completion time for this specific SNC Response for FNP:

The following statement will be placed in new Section 5.5.20 of the FNP TS:

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.

3) NRC Question #13, from SNC letter NL-14-1016, dated July 17, 2014.

In a number of instances, the disposition in Table E1.1 justifies such differences as PRA success criteria representing more realistic success criteria. Since the PRA success criteria differ in some instances from design basis criteria, please confirm that the PRA success criteria is up-to-A1-18 to NL-18-0039 Basis for Proposed Change date, clearly and fully documented for the 4b application to the level of detail necessary for the RICT program, and appropriate review processes are being implemented for the supporting calculations.

SNC Response for FNP:

Success criteria are documented as part of the PRA documentation and included in the scope of the Peer Review. PRA success criteria for each system included in the scope of the RICT program are further documented in the CRM System Guidelines: including flow rates, where applicable, for ease of use during PRA Functionality evaluations when a RICT is entered.

The PRA success criteria are documented in a SNC calculation, which is governed by SNC procedures. The success criteria calculations are living documents and are maintained to reflect the as-built, as-operated plant conditions. SNC calculations are performed by qualified individuals and include a preparer, a reviewer, and an approver.

Table E1.1 of this letter documents the TS LCO Conditions included in the scope of the FNP RICT Program for a comparison between the design basis and PRA success criteria.

D It also documents, in the Disposition Column of Table E1.1, a satisfactory disposition where a difference was identified. Since all differences, as documented in Table E1.1 were satisfactorily resolved, no programmatic restrictions were necessary.

RA

4) NRC RAI #1 (Alternative SSCs), from SNC letter NL-16-0067, dated February 17, 2016 If a PRA Functional determination for a loss of specified safety function or inoperability of all required trains or divisions of a system credits SSCs other than the SSCs covered by FT TSs (e.g., crediting the Fire Protection system as an alternative water source), please summarize each such TS and justify how appropriate redundancy and diversity is maintained if alternative SSCs are credited.

SNC Response for FNP:

SSCs credited in the PRA Functionality determination are the same SSCs relied on to perform the specified safety function when a RICT for a Technical Specification (TS) total loss of function (LOF Condition) is calculated.

If SNC desires to credit specific alternative SSCs in the future, i.e., SSCs other than those covered by the TS, a separate license amendment request will be required.

5) NRC RAI #1 (Human Actions) from SNC letter NL-16-0067, dated February 16, 2016.

Please confirm that all human action required to achieve PRA functional upon loss of specified safety function are modeled in the PRA (i.e., are A1-19 to NL-18-0039 Basis for Proposed Change proceduralized and trained on or are simple enough so as to be skill of the craft). If any action were evaluated not modeled, please summarize the actions and the evaluation.

SNC Response for FNP:

Human actions required to achieve PRA Functionality during a TS LOF Condition are modeled in the PRA and are proceduralized and trained on unless they are simple enough to be skill of the craft.

6) NRC RAI #1 (Intent of Design Basis) from SNC letter NL-16-0067, dated February 16, 2016 Please confirm that PRA Functionality does not include any scenarios that allow any design basis accident to proceed directly to core damage or containment failure.

SNC Response for FNP:

When in a TS LOF RICT, PRA Functionality determination will include a review of dominant internal events CDF and LERF cutsets to provide high confidence that none of D

the design basis accidents, as modeled in the internal events PRA, proceed directly to core damage or containment failure.

RA

7) NRC RAI #2 (SSCs not supporting CDF/LERF) from SNC letter NL-16-0067, dated February 16, 2016 Please confirm that the acceptable PRA Functional modelled in the PRA is also available and sufficient for the remaining design basis accident scenarios that are not modelled in the PRA because other design basis accident scenario does not affect CDF or LERF.

FT SNC Response for FNP:

For design basis initiators that are not modeled in the PRA because they do not affect CDF or LERF, the PRA Functionality evaluation performed following a TS LOF Condition will ensure SSCs not supporting CDF/LERF will remain available and will sufficiently perform their safety function with respect to the credited design basis scenario.

8) NRC Question #2 (Design Basis Success Criteria) from SNC letter NL-16-0067, dated February 16, 2016.

In Table E1.1 of its application dated September 13, 2012, the licensee noted differences between the design basis success criteria and the PRA success criteria for certain specified safety functions.

please elaborate on how adequate safety margins are maintained and provide some clarifying examples of adequate safety margins for where the A1-20 to NL-18-0039 Basis for Proposed Change PRA success criteria (e.g., flow rates, temperature limits) differ from the design criteria.

SNC Response for FNP:

For design basis initiators modelled in the internal events PRA, PRA Functionality determination performed subsequent to a TS LOF Condition entry will ensure design basis success criteria for parameters (e.g., flow rates, temperature limits) are met.

9) NRC Question (VEGP LCO 3.8.1, AC Sources - Operating) from SNC letter NL 0307, dated April 18, 2016.

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

verifying availability of SAT and functionality of a DG.

SNC Response for FNP:

RA The VEGP TS, prior to the approval and implementation of the Risk Informed Completion Time Program into the current TS, contained a risk-informed LCO 3.8.1 which allowed a 14-day Completion Time (CT) for one inoperable diesel generator provided the availability of Start-Up Transformer (SUT) and a Combustion Turbine Generator (CTG) could be confirmed. Ultimately, the LCO 3.8.1 section of the VEGP TS for the Risk Informed FT Completion Time program was revised to reflect LCO 3.8.1 of the NUREG-1431 standard and TSTF-505. Accordingly, the front stop CT for the DG was changed from 14 days to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , per the standard.

FNP LCO 3.8.1 currently has a 10 day CT. This is not a risk-informed completion time, in other words, the original justification for the 10 day CT was not risk-informed. Therefore, SNC proposes that the front stop remain at 10 days, with the option of calculating a RICT.

10) NRC Question PRA RAI S-1 (A) from SNC letter NL-16-1008, dated July 13, 2016.

The NRC staff requests SNC to discuss the completion times backstop associated with TS-LOF and its basis. In particular the NRC requests SNC to clarify whether it intends to adopt a 24-hour backstop (and if so, how it intends to do so, in addition to providing marked up TS pages). And whether SNC intends to revise TS 5.5.22 to incorporate the following A1-21 to NL-18-0039 Basis for Proposed Change constraints delineated SNCs previous response (And if so, how it intends to do so, in addition to providing marked-up TS pages):

i) Alternative SSCs cannot replace the SSCs covered by the TSs as described in the response to RAI 1.a.

ii) Design basis success criteria parameters shall be met for design basis accident scenarios that are not modeled in the internal events PRA as described in the response to 2.a.

iii) Design basis success criteria parameters shall be met for design basis accident scenarios modelled in the internal events PRA as described in the response to 2.c.

SNC Response for FNP:

SNC intends to adopt a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months backstop for loss of function conditions in the FNP Risk Informed Completion Time Program.

The three additional constraints listed above will also be adopted by FNP and placed in FNPs proposed corresponding description of the Risk Informed Completion Time Program, Section 5.5.20.

D

11) NRC Question PRA RAI S-2 from SNC letter NL-16-1008, dated July 13, 2016.

RA C. The NRC staff requests SNC to identify any proposed changes to the TSs that conflict with the constraints or controls identified in PRA RAI S-1 and to provide a disposition of any conflict.

SNC Response for FNP:

FT The FNP LAR and the FNP proposed TS changes were prepared with the constraints and controls of PRA RAI S-1 in mind. The FNP LCO Conditions which are proposed to include a risk informed completion time do not conflict with the restrictions of question PRA-RAI S-1 from the NRC review of the VEGP risk informed TS.

12) NRC Question DORL-RAI-1 from SNC letter NL-16-1008, dated July 13, 2016.

NEI 06-09, Revision 0-A incorporates changes based on the NRC staffs safety evaluation dated May 7, 2007, of NEI 06-09, Revision 0-A in the TS, and if so, to submit marked-up TS pages that reference Revision 0-A of NEI 06-09.

SNC Response for FNP:

Although the FNP submittal is a site specific TS change request, SNC will nonetheless use NEI 06 0-A as the implementation guideline and reference it in proposed Section 5.5.20, Risk Informed Completion Time Program.

A1-22 to NL-18-0039 Basis for Proposed Change

13) NRC Question #2 from SNC letter NL-17-0232, dated March 13, 2017.

SNC provided a list of systems with descriptions of the TS LOF Conditions. The proposed TS 5.5.22 in the same RAI response contains several constraints (e.g., 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months backstop and remaining mitigating capabilities) on developing a RICT that can be used for these conditions. However, the proposed TS changes do not identify the Conditions to which these constraints apply. Please propose a modification to the affected TS that stipulates that Conditions will be subject to the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months backstop and associated mitigating capabilities.

SNC Response for FNP:

Section 5.5.20, Risk Informed Completion Time Program will contain general rules for the program. Including those that apply specifically to loss of function conditions. Additionally, each individual loss of function (LOF) Condition will make reference, in a Note, to those specific parts of 5.5.20 applicable to LOF Conditions.

D

14) NRC Question #3 from SNC letter NL-17-0232, dated March 13, 2017.

The staff reviewed the proposed TS 5.5.22, Risk Informed Completion Time Program, as RA provided in Enclosure 3 in the letter dated July 13, 2016, and identified the need for some additional clarification.

(1) Enclosure 3, part c, currently states:

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

The proposed wording appears to be circular. The parallel limitation from the NRC SE on NEI 06-09 is:

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

Please clarify the logic of the proposed limitation or revise TS 5.5.22 accordingly.

(2) Enclosure 3, part e.2 and 3.3 currently state:

e.2 For design basis accident scenarios that are not modelled in the PRA because they do not affect the CDF or LERF, the PRA Functionality evaluation performed following a TS LOF Condition entry will ensure SSCs not supporting CDF/LERF will remain available and sufficient.

A1-23 to NL-18-0039 Basis for Proposed Change e.3 For design basis initiators modeled in the internal events PRA, the PRA Functionality determination performed subsequent to a TS LOF Condition entry will ensure design basis success criteria for parameters (e.g., flow rate, temperature limits) are met.

(NRC further indicated in this question that SNCs proposed words, as presented above, did not match NRCs suggested wording, and that it (SNCs words) substantively changed the scope of the response. NRC went on to suggest additional alternate wording).

SNC Response to part (1) for FNP:

The applicable portion of FNP Section 5.5.20 will use the same words and phrasing as that from the NRC SE on NEI 06-09 transcribed above.

SNC Response to part (2) for FNP:

D SNC will use the same wording for FNP as for VEGP:

Design basis success criteria parameters shall be met for all design basis RA accident scenarios for establishing PRA Functionality where a RICT is applied.

15) NRC Question #7 from SNC letter NL-17-0232, dated March 13, 2017.

LCO 3.5.1.A, One accumulator inoperable due to boron concentration not within limits, is proposed in the scope of the RICT program. In response to RAI #12 provided in letter FT dated July 17, 2014, the licensee stated that this condition will be modeled in the PRA by assuming loss of accumulator as a surrogate. The RAI response further states that loss of accumulator is the worst case surrogate for this degraded condition.

a) explain how modeling the accumulator as unavailable (i.e., no injection) in the PRA represents the worst case impact of the accumulator boron concentration not being within limits or remove Condition 3.5.1.A from the RICT program.

b)

SNC Response for FNP As was done for the VEGP Program, this LCO Condition will not be included in the FNP Risk Informed Completion Time Program.

A1-24 to NL-18-0039 Basis for Proposed Change NRC Question #11 from SNC letter NL-17-0232, dated March 13, 2017.

Please provided a license condition limiting the scope of the PRA and non-PRA methods to what is approved by the NRC staff for use in the plant specific RMTS program. An example is provided below:

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 at the plant. Acceptable methods to assess the risk from extending the completion times must be PRA methods accepted as part of this license amendment, or other methods currently approved by the NRC for generic use. If a licensee wishes to change its method and the change is outside the bounds of this license condition, the licensee will need prior NRC approval, via license amendment.

SNC Response for FNP FNP will adopt a similar license condition. Enclosure xx contains the marked-up and clean D

pages for the operating license with this particular condition included.

16) NRC Question 10.3 from SNC letter NL-17-0447, dated April 14, 2017 RA 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 FT 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 condition, the RICT is limited to maximum of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months and constraints on PRA 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.

A1-25 to NL-18-0039 Basis for Proposed Change SNC Response for FNP Similar to the VEGP response, this will be made a loss of function condition in the FNP RICT Program.

17) NRC Question #10.4 from SNC letter NL-17-0447, dated April 14, 2017 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 residual heat removal pump, one residual heat D

removal (RHR) heat exchanger, together with their associated valves and piping will ensure adequate core cooling in the event of a design basis accident.

RA 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 FT 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.

Please provide an explanation of how the 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 for FNP Like the VEGP TS, the LCO Condition for FNP was also revised from a one hour CT to a 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months CT. The arguments in support of the amendment were risk informed. Therefore, this LCO Condition (3.5.1.B) will be excluded from the FNP RICT program.

18) NRC Question #10.5 from SNC letter NL-17-0447, dated April 14, 2017 The proposed change to the TS include Condition 3.6.3.B, Containment Penetrations with more than one inoperable containment isolation valve, A1-26 to NL-18-0039 Basis for Proposed Change 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 for at least 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 period, no actions would be required to isolate the affected penetration D

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 RA 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 open in the isolated position, the safety function of minimizing the loss of be assured.

FT reactor coolant inventory and maintaining the containment pressure boundary would not Please provide justification to support extension of the Completion Time up to a maximum of 30 days or remove those conditions from the scope of the RICT program. Please include an explanation of how PRA functionality would be applied in this Condition, why this condition would not be considered a loss of function, and how it would be assured that design basis success criteria would be satisfied.

SNC Response for FNP Conditions B and C, One or more penetration flow paths with two containment isolation valves inoperable except for purge valve penetration leakage not within limit, and One or more penetration flow paths with one containment isolation valve inoperable, respectively, will be added to the program as loss of function conditions. Condition B is applicable to penetrations with two containment isolation valves and Condition C is applicable to penetrations with one containment isolation valve.

A1-27 to NL-18-0039 Basis for Proposed Change

19) NRC Verbal Question #1 from SNC letter NL-17-0447, dated April 14, 2017 In Condition 3.4.11.E. Two PORVs inoperable and incapable of being manually cycled requires closing and de-energizing the block valves. The current REQUIRED ACTION (RA) statement for this LCO Condition requires closing the associated block valves and removing their power (RAs E.1 and E.2). FSAR Section 15.5.5.1.2.1 describes the inadvertent operation of emergency core cooling systems during power operation (IOECCS) event.

For this event, a manual operator action is assumed to open one PORV for water relief.

The safety analysis assumes that the PORV is opened in approximately 10 minutes.

However, if a block valve is closed and de-energized, the time to 1) recover power to the block valve, 2) open the block valve, then 3) open the PORV, may go beyond 10 minutes.

In their verbal request, NRC asked SNC to reconcile the situation.

Program. D SNC Response for FNP As was done for VEGP, this LCO Condition, 3.4.11.E, will be removed from the FNP RICT RA

20) Common Cause Failure Probabilities In their requests for additional information letters to SNC of February 3, and March 7, 2017 and subsequent telephone conferences, NRC requested information on the VEGPs FT proposed handling of potential common cause failures during RICT entries. NRCs questions were answered via SNC letters NL-17-0447 dated April 14, 2017 and NL 0783, dated May 4, 2017.

Ultimately, NRC and SNC agreed that common cause failures during RICT entry could be handled either by calculational means or by the implementation of Risk Management Actions specifically intended to mitigate the effects of a common cause failure.

Consequently, Paragraph g. was added to Section 5.5.22 of the VEGP TS to describe the means that would be used to mitigate the effects of a common cause failure during RICT entry. The same paragraph will be added to FNP TS Section 5.5.20, as follows:

Upon entering a RICT for an emergent condition, the potential for a common cause (CC) failure must be addressed.

If there is a high degree of confidence, based on the evidence collected, that there is no CC failure mechanism that could affect the redundant components, the RICT calculation may use nominal CC factor probability.

A1-28 to NL-18-0039 Basis for Proposed Change If a high degree of confidence cannot be established that there is no CC failure that could affect redundant components, the RICT shall account for the increased possibility of CC failure. Accounting for the increased possibility of CC failure shall be accomplished by one of two methods. If one of the two methods listed below is not used, the Technical Specifications Front Stop will not be exceeded.

1. The RICT calculation shall be adjusted to numerically account for the increased possibility of CC 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 CC probability for the remaining redundant components shall be increased to represent the conditional failure probability due to CC failure of these components, in order to account for the possibility the first failure was caused by a CC mechanism.

OR

2. Prior to exceeding the front stop, RMAs not already credited in the RICT calculation shall D

be implemented. These RMAs shall 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.

RA Documentation of RMAs shall be available for NRC review.

5. Regulatory Analysis 5.1 Significant Hazards Evaluation FT SNC requests adoption of a change to the Farley Nuclear Plant (FNP) plant-specific technical specifications (TS), to modify the TS requirements related to completion times for required actions to provide the option to calculate a longer, risk-informed completion time.

The allowance is described in a new program in Chapter 5, Administrative Controls, entitled the Risk Informed Completion Time Program.

As required by 10 CFR 50.91(a), an analysis of the issue of no significant hazards consideration is presented below:

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

Response: No The proposed change permits the extension of completion times provided risk is assessed and managed within the Risk Informed Completion Time Program. The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the changes A1-29 to NL-18-0039 Basis for Proposed Change involve no change to the plant or its mode of operation. This proposed change does not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the consequences of an accident during the extended completion time are no different from those during the existing completion time.

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

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

Response: No The proposed TS revision does not change the design, configuration, or method of plant operation. The proposed change does not involve a physical alteration of the plant in that no new or different kind of equipment will be installed.

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

D

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

RA Response: No The proposed change permits the extension of completion times provided risk is assessed and managed within the Risk Informed Completion Time Program. The proposed change implements a risk-informed configuration management program to assure that adequate safety margins are maintained. Application of these new specifications and the FT configuration management program considers cumulative effects of multiple systems or components being out of service and does so more effectively than the current TS.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, SNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5.2 Applicable Regulatory Requirements/Criteria 10 CFR 50.36, Technical Specifications - 10 CFR 50.36(c)(2) states, When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the Technical Specifications until the condition can be met.

The proposed change continues to meet the requirements of this regulation.

A1-30

Attachment 1 to NL-18-0039 Basis for Proposed Change 10 CFR 50.65, Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, requires monitoring the performance of condition of SSCs against licensee-established goals, in a manner sufficient to provide reasonable assurance that these SSCs are capable of fulfilling their intended functions. Additionally, 10 CFR 50.65(a)(4) requires that assessment and management of the increase in risk that may result from a proposed maintenance activity. The proposed change continues to meet the requirements of this regulation.

This license amendment request is consistent with the guidance set forth in NEI 06-09, Revision 0-A, which was found to be consistent with the guidance set forth in Revision 1 of Chapter 19.0, Use of Probabilistic Risk Assessment in Plant -Specific, Risk-Informed Decision making: Technical Specifications, of the Standard Review Plan, NUREG-0800, as well as the guidance of Regulatory Guide (RG) 1.174, Revision 1, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, and RG 1.177, Revision 0, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications.

RG 1.200, Revision 2, An Approach for Determining the Technical Adequacy of D

Probabilistic Risk Assessment Results for Risk-Informed Activities, establishes requirements for PRA technical adequacy. The PRA supporting the proposed change has been assessed using this regulatory guidance.

RA 5.3 Conclusions Based on the consideration discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted with the Commissions regulations, and (3)

FT the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6. Environmental Considerations The proposed TS revision would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed change meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.

A1-31

Attachment 1 to NL-18-0039 Basis for Proposed Change

7. References

1) TSTF-505-A, Rev. 1, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b.

2) Topical Report NEI 06-09, Revision 0-A, Risk-Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines.

3) NUREG-0800, Standard Review Plan 19.1, Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Assessment Results for Risk-Informed Activities, Revision 3, May 2012.

4) NUREG-0800, Standard Review Plan 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance, Revision 0, November, 2002.

5) NUREG-0800, Standard Review Plan 16.1, Risk-Informed Decisionmaking : Technical Specifications, Revision 1, March 20

6) Regulatory Guide 1.174, Revision 2, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis, May, 2011, Accession No. ML100910008.

D

7) Regulatory Guide 1.177, Revision 1, An Approach for Plant-Specific Risk-Informed Decisionmaking: Technical Specifications, May, 2011, Accession No. ML100910008.

8) Regulatory Guide 1.200, Revision 2, An Approach for Determining the Technical RA Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities, March, 2009, Accession No. ML090410014.

FT A1-32

D RA FT

Farley Nuclear Plant Units 1 and 2 License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines" Enclosure 1 List of Revised Required Actions to Corresponding PRA Functions DRA FT to NL-18-0039 List of Revise Required Actions to Corresponding PRA Functions Table of Contents

1.0 INTRODUCTION

AND

SUMMARY

..................................................................................... 4 Revised TS LCO Conditions to Corresponding PRA Functions ................................................. 4 Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit .................................. 25

2.0 REFERENCES

......................................................................................................................... 38 DRA FT E1-1 to NL-18-0039 List of Revise Required Actions to Corresponding PRA Functions 1.0 Introduction and Summary Section 4.0, Item 2 of the Final Safety Evaluation for NEI 06-09 (Revision 0-A, Reference 1) identifies the following License Amendment Request (LAR) content needed on applicable Technical Specifications (TSs), comparison of the TS functions to the probabilistic risk assessment (PRA) functions, and comparison of design basis assumptions to the scope of the PRA:

The LAR will provide identification of the TS Limiting Conditions for Operations (LCO) and action requirements to which the Risk Informed Completion Time (RICT) Program will apply.

The LAR will provide a comparison of the TS functions to the PRA modeled functions of the structures, systems, and components (SSCs) subject to those LCO Actions.

The comparison should justify that the scope of the PRA model, including D

applicable success criteria such as number of SSCs required, flowrate, etc.,

are consistent licensing basis assumptions (i.e., 10 CFR 50.46 ECCS flow rates) for each of the TS requirements, or an appropriate disposition or RA programmatic restriction will be provided.

This enclosure provides confirmation that the Farley Nuclear Plant (FNP) PRA models include the necessary scope of structures, systems, and components (SSCs) and their functions to address each proposed application of the Risk Informed Completion Time (RICT) Program to the TS LCO Conditions. The scope of the comparison includes each FT of the TS LCO conditions and associated required actions applicable to RICT Program implementation at FNP Units 1 and 2.

Table E1.1 below lists each TS LCO Condition to which the RICT Program is proposed to be applied and documents the following information regarding the TSs with the associated safety analyses, the analogous PRA functions and the results of the comparison:

Column TS LCO Condition: Lists all of the LCOs and Condition statements within the scope of the RICT Program.

Column SSCs Covered by TS LCO Condition: The SSCs addressed by each Action requirement.

Column SSCs Modeled in PRA: Indicates whether the SSCs addressed by the TS LCO Condition are included in the PRA.

Column Function Covered by TS LCO Condition: A summary of the required functions from the design basis analyses.

E1-1 to NL-18-0039 List of Revise Required Actions to Corresponding PRA Functions

Column PRA Success Criteria: The function success criteria modeled in the PRA, as specified in the referenced PRA documentation and verified in the PRA model files.

Column Disposition: Justification or resolution to address any inconsistencies between the TS and PRA functions, regarding the scope of SSCs and the success criteria. Where the PRA scope of SSCs is not consistent with the TS, additional information is provided to describe how the LCO Condition can be evaluated using appropriate surrogate events.

Differences in the success criteria for TS functions are addressed to demonstrate the PRA criteria provide a realistic estimate of the actual risk of the TS Condition as required by NEI 06-09 and PRA standards for Capability Category (CC) II.

The corresponding SSCs for each TS LCO and the associated TS functions are D

identified and compared to the PRA. This description also includes the design success criteria and the applicable PRA success criteria. Any difference between the PRA scope or PRA success criteria are described in the table. Scope differences are RA justified by identifying appropriate surrogate events which permit a risk evaluation to be completed using the Configuration Risk Management Program (CRMP) tool for the RICT Program. Differences in success criteria typically arise due to the requirement in the PRA standards (for example, SC-B1) to make PRAs realistic rather than bounding, whereas design basis criteria are necessarily conservative and bounding. The use of realistic success criteria is necessary to conform to CC II of the PRA standards as FT required by NEI 06-09 (Reference 1).

The calculated RICTs, provided in Table E1.2, demonstrate the effect on CDF and LERF for each individual condition to which the RICT Program applies (assuming no other SSCs modeled in the PRA outside the scope of the applicable TS LCO Condition are unavailable). These calculations were performed based on the use of separate zero-maintenance annual average PRA models which include the internal events PRA model, internal fire PRA model that reflects NFP-805 plant modifications, seismic bounding delta CDF/LERF values and main control room abandonment bounding delta CDF/LERF values. Use of the main control room abandonment bounding values may be discontinued in the future if the fire PRA models are revised to include detailed modeling of main control room abandonment risk contribution. In addition, the RICT calculations in Table E1.2 assume that a single SSC impacts the applicable TS LCO Condition for most cases; however, in some cases, more than one SSC was considered to impact the TS LCO Condition to ensure a worst case RICT can be generated for conditions that allow more than one train inoperable but do not meet the criteria for a loss of function. In such cases there are two entries for that LCO. These estimates are based on a Unit 1 model calculation and are considered applicable to Unit 2 for the purpose of providing an estimate due to the close similarity between the Unit 1 and Unit 2 models. The actual RICT values during program implementation will be calculated E1-3 to NL-18-0039 List of Revise Required Actions to Corresponding PRA Functions based on the actual unit and plant configuration and the on-record version of the CRMP model available which represents the as-built and as-operated plant, as required by NEI 06-09 and the NRC Safety Evaluation. For the values presented in the RICT Calculated column of Table E1.2, the equipment removed from service for the calculation is the piece of equipment associated with the applicable LCO Condition.

DRA FT E1-3

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.4.10 Pressurizer 3 PSVs Yes Prevent RCS pressure 3 of 3 PSVs Same as Design Success criteria SSCs are modeled consistent with the TS scope and so can be Safety Valves from exceeding safety for limiting transient (ATWT directly evaluated using the CRMP tool.

limit with initial reactor power >

A. One 40%) The success criteria in the PRA are consistent with the design basis pressurizer safety criteria.

valve inoperable.

(TS LOF) TS LOF PRA Functionality Requirements: :

1 PSV Inoperable requires 3 PSVs PRA Functional 3.4.11 Pressurizer Power Operated Relief 2 PORVs Yes RA Depressurize the RCS in 1) 1 of 2 PORVs for certain transients opening.

1) SAME or more restrictive

2) Function not specifically

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

Valves (PORV)

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

FT

2) 2 of 2 PORVs must not have excessive leakage.

modeled The success criteria in the PRA are consistent with the design basis criteria and in some cases are more restrictive when the PORVs are used to mitigate some beyond design basis scenarios The Function 2 success criteria of 2 of 2 PORVs must not have excessive leakage have no consequence on the likelihood of mitigating a worst case ATWT event. As a result the success criteria in the PRA are consistent with the design basis criteria.

3.4.11 Pressurizer Power Operated Relief Valves (PORV)

C. One Block Valve inoperable 2 Block Valves Yes D

Isolate the flow path through a PORV with excessive leakage.

Associated block valve closed to prevent leakage Same as Design Success criteria SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

The success criteria in the PRA are consistent with the design basis criteria.

E1-4

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.4.11 Pressurizer See LCO Condition 3.4.11.B See LCO Condition 3.4.11.B Power Operated Relief Valves (PORV) TS LOF PRA Functionality Requirements: :

2 PORV Inoperable requires at least 1 PORV PRA E. Two PORVs Functional inoperable and

Design basis criteria for parameters overrides PRA SC criteria not capable of for parameters for Function being manually

Manual actions credited in PRA for Function: None cycled (TS LOF)

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None 3.4.11 Pressurizer Power Operated Relief Valves (PORV)

F. Two blocks valves inoperable See LCO Condition 3.4.11.C RA See LCO Condition 3.4.11.C.

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

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

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h FT D

E1-5

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.5.1 Accumulators ECCS ECCS Supply borated water to 2 of 3 accumulators For LLOCA and MLOCA SSCs are modeled consistent with the TS scope and so can be Accumulators Accumu- the reactor vessel during accidents 2 of 2 Accumulators directly evaluated using the CRMP tool.

A. Two or more lator valves LOCA blowdown phase. to 2 of 2 intact cold legs Accumulators as The success criteria in the PRA are consistent with the design basis inoperable for surrogate For SLOCA and Consequential criteria.

reasons other LOCA 2 out of 3 Accumulators than boron to 2 out of 3 cold legs. TS LOF PRA Functionality Requirements:

concentration not

2 Accumulators Inoperable requires at least 1 within limits (TS Accumulator PRA Functional LOF)

3 Accumulators Inoperable requires at least 2

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

1. Not applicable when two or more ECCS accumulators are intentionally made inoperable.

2. The following Section RA Accumulators PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h FT D

E1-6

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.5.2 ECCS - Operating 3 Centrifugal Yes Provide core cooling and 1 of 3 CCPs LHI (Low-Head Injection) SSCs are modeled consistent with the TS scope and so can be charging pumps negative reactivity for: 1 of 2 LHSI pumps deliver flow to directly evaluated using the CRMP tool.

A. One or more (CCPs) 1 of 2 RHR pumps 2 intact RCS CLs trains inoperable. 1) LOCA The success criteria in the PRA are consistent with the design basis 2 RHR pumps 2) Rod Ejection Accident HHI (High-Head Injection) criteria and in some cases mitigate some beyond design basis AND 3) Loss of secondary 1 of 3 CCPs deliver flow to 2 scenarios like SIT (SI Termination) where Operator terminates 2 RHR heat coolant accident intact RCS CLs CCPs and establishes normal charging.

At least 100% of exchangers 4) Steam Generator Tube the ECCS flow Rupture HLR (Hot Leg Recirculation) equivalent to a 1 of 2 LHSI pumps deliver flow to single OPERABLE ECCS train available RA 1 intact RCS Hot Leg (HL)

LHR (Low-Head Recirculation) 1 of 2 LHSI pumps deliver flow to 2 intact RCS CLs LTC (Long Term Cooling - HHR) 1 of 3 CCPs delivers flow to 2 3.5.4 Refueling Water RWST Yes FT intact RCS CLs LTC (Long Term Cooling - LHR) 1 of 2 RHR trains deliver flow to 2 intact RCS CLs SIT (SI Termination) Operator terminates CCPs and establishes normal charging Supply borated water to Boron concentration limits Same as Design Success Criteria TS LOF PRA Functionality Requirements:

Storage Tank B. RWST inoperable for reasons other than Condition A.

(TS LOF)

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

1. Not applicable when ECCS and D

Containment Spray during LOCA phase for

1) negative reactivity for reactor shutdown, and

2) core and containment cooling and containment and temperature limits met.

RWST is required to be PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None the RWST is intentionally depressurization made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h E1-7

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.6.2 Containment Air Containment Yes Control of Post- Post-Accident Containment Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be Locks Airlock Doors Accident Containment Leakage Rates within limits directly evaluated using the CRMP tool.

Leakage Rates C. One or more The success criteria in the PRA are consistent with the design basis containment criteria airlock doors open for reasons other than Conditions A or B 3.6.3 Containment Two isolation Yes Isolate Containment One Containment isolation Same as Design Success Criteria The PRA does not explicitly model the impact of excessive stroke Isolation Valves A. One or more penetration flow paths with one containment isolation valve inoperable except devices within assumed time limits to prevent excessive RCS loss and establish containment pressure boundary post-accident RA valve closed within stroke time limits, if applicable.

time.

This condition can be addressed for the RICT Program by assuming the inoperable containment isolation valve(s) to be unavailable (failed open) in the PRA model if it is open. Therefore, this LCO condition can be evaluated using the CRMP tool.

The success criteria in the PRA are consistent with the design basis for purge valve penetration leakage not within limit

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

Only applicable to penetration flow paths with two containment FT criteria.

isolation valves.

D E1-8

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.6.3 Containment See LCO Condition 3.6.3.A Isolation Valves B. One or more penetration flow paths with two containment isolation valves inoperable except for purge valve penetration leakage not within limit

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

Only applicable to penetration flow paths with two containment RA isolation valves. Not applicable when the second Containment Isolation valve is intentionally made inoperable The following Section 5.5.20 Constraints apply:

parts b, c2, c3, d, e, f, g, and h FT D

E1-9

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.6.3 Containment Penetration flow Yes See LCO Condition Containment isolation valve See LCO Condition 3.6.3.A See LCO Condition 3.6.3.A Isolation Valves paths with one 3.6.3.A closed within stroke time isolation valve limits, if applicable. Closed C. One or more and a closed system intact.

penetration flow system paths with one containment isolation valve inoperable.

NOTES-----

Only applicable to penetration flow paths with one containment isolation valve and a closed system.

Not applicable when the second RA Containment Isolation valve is intentionally made inoperable The following Section 5.5.20 Constraints apply: parts b, c2, c3, d, e, f, g, and h 3.6.6 Containment Spray and Cooling Systems 2 Containment Spray Systems Yes Provides a spray of cold borated water into the upper regions of FT 1 of 2 Containment Spray Same as Design Success Criteria The PRA models the containment heat removal function trains consistently with the DBA. However, the PRA does not model the fission product removal functions.

A. One containment spray train inoperable pressure and D

containment to reduce the containment temperature and to reduce fission products Use of RICT for this TS Condition is contingent on the sufficiency and availability of the fission product removal functions.

E1-10

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.6.6 Containment Spray See LCO Condition 3.6.6.A See LCO Condition 3.6.6.A and Cooling Systems TS LOF PRA Functionality Requirements: :

B. Two containment

One containment spray system is required to be PRA spray trains Functional inoperable

Design basis criteria for parameters overrides PRA SC (TS LOF) criteria for parameters for Function

Manual actions credited in PRA for Function: None

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

Manual actions not credited in PRA for Function: None

1. Not applicable when

SSCs not modeled in PRA for Function: None the second containment spray train is intentionally made inoperable

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g RA and h 3.6.6 Containment Spray and Cooling Systems D. One containment cooling train inoperable.

2 Containment cooling trains 3.6.6 Containment Spray See LCO Condition 3.6.6.D Yes Limits the ambient containment air temperature during normal unit operation to less than the design limit.

FT 1 of two containment cooling trains 2 of 4 CCS Fan Coolers (FCs) operations are not modeled but SSCs modeled in the PRA using a more restrictive success criteria for the DBA than the TS scope and so can be directly evaluated The CCS functions during normal using the CRMP tool.

PRA modeling is more restrictive The success criteria in the PRA are consistent with the design basis and supports DBA. criteria See LCO Condition 3.6.6.D and Cooling Systems E. Two containment cooling trains inoperable.

D E1-11

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.6.6 Containment Spray See LCO Condition 3.6.6.A and 3.6.6.D See Condition LCO Condition 3.6.6.A and 3.6.6.D and Cooling Systems TS LOF PRA Functionality Requirements:

G. Any combination

2 Containment Spray trains and 1 containment cooling of three or more train Inoperable requires at least 1 containment spray trains inoperable train PRA Functional (TS LOF)

2 Containment cooling trains and 1 containment spray train Inoperable requires at least 1 containment cooling

NOTES----------- train PRA Functional

1. Not applicable when

2 Containment Spray trains and 2 containment cooling three or more combinations of trains are intentionally made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h RA train Inoperable requires at least 1 containment spray train and 1 containment cooling train PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None 3.7.2 Main Steam Isolation valves A. One or more steam lines with one MSIV inoperable in MODE 1.

2 MSIVs per steam line Yes Isolate steam flow from the secondary side of the steam generators in a High Energy Line Break. FT One MSIV closes in each steam line (1) SGI (SG Isolation) for SSB: 1 of 2 MSIVs closed on all three SGs to prevent blowdown of the intact SGs (2) SGI (Ruptured SG Isolation) for SGTR:

1 of 2 MSIVs closed on ruptured SG SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool and EOOS model.

The success criteria in the PRA are consistent with the design basis criteria D OR

1 of 2 MSIVs on each of 2 intact SGs closed to prevent blowdown of the ruptured SG.

E1-12

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.7.2 Main Steam See LCO Condition 3.7.2.A See LCO Condition 3.7.2.A Isolation valves TS LOF PRA Functionality Requirements:

B. One or more

1 main steam line with two MSIVs inoperable requires at main steam lines least 1 MSIV PRA Functional in each steamline with two MSIVs

2 main steam lines with two MSIVs inoperable requires at inoperable in least 1 MSIV PRA Functional in each steamline MODE 1. (TS

3 main steam lines with two MSIVs inoperable requires at LOF) least 1 MSIV PRA Functional in each steamline

Design basis criteria for parameters overrides PRA SC criteria

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

1. Not applicable when second MSIV in a line is intentionally made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, RA

for parameters for Function Manual actions credited in PRA for Function: None Manual actions not credited in PRA for Function: None SSCs not modeled in PRA for Function: None c3, d, e, f, g and h 3.7.4 Atmospheric Relief Valves A. One required ARV line inoperable.

3 Atmospheric Relief Valves 3.7.4 Atmospheric Relief See LCO Condition 3.7.4.A Yes Cools the unit to RHR entry conditions if the preferred heat sink via the steam dump system to the main condenser becomes unavailable.

FT One ARV remains available Same as Design Basis Criteria following a SGTR. 4 of 4 ARV Lines.

SSCs are modeled consistent with the TS scope and so can be to conduct a unit cooldown except for ATWT conditions, then directly evaluated using the CRMP tool.

The success criteria in the PRA are consistent with the design basis criteria with exception noted below PRA SC differs from the DB SC, the PRA SC are judged to be more realistic and restrictive than those assumed in the DB analysis.

Valves B. Two required ARV lines inoperable.

D E1-13

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.7.4 Atmospheric Relief See LCO Condition 3.7.4.A. See LCO Condition 3.7.4.A.

Valves TS LOF PRA Functionality Requirements C. Three required

3 ARVs lines inoperable requires 1 ARV lines to be PRA ARV lines Functional inoperable

Design basis criteria for parameters overrides PRA SC criteria (TS LOF) for parameters for Function

Manual actions credited in PRA for Function: OPERATOR

NOTES----------- FAILS TO LOCALLY OPEN ATMOS RELIEF VLVS ON

1. Not applicable when LOSS OF SUPPORT second MSIV in a line is intentionally made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h 3.7.5 Auxiliary 2 steam supplies Yes Provide a steam supply RA1 of 2 steam supplies Same as Design Basis Criteria

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None SSCs are modeled consistent with the TS scope and so can be Feedwater System A. One steam supply to turbine driven AFW pump inoperable 3.7.5 Auxiliary Feedwater System B. One AFW train 2 motor driven auxiliary feedwater pumps, and 1 turbine Yes to the turbine driven auxiliary feedwater pump.

Supply feedwater to the steam generators to remove heat.

FT available 2 of 3 AFW pumps 1 of 3 except for ATWT conditions, where more restrictive criteria of 3 of 3 are applied directly evaluated using the CRMP tool and EOOS model.

The success criteria in the PRA are consistent with the design basis criteria SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

The success criteria in the PRA are based on a realistic analysis inoperable for reasons other than Condition A.

driven.

D and for all initiators except ATWT are less restrictive than the design basis criteria, and more conservative for mitigation of beyond design basis ATWT scenarios.

E1-14

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.7.5 Auxiliary See LCO Condition 3.7.5.B See LCO Condition 3.7.5.B Feedwater System TS LOF PRA Functionality Requirements:

2 AFW trains are required to be PRA Functional.

C. Two AFW trains

Design basis criteria for parameters overrides PRA SC inoperable (TS criteria for parameters for Function LOF)

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: None

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

SSCs not modeled in PRA for Function: None

1. Not applicable when the second AFW train is intentionally made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h 3.7.6 Condensate One condensate Yes Provides a safety grade RA CST Operable CST available OR SSCs are modeled consistent with the TS scope and so can be Storage Tank A. CST Inoperable (LOF)

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

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

2. The following Section storage tank source of water to the Steam Generators. Also provides a passive flow of water to the Auxiliary Feedwater (AFW)

System.

FT Plant Service Water suction source to AFW pumps available.

directly evaluated using the CRMP tool.

Since this is a TS LOF Condition, PRA parameter success criteria are overridden by design basis parameters for the purpose of establishing PRA functionality.

An NRC approval is sought as part of this LAR submittal to credit use of plant service water as modeled in the PRA as an alternate source of water to recover degraded CST design basis parameters for establishing PRA Functionality.

5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h D The PRA success criteria are consistent with the design basis criteria.

LOF PRA Functionality Requirements:

1 CST Inoperable requires 1 CST OR Plant Service Water suction source to AFW pumps available to recover degraded CST design basis parameters.

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: Failure of OPERATOR to align SW TO AFW Pump Suction

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None E1-15

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.7.7 Component 2 trains of CCW Yes The CCW System One of two CCW trains Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be Cooling Water each with one full provides a heat sink for except the initial containment directly evaluated using the CRMP tool.

capacity pump. the removal of process temperature assumed in the A. One CCW train and PRA Success Criteria analysis The success criteria in the PRA are consistent with the design basis inoperable operating heat from is 125°F, max design basis criteria for the number of pump trains required. The inlet sump safety related containment sump temp temperature in the PRA is a function of the realistic accident components during a assumed is 132.8°F. progression conditions experienced for the accident sequence Design Basis being analyzed by MAAP. Realistic success criteria are used Accident (DBA) or consistent with the PRA standards for CC II.

transient.

3.7.7 Component Cooling Water B. Two CCW trains inoperable (TS LOF)

See LCO Condition 3.7.7.A.

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

RA See LCO Condition 3.7.7.A TS LOF PRA Functionality Requirements: :

2 CCW trains Inoperable requires at least 1 CCW train PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function:

Manual actions credited in PRA for Function: None

1. Not applicable when second CCW train is intentionally made System inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h 3.7.8 Service Water 2 SWS trains each consisting of Yes Provides a heat sink for the removal of process FT One SWS train, in conjunction with the CCW (1) 1 SW train with 1 SW pump per train for non-LOSP/non-SI

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

A. One SWS Train inoperable 2 50% capacity pumps and 1 50% capacity shared pump. D and operating heat from safety related components during a Design Basis Accident (DBA) or transient.

System and a 100%

capacity containment cooling system.

conditions, (2) 1 SW train with 1 SW pumps per train for LOSP prior to the need for RHR cooling and if the dilution bypass valves are not open, and (3) 1 SW train with 2 SW pumps per train for SI conditions.

The success criteria in the PRA are less restrictive than the design basis criteria for non-LOSP/non-SI conditions, but are consistent with the design basis criteria for other conditions, and are more realistic and consistent with the PRA standards for CC II which requires use of realistic analysis to support a RI application.

E1-16

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.7.8 Service Water See LCO Condition 3.7.8.A See LCO Condition 3.7.8.A System TS LOF PRA Functionality Requirements: :

B. Two SWS Trains

2 Service Water trains Inoperable requires at least 1 inoperable (TS Service Water train PRA Functional LOF)

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function:

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

Manual actions credited in PRA for Function: None

1. Not applicable when

Manual actions not credited in PRA for Function: None second CCW train is

SSCs not modeled in PRA for Function: None intentionally made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h 3.7.11 Control Room Air Two independent Yes Conditioning System and redundant Provides temperature control for the FNP RA One CRACS train Not Modeled- Documented in PRA basis as not needed to See LCO Condition 3.7.11.A (CRACS)

E. Two CRACs trains inoperable (TS LOF)

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

1. Not applicable when second CRACS train is trains of the Control Room Air Conditioning System common control room by maintaining an adequate control room temperature for 30 days of continuous occupancy. FT prevent to core damage. TS LOF PRA Functionality Requirements:

2 CRACS trains requires at least 1 CRACS train to be PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: examples of simple and uncomplicated actions include opening doors and starting the opposite train cooler with at least 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months available to prevent a reactor trip on loss of control room intentionally made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h D cooling.

SSCs not modeled in PRA for Function: None E1-17

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.7.19 Engineered Two ESF Room Room cooling for ESF 1 of 2 trains. Same as Design Success Criteria Charging Pump A and C belong to Train A and B, respectively.

Safety Features (ESF) Cooler and equipment provided by Charging Pump B is the swing pump and can align to either train.

Room Coolers Safety-Related ESF Room Coolers. The Only one pump per train is necessary for operability of HHSI. The Chiller Trains Room Coolers are swing pump and its associated cooler can be powered from either A. One required divided into subsystems Train A or B.

ESF Room and each subsystem has Cooler two 100% capacity trains. ESF Room Cooler Subsystems are:

subsystem Train

Motor Driven Auxiliary Feedwater (MDAFW) Pump Rooms inoperable

Charging Pump Rooms

Containment Spray (CS) Pump Rooms RA

Component Cooling Water (CCW) Pumps Room

Auxiliary Building DC Switchgear / Battery Charger Rooms

Load Control Center (LCC) Rooms (LCC D and E Rooms)

The ESF room coolers are considered support equipment for ESF equipment in the above rooms with the exception of the CCW Pumps Room 3.7.19 Engineered Safety Features (ESF)

Room Coolers B. Two trains of the same ESF Room Cooler subsystem inoperable (TS See LCO Condition 3.7.19.A FT See LCO Condition 3.7.19.A TS LOF PRA Functionality Requirements:

2 ESF room cooler trains of the same subsystem requires at least 1 ESF room cooler train to be PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None LOF)

Manual actions not credited in PRA for Function: None

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

1. Not applicable when second ESF room cooler is intentionally made inoperable.

2. The following Section 5.5.20 constraints are D

SSCs not modeled in PRA for Function: None applicable: parts b, c2, c3, d, e, f, g and h E1-18

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.8.1 AC Sources - Breakers, Yes Transmit power from 1 of 2 circuits. Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be Operating transformers, offsite transmission directly evaluated using the CRMP tool.

switches, network to onsite Class A. One required interrupting 1E ESF buses The success criteria in the PRA are consistent with the design basis offsite circuit devices, cabling, criteria.

inoperable and controls required to transmit power from the offsite transmission 3.8.1 AC Sources -

Operating B. One DG set inoperable network to the onsite Class 1E ESF bus(es).

2 DG Sets, each set comprised of 2 DGs.

Yes Upon loss of preferred power, supply ESF loads in time to mitigate consequences of a DBA RA 1 of 2 DG Sets. Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

The success criteria in the PRA are consistent with the design basis criteria 3.8.1 AC Sources -

Operating C. Two required offsite circuits inoperable See LCO Condition 3.8.1.A FT See LCO Condition 3.8.1.A D

E1-19

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.8.1 AC Sources - Breakers, See LCO Conditions 3.8.1.A and 3.8.1.B See LCO Conditions 3.8.1.A and 3.8.1.B Operating transformers, switches, D. One required interrupting offsite circuit devices, cabling, inoperable. and controls required to AND transmit power from the offsite One DG set transmission inoperable. network to the onsite Class 1E ESF bus(es),

and 2 sets of DGs, each set RA 3.8.1 AC Sources -

Operating E. Two DG sets inoperable 3.8.1 AC Sources -

Operating comprised of 2 DGs.

See LCO Condition 3.8.1.A 2 sequencers Yes 1) Provides a pre-determined sequence of FT 1 of 2 sequencers for both functions 1 and 2 Same as Design Success Criteria See LCO Conditions 3.8.1.A and 3.8.1.C SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

G. One Automatic Load Sequencer inoperable D

loading the DGs, and

2) Also actuates the ESF loads on the offsite circuits when offsite power is available.

The success criteria in the PRA are consistent with the design basis criteria.

E1-20

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.8.1 AC Sources See LCO Conditions 3.8.1.A and 3.8.1.B See LCO Conditions 3.8.1.A and 3.8.1.B H. Three or more TS LOF PRA Functionality Requirements:

required AC

3 AC Sources Inoperable: 2 DG trains and 1 offsite AC Sources source inoperable (1 offsite source operable) requires inoperable (TS at least 1 offsite AC source or 1 DG train PRA LOF) Functional

3 AC Sources Inoperable: 1 DG train (1 offsite AC

NOTES----------- operable) and 2 offsite AC sources inoperable requires

1. Not applicable when at least 1 DG trains or 1 offsite AC source PRA three or more AC sources are intentionally made inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h RA Functional

4 AC sources inoperable: 2 DG Trains and 2 Offsite AC sources Inoperable requires at least 1 DG train and 1 offsite source PRA Functional; OR

4 AC sources inoperable: 2 DG Trains and 2 Offsite AC sources Inoperable requires at least 2 DG trains PRA Functional; OR

4 AC sources inoperable: 2 DG Trains and 2 Offsite AC 3.8.4 DC Sources - 2 trains of Yes Supplies DC power to FT

1) 1 of 2 trains 1) Same as Design Success sources Inoperable requires at least 2 Offsite AC sources PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: None

SSCs not modeled in PRA for Function: None SSCs are modeled consistent with the TS scope and so can be Operating Auxiliary DC various ESF systems Criteria with the exception directly evaluated using the CRMP tool.

A. One Auxiliary Building DC electrical power subsystem inoperable system D

throughout the plant. that PRA models reactor trip on loss of AB DC train. The success criteria in the PRA are consistent with the design basis criteria except that PRA models reactor trip on loss of AB DC train.

This is consistent with the plant practice of initiating a reactor trip on loss of AB DC train E1-21

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.8.4 DC Sources - See LCO Condition 3.8.4.A Operating B. One Auxiliary Building DC electrical power subsystem with battery connection resistance not within limit.

3.8.4 DC Sources -

Operating D. One required SWIS DC electrical power subsystem Four 125 VDC batteries with battery chargers (Shared between the two units).

Yes Provide a reliable source of power for controls, power loads, annunciation and alarms RA 1 of 2 subsystems. 1) 1 of 2 trains supporting 2 of 2 SW Pumps per train SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

The success criteria in the PRA are consistent with the design basis criteria except that PRA additionally requires 2 of 2 SW pumps per train.

battery connection resistance not within limit.

3.8.4 DC Sources -

Operating F. Two or more DC electrical subsystems See LCO Condition 3.8.4.A FT See LCO Condition 3.8.4.A TS LOF PRA Functionality Requirements:

Two DC electrical subsystems inoperable requires at least one DC electrical power subsystem to be PRA functional inoperable that result in a loss of function (TS LOF)

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

1. Not applicable when second DC power electrical subsystem is D

Three DC electrical subsystems inoperable requires at least 1 DC electrical power subsystem to be PRA functional intentionally removed from service.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h E1-22

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.8.7 Inverters - 4 Class 1E Yes Provides reliable AC One train with 2 of 2 Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be Operating inverters electrical power to the inverters, (each train directly evaluated using the CRMP tool.

vital buses redundant).

A. One required The success criteria in the PRA are consistent with the design basis inverter criteria inoperable 3.8.7 Inverters - See LCO Condition 3.8.7.A See LCO Condition 3.8.7.A Operating TS LOF PRA Functionality Requirements:

B. Two or more

One required inverter in each train inoperable requires required inverters inoperable (TS LOF)

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

1. Not applicable when second required inverter is intentionally made RA one train to have two inverters to be PRA functional

Two required inverters inoperable (both in one train) requires two inverters on the opposite train

Three required inverters inoperable (two on one train and one on opposite train) requires either one in the opposite train to be PRA functional.

inoperable.

2. The following Section 5.5.20 constraints are applicable: parts b, c2, c3, d, e, f, g and h 3.8.9 Distribution Systems - Operating A. One or more AC electrical Two trains each of AC Safety buses Yes Provide necessary power to ESF systems FT 1 of 2 AC trains Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

The success criteria in the PRA are consistent with the design basis criteria.

distribution subsystems inoperable 3.8.9 Distribution Systems -

Operating B. One or more AC Vital buses Two AC Vital distribution panels per train Yes D Provide necessary power to Essential Instrumentation.

1 Train with 2 of 2 distribution panels (each train redundant)

Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be directly evaluated using the CRMP tool.

The success criteria in the PRA are consistent with the design basis criteria.

inoperable E1-23

Table E1.1 Revised TS LCO Conditions to Corresponding PRA Functions SSCs Covered SSCs Function Covered by TS LCO Condition by TS LCO Modeled in Design Success Criteria PRA Success Criteria Disposition TS LCO Condition Condition PRA 3.8.9 Distribution Two DC Yes Provides a source of DC 2 of 2 Distribution Panels in Same as Design Success Criteria SSCs are modeled consistent with the TS scope and so can be Systems- Operating Distribution power for control and one train. (each train directly evaluated using the CRMP tool.

Panels per train instrumentation during redundant)

C. One Auxiliary normal conditions and The success criteria in the PRA are consistent with the design basis Building DC design basis events. criteria.

electrical power distribution subsystem inoperable 3.8.9 Distribution See LCO Conditions 3.8.9.A thru 3.8.9 C See LCO Conditions 3.8.9.A thru 3.8.9 C Systems -Operating D. Two trains with inoperable distribution subsystems that result in a loss of safety function RA LOF PRA Functionality Requirements: :

2 trains inoperable requires at least one 1 train PRA Functional

Design basis criteria for parameters overrides PRA SC criteria for parameters for Function

Manual actions credited in PRA for Function: None

Manual actions not credited in PRA for Function: None (TS LOF)

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

1. Not applicable when two or more electrical power distribution trains are intentionally made inoperable.

2. The following Section 5.5.20 constraints are FT

SSCs not modeled in PRA for Function: None applicable: parts b, c2, c3, d, e, f, g and h D

E1-24 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.4.10 Pressurizer Safety 1PZRV8010A---D (PRA Functional) 30.0 (30.0)

Valves (PRESSURIZER SV 8010A FAILS TO OPEN DUE TO RANDOM FAULTS)

A. One pressurizer safety valve inoperable. (TS LOF) 3.4.11 Pressurizer Power 1PZAV444B----D (HARDWARE 30.0 (30.0)

Operated Relief Valves FAULTS OF PORV 444B)

(PORV)

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

3.4.11 Pressurizer Power 1PZMV8000B---K (PRESSURIZER 30.0 (30.0)

Operated Relief Valves PORV BLOCK VALVE 8000B FAILS (PORV) TO CLOSE)

C. One Block Valve inoperable 3.4.11 Pressurizer Power 1PZAV444B----D (HARDWARE 30.0 (30.0)

Operated Relief Valves FAULTS OF PORV 444B)

(PORV)

E. Two PORVs inoperable and not capable of being manually cycled (TS LOF) 3.4.11 Pressurizer Power 1PZMV8000A---K (PRESSURIZER 30.0 (30.0)

Operated Relief Valves PORV BLOCK VALVE 8000A FAILS (PORV) TO CLOSE) and 1PZMV8000B---K (PRESSURIZER PORV BLOCK F. Two block valves VALVE 8000B FAILS TO CLOSE) inoperable E1-25 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.5.1 Accumulators 1HHMV8808A---V (ACCUMULATOR 30.0 (30.0) 1A ISOLATION VALVE)

C. Two or more Accumulators inoperable for reasons other than boron concentrations not within limits (TS LOF) 3.5.2 ECCS - Operating 1LHPMP001A---A (RHR/LHI PUMP P- 14.4 (10.7) 001A FAILS TO START DUE TO A. One or more trains RANDOM FAILURE) inoperable.

AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available 3.5.2 ECCS - Operating 1HHPMP002A---A (CHG PUMP P002A 30.0 (25.0)

FAILS TO START)

A. One or more trains inoperable.

AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available 3.5.4 Refueling Water 1SITKF16T501-R (PRA Functional) 30.0 (30.0)

Storage Tank (RWST RUPTURES)

B. RWST inoperable for 1HHCV8926----D (PRA Functional) reasons other than (RWST TO CHARGING PUMPS Condition A. (TS LOF) CHECK VALVE 8926 FAILS TO OPEN)

E1-26 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.6.2 Containment Air ADMN-PEN-NI (surrogate) 30.0 (5.3)

Locks (ADMINISTRATIVELY CONTROLLED PENETRATIONS NOT ISOLATED)

C. One or more containment airlock doors open for reasons other than Conditions A or B 3.6.3 Containment 1CICVB13V038-K (CHECK VALVE 30.0 (7.1)

Isolation Valves QnB31V038 FAILS TO CLOSE)

A. One or more penetration flow paths with one containment isolation valve inoperable except for purge valve penetration leakage not within limit 3.6.3 Containment 1CICVG21V204-K (CHECK VALVE 30.0 (26.2)

Isolation Valves QnG21V204 FAILS TO CLOSE)

A. One or more penetration flow paths with one containment isolation valve inoperable except for purge valve penetration leakage not within limit 3.6.3 Containment 1CIAVB13V040-K (AOV QnB31V040 30.0 (5.3)

Isolation Valves FAILS TO CLOSE (HARDWARE)) and 1CICVB13V038-K (CHECK VALVE A. One or more QnB31V038 FAILS TO CLOSE) penetration flow paths with two containment isolation valves inoperable except for purge valve penetration leakage not within limit E1-27 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.6.3 Containment ADMN-PEN-NI (surrogate) 30.0 (5.3)

Isolation Valves (ADMINISTRATIVELY CONTROLLED PENETRATIONS NOT ISOLATED)

C. One or more penetration flow paths with one containment isolation valve inoperable.

3.6.6 Containment Not Modeled since not needed for core 30.0 (30.0)

Spray and Cooling damage prevention. 30 day back stop Systems applies A. One containment spray train inoperable 3.6.6 Containment Spray Not Modeled since not needed for core 30.0 (30.0) and Cooling Systems damage prevention. 30 day back stop applies B. Two containment spray trains inoperable (TS LOF) 3.6.6 Containment Spray 1FCMOH001D---F (FAN MOTOR D 30.0 (30.0) and Cooling Systems FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS) ,1FCMOH001C---

D. One containment F (FAN MOTOR C FAILS TO SWITCH cooling train inoperable. SPEEDS DUE TO RANDOM FAULTS) 3.6.6 Containment Spray 1FCMOH001D---F(FAN MOTOR D 15.7 (30.0) and Cooling Systems FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS),1FCMOH001C---F E. Two containment (FAN MOTOR C FAILS TO SWITCH cooling trains inoperable. SPEEDS DUE TO RANDOM FAULTS),1FCMOH001A---F (FAN MOTOR A FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS),1FCMOH001B---F (FAN MOTOR B FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS)

E1-28 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.6.6 Containment Spray 1FCMOH001D---F(FAN MOTOR D 15.7 (30.0) and Cooling Systems FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS),1FCMOH001C---F G. Any combination of (FAN MOTOR C FAILS TO SWITCH three or more trains SPEEDS DUE TO RANDOM inoperable (TS LOF) FAULTS),1FCMOH001A---F (FAN MOTOR A FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS),1FCMOH001B---F (FAN MOTOR B FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS) 3.6.6 Containment Spray 1FCMOH001D---F (FAN MOTOR D 30.0 (30.0) and Cooling Systems FAILS TO SWITCH SPEEDS DUE TO RANDOM FAULTS) ,1FCMOH001C---

G. Any combination of F (FAN MOTOR C FAILS TO SWITCH three or more trains SPEEDS DUE TO RANDOM FAULTS) inoperable (TS LOF) 3.7.2 Main Steam 1MSHV3369A---K (MSIV HV-3369A 30.0 (30.0)

Isolation valves FAILS TO CLOSE DUE TO HARDWARE FAULTS), 1MSHV3369B-A. One or more steam --K, HV-3369B FAILS TO CLOSE DUE lines with one MSIV TO HARDWARE FAULTS),

inoperable in MODE 1. 1MSHV3369C---K (HV-3369C FAILS TO CLOSE DUE TO HARDWARE FAULTS),

3.7.2 Main Steam 1MSHV3369A---K (MSIV HV-3369A 30.0 (30.0)

Isolation valves FAILS TO CLOSE DUE TO HARDWARE FAULTS)

B. One or more main steam lines with two MSIVs inoperable in MODE 1. (TS LOF) 3.7.2 Main Steam 1MSHV3369A---K (MSIV HV-3369A 30.0 (30.0)

Isolation valves FAILS TO CLOSE DUE TO HARDWARE FAULTS), 1MSHV3369B-B. One or more main --K, HV-3369B FAILS TO CLOSE DUE steam lines with two TO HARDWARE FAULTS),

MSIVs inoperable in MODE 1. (TS LOF)

E1-29 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.7.2 Main Steam 1MSHV3369A---K (MSIV HV-3369A 30.0 (30.0)

Isolation valves FAILS TO CLOSE DUE TO HARDWARE FAULTS), 1MSHV3369B-B. One or more main --K, HV-3369B FAILS TO CLOSE DUE steam lines with two TO HARDWARE MSIVs inoperable in FAULTS),1MSHV3369C---K (HV-MODE 1. (TS LOF) 3369C FAILS TO CLOSE DUE TO HARDWARE FAULTS),

3.7.4 Atmospheric Relief 1MSAVPV3371A-D (SG ARV 30.0 (30.0)

Valves PV3371A FAILS TO OPEN DUE TO RANDOM FAULTS)

A. One required ARV line inoperable.

3.7.4 Atmospheric Relief 1MSAVPV3371A-D (SG ARV 30.0 (30.0)

Valves PV3371A FAILS TO OPEN DUE TO RANDOM FAULTS) AND B. Two or more required 1MSAVPV3371B-D (SG ARV ARV lines inoperable PV3371B FAILS TO OPEN DUE TO RANDOM FAULTS) 3.7.4 Atmospheric Relief 1MSAVPV3371A-D (SG ARV 30.0 (30.0)

Valves PV3371A FAILS TO OPEN DUE TO RANDOM FAULTS) AND C. Three required ARV 1MSAVPV3371B-D (SG ARV lines inoperable. PV3371B FAILS TO OPEN DUE TO (TS LOF) RANDOM FAULTS) 3.7.5 Auxiliary Feedwater 1AFXV005B----V (L.O. MANUAL 30.0 (30.0)

System VALVE V005B FAILS CLOSED (IN SEGMENT TI)

A. One steam supply to turbine driven AFW pump inoperable 3.7.5 Auxiliary Feedwater 1AFPM001B----A (MDP B FAILS TO 11.4 (30.0)

System START DUE TO RANDOM FAULTS)

B. One AFW train inoperable for reasons other than Condition A.

E1-30 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.7.5 Auxiliary Feedwater 1AFPT002-----A (TDP P002 FAILS TO 24.5 (17.6)

System START DUE TO RANDOM FAULTS)

B. One AFW train inoperable for reasons other than Condition A.

3.7.5.Auxiliary Feedwater 1AFPT002-----A (TDP P002 FAILS TO 24.5 (17.6)

System START DUE TO RANDOM FAULTS)

C. Two AFW trains inoperable (TS LOF) 3.7.5.Auxiliary Feedwater 1AFPM001B----A (MDP B FAILS TO 11.4 (30.0)

System START DUE TO RANDOM FAULTS)

C. Two AFW trains inoperable (TS LOF) 3.7.6 Condensate 1AFTK-CST-TR-R (CST EXCESSIVE 11.7 (16.5)

Storage Tank LEAKAGE REQUIRING MAKEUP PRIOR TO 24 HOURS)

A. CST Inoperable (TS LOF) 3.7.6 Condensate 1AFCV007A----V (CHECK VALVE 30.0 (30.0)

Storage Tank V007A TRANSFERS CLOSED)

A. CST Inoperable (TS LOF) 3.7.7 Component Cooling 1CCPM001C----A (CCW PUMP C 30.0 (30.0)

Water FAILS TO START DUE TO RANDOM FAULTS) AND A. One CCW train 1CCPM001B----A (CCW PUMP B FTS inoperable DUE TO RANDOM FAULTS) 3.7.7 Component Cooling 1CCPM001C----A (CCW PUMP C 30.0 (30.0)

Water FAILS TO START DUE TO RANDOM FAULTS)

A. One CCW train inoperable E1-31 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.7.7 Component Cooling 1CCPM001C----A (CCW PUMP C 30.0 (30.0)

Water FAILS TO START DUE TO RANDOM FAULTS) AND B. Two CCW trains 1CCPM001B----A (CCW PUMP B FTS inoperable (TS LOF) DUE TO RANDOM FAULTS) 3.7.8 Service Water 1SWPM1A------A (SW PUMP 1A 26.1 (30.0)

System RANDOMLY FAILS TO START),

1SWPM1B------A (SW PUMP 1B A. One SWS Train RANDOMLY FAILS TO START) inoperable 3.7.8 Service Water 1SWPM1A------A (SW PUMP 1A 26.1 (30.0)

System RANDOMLY FAILS TO START),

1SWPM1B------A (SW PUMP 1B B. Two SWS Trains RANDOMLY FAILS TO START) inoperable (TS LOF) 3.7.11 Control Room Air Not Modeled- Documented in PRA 30.0 (30.0)

Conditioning System basis heat up analysis as not needed (CRACS) to prevent to core damage.

E. Two CRACs trains inoperable (TS LOF) 3.7.19 Engineered Safety 1HHMOM001A---X (CHG PMP A FAN 9.1 (9.6)

Features (ESF) Room COOLER FAILS TO RUN DUE TO Coolers RANDOM FAULTS),

1LHMOM003A---X (RHR PUMP 1A A. One required ESF FAN COOLER FAILS TO RUN DUE Room Cooler subsystem TO RANDOM FAULTS),

Train inoperable 1CSMOM002A---X (CS PUMP Q1E13P001A ROOM COOLER RANDOMLY FAILS TO RUN),

1AFMOH005A-TRX (MDAFW PUMP A ROOM COOLER FTR DUE TO RANDOM FAULTS)

E1-32 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.7.19 Engineered Safety 1HHMOM001C---X (PMP C FAN 9.1 (28.5)

Features (ESF) Room COOLER FAILS TO RUN DUETO Coolers RANDOM FAULTS) AND 1LHMOM003B---X (RHR PUMP 1B A. One required ESF FAN COOLER FAILS TO RUN DUE Room Cooler subsystem TO RANDOM FAULTS) AND Train inoperable 1CSMOM002B---X (CS PUMP Q1E13P001B ROOM COOLER RANDOMLY FAILS TO RUN) AND 1AFMOH005B-TRX (MDAFW PUMP B ROOM COOLER FTR DUE TO RANDOM FAULTS) 3.7.19 Engineered Safety 1HHMOM001A---X (CHG PMP A FAN 9.1 (9.6)

Features (ESF) Room COOLER FAILS TO RUN DUE TO Coolers RANDOM FAULTS),

1LHMOM003A---X (RHR PUMP 1A B. Two trains of the same FAN COOLER FAILS TO RUN DUE ESF Room Cooler TO RANDOM FAULTS),

subsystem inoperable 1CSMOM002A---X (CS PUMP Q1E13P001A ROOM COOLER RANDOMLY FAILS TO RUN),

1AFMOH005A-TRX (MDAFW PUMP A ROOM COOLER FTR DUE TO RANDOM FAULTS) 3.7.19 Engineered Safety 1HHMOM001C---X (PMP C FAN 9.1 (28.5)

Features (ESF) Room COOLER FAILS TO RUN DUETO Coolers RANDOM FAULTS) AND 1LHMOM003B---X (RHR PUMP 1B B. Two trains of the same FAN COOLER FAILS TO RUN DUE ESF Room Cooler TO RANDOM FAULTS) AND subsystem inoperable 1CSMOM002B---X (CS PUMP Q1E13P001B ROOM COOLER RANDOMLY FAILS TO RUN) AND 1AFMOH005B-TRX (MDAFW PUMP B ROOM COOLER FTR DUE TO RANDOM FAULTS) 3.8.1 AC Sources - 1ACTRSUT1B---F (START UP 12.8 (30.0)

Operating TRANSFORMER 1B RANDOM FAILURE)

A. One required offsite circuit inoperable E1-33 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.8.1 AC Sources - BDGGER43A501AAL (DIESEL 1/2A 30.0 (30.0)

Operating FAILS TO START ON DEMAND DUE TO RANDOM FAILURE)

B. One DG set inoperable 3.8.1 AC Sources - 1ACTRSUT1B---F (START UP 1.5 (7.0)

Operating TRANSFORMER 1B RANDOM FAILURE),AND 1ACTRSUT1A---F C. Two required offsite (START UP TRANSFORMER 1A circuits inoperable RANDOM FAILURE) 3.8.1 AC Sources - 1ACTRSUT1A---F (START UP 0.2 (1.9)

Operating TRANSFORMER 1A RANDOM FAILURE),

D. One required offsite BDGGER43A501AAL(DIESEL 1/2A circuit inoperable. FAILS TO START ON DEMAND DUE TO RANDOM FAILURE), AND AND BDGGEDIESEL1CAS (DIESEL 1C FAILS TO START ON DEMAND)

One DG set inoperable.

3.8.1 AC Sources - 1DGGER43A502BAL (DIESEL 1B 4.4 (30.0)

Operating FAILS TO START ON DEMAND DUE TO RANDOM FAILURE),

E. Two DG sets BDGGER43A501AAL(DIESEL 1/2A inoperable FAILS TO START ON DEMAND DUE TO RANDOM FAILURE), AND BDGGEDIESEL1CAS(DIESEL 1C FAILS TO START ON DEMAND) 3.8.1 AC Sources - 1ACARB1G52GX-F (SEQ B1G RELAY 19.3 (30.0)

Operating 52GX FAILS DUE TO RANDOM CAUSE) & 1ACARB1G4G---F G. One Automatic Load (RANDOM FAILURE OF SEQ B1G Sequencer inoperable RELAY 4G) & 1ACARB1GXG---F (SEQ B1G RELAY XG FAILS DUE TO RANDOM CAUSE ) &

1ACCNB1G68G13U (SEQ. B1G AUX.

RELAY 68G1 CONTACTS 3,4 SPURIOUSLY OPEN)

E1-34 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.8.1 AC Sources 1ACTRSUT1B---F ((START UP 1.5 (6.9)

TRANSFORMER 1B RANDOM H. Three or more required FAILURE), and 1ACTRSUT1A---F AC Sources inoperable ((START UP TRANSFORMER 1A (TS LOF) RANDOM FAILURE) 3.8.1 AC Sources 1ACTRSUT1A---F (START UP 0.2 (1.9)

TRANSFORMER 1A RANDOM H. Three or more required FAILURE) AND AC Sources inoperable BDGGER43A501AAL(DIESEL 1/2A (TS LOF) FAILS TO START ON DEMAND DUE TO RANDOM FAILURE), AND BDGGEDIESEL1CAS (DIESEL 1C FAILS TO START ON DEMAND) 3.8.1 AC Sources 1ACTRSUT1B---F AND 1.5 (7.4) 1ACTRSUT1A---F (START UP H. Three or more required TRANSFORMER 1A RANDOM AC Sources inoperable FAILURE)

(TS LOF) 3.8.1 AC Sources BDGGER43A501AAL(DIESEL 1/2A 0.5 (13.8)

FAILS TO START ON DEMAND DUE H. Three or more required TO RANDOM FAILURE), AND AC Sources inoperable BDGGEDIESEL1CAS (DIESEL 1C (TS LOF) FAILS TO START ON DEMAND),

1DGGER43A502BAL (DIESEL 1B FAILS TO START ON DEMAND DUE TO RANDOM FAILURE)AND BDGGER43A504BAS (DIESEL 2C FAILS TO START ON DEMAND) 3.8.1 AC Sources 1ACTRSUT1A---F (START UP 0.2 (1.9)

TRANSFORMER 1A RANDOM H. Three or more required FAILURE)AND AC Sources inoperable BDGGER43A501AAL(DIESEL 1/2A (TS LOF) FAILS TO START ON DEMAND DUE TO RANDOM FAILURE), AND BDGGEDIESEL1CAS (DIESEL 1C FAILS TO START ON DEMAND)

E1-35 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.8.4 DC Sources - 1DCBSR42B001AF (RANDOM 1.4 (1.2)

Operating FAILURE OF DC BUS 1A)

A. One Auxiliary Building DC electrical power subsystem inoperable 3.8.4 DC Sources - 1DCBYR42E002AF (AUXILIARY 30.0 (30.0)

Operating BUILDING BATTERY 1A FAILS DUE TO RANDOM FAULT)

B. One Auxiliary Building DC electrical power subsystem with battery connection resistance not within limit.

3.8.4 DC Sources - BDCBYR42B523CF (3.8.4 30.0 (30.0)

Operating SERVICE WATER BATTERY #3 FAILURE)

D. One required SWIS DC electrical power subsystem battery connection resistance not within limit.

3.8.4 DC Sources - 1DCBSR42B001AF (RANDOM 1.4 (1.2)

Operating FAILURE OF DC BUS 1A)

F. Two or more DC electrical subsystems inoperable that result in a loss of function (TS LOF) 3.8.7 Inverters - 1DCBSR42B001AF (RANDOM 1.4 (1.2)

Operating FAILURE OF DC BUS 1A)

A. One required inverter inoperable E1-36 to NL-18-0039 List of Revised Required Actions to Corresponding PRA Functions Table E1.2 Unit 1/Unit 2 TS RICT Estimate Based on CDF(LERF) Limit RICT Calculated for TS LCO/Condition Selected Equipment Description Selected Equipment in Days - CDF(LERF) 3.8.7 Inverters - 1ACIVR21E009AF(INVERTER 1A 30.0 (30.0)

Operating FAILURE),1ACIVE009B-I2F(INVERTER 1B RANDOM B. Two or more required FAILURE) inverters inoperable 3.8.9 Distribution 1ACTRSUT1A---F (START UP 0.2 (1.9)

Systems Operating TRANSFORMER 1A RANDOM FAILURE),

A. One or more AC BDGGER43A501AAL(DIESEL 1/2A electrical distribution FAILS TO START ON DEMAND DUE subsystems inoperable TO RANDOM FAILURE),

BDGGEDIESEL1CAS (DIESEL 1C FAILS TO START ON DEMAND) 3.8.9. Distribution 1ACBSL001A-I2F(VITAL AC PANEL 30.0 (30.0)

Systems Operating 1A FAILURE), AND 1ACBSL001B-I1F (VITAL AC PANEL 1B FAILURE)

B. One or more AC Vital buses inoperable 3.8.9. Distribution 1DCBSB001ADGSF (125V DC BUS 15.0 (30.0)

Systems Operating 1A RANDOMLY FAILS (DG START SUPPORT))

C. One Auxiliary Building DC electrical power distribution subsystem inoperable 3.8.9. Distribution 1ACTRSUT1A---F (START UP 0.2 (1.8)

Systems Operating TRANSFORMER 1A RANDOM FAILURE),

D. Two trains with BDGGER43A501AAL(DIESEL 1/2A inoperable distribution FAILS TO START ON DEMAND DUE subsystems that result in TO RANDOM FAILURE),

a loss of safety function BDGGEDIESEL1CAS (DIESEL 1C (TS LOF) FAILS TO START ON DEMAND)

E1-37 to NL-12-1344 List of Revised Required Actions to Corresponding PRA Functions 2.0 References

1. Letter from Jennifer M. Golder (NRC) to Biff Bradley (NEI), Final Safety Evaluation for Nuclear Energy Institute (NEI) Topical Report (TR) NEI 06-09,

'Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines,' dated May 17, 2007 (ADAMS Accession No. ML071200238).

2. Nuclear Energy Institute (NEI) Topical Report (TR) NEI 06-09, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0-A, October 2012 (ADAMS Accession No. ML12286A322).

DRA FT E1-38

ML18065A022

Text

Enclosure:

1.0 INTRODUCTION

SUMMARY

2.0 REFERENCES

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