Text

End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications
	ML19190A309
Person / Time
Site:	Vogtle
Issue date:	07/09/2019
From:	Gayheart C; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-19-0635
	Download: ML19190A309 (57)
	v • d • e

~ Southern Nuclear JUL 0 9 2019 Docket Nos.: 50-424 50-425 U. S. Nuclear Regulatory Commission A TIN: Document Control Desk Washington, D. C. 20555-0001 Cheryl A. Gayheart Regulatory Affairs Director Vogtle Electric Generating Plant-Units 1 and 2 3535 Colonnade Parkway Birmingham, AL 35243 205 992 53 t 6 tel 205 992 7795 fax cagayhea@southemco.com NL-19-0635 End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications Ladies and Gentlemen:

Pursuant to the provisions of Section 50.90 of Title 10 of the Code of Federal Regulations (1 0 CFR), Southern Nuclear Operating Company (SNC) hereby requests an amendment to Vogtle Electric Generating Plant (VEGP) Unit 1 renewed operating license NPF-68 and Unit 2 renewed operating license NPF-81. The proposed amendment for each unit revises the actions of Technical Specification (TS) 3.7.7, "Component Cooling Water (CCW) System,"

TS 3.7.8, "Nuclear Service Cooling Water (NSCW) System," TS 3.8.1, "AC Sources-Operating," TS 3.8.4, "DC Sources-Operating," TS 3.8.7, "Inverters-Operating," and TS 3.8.9, "Distribution Systems - Operating," and includes the results of the no significant hazards considerations analysis. The proposed license amendments modify action end states for the subject TS in conditions where more than one safety-related train is inoperable or the electrical power system is significantly degraded. Specifically, if the related required action statements are not met, then instead of requiring the plant to achieve hot shutdown (i.e.,

Mode 4), the end state of cold shutdown (i.e., Mode 5) is required.

SNC requests approval of the proposed license amendments by October 1, 2019 so that the TS requirements will reflect the limitations specified in the NRC safety evaluation associated with Westinghouse topical report WCAP-16294-NP-A, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs" (NRC Agencywide Documents Access and Management System Accession No. ML103430249). The proposed changes would be implemented as soon as practicable upon issuance of the amendments.

This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.

U.S. Nuclear Regulatory Commission NL-19-0635 Page 2 I declare under penalty of perjury that the foregoing is true and correct. Executed on the a'f!l. day of July 2019.

Respectfully submitted, C. A. G y

Director, egulatory Affairs Southern Nuclear Operating Company CAGrrLE

Enclosure:

Basis for Proposed Change Attachments: 1. VEGP Technical Specifications Marked-Up Pages

2. VEGP Technical Specifications Clean-Typed Pages

3. VEGP Technical Specifications Bases Marked-Up Pages (Information Only) cc:

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

Vogtle Electric Generating Plant-Units 1 & 2 End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications Enclosure Basis for Proposed Change

Enclosure to NL-19-0635 Basis for Proposed Change 1.0

SUMMARY

DESCRIPTION Southern Nuclear Operating Company (SNC) requests amendments to Facility Operating Licenses NPF-68 and NPF-81 for Vogtle Electric Generating Plant (VEGP)

Units 1 and 2, respectively. The proposed license amendments revise the actions of Technical Specification (TS) 3.7.7, "Component Cooling Water (CCW) System,"

TS 3.7.8, "Nuclear Service Cooling Water (NSCW) System," TS 3.8.1, "AC Sources-Operating," TS 3.8.4, "DC Sources-Operating," TS 3.8.7, "Inverters-Operating," and TS 3.8.9, "Distribution Systems-Operating." The proposed license amendments modify action end states for the subject TS in conditions where more than one safety-related train is inoperable or the electrical power system is significantly degraded.

Specifically, if the related required action statements are not met, instead of requiring the plant to achieve hot shutdown (i.e., Mode 4), the end state of cold shutdown (i.e.,

Mode 5) is required.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation CCW and NSCW Systems The CCW system provides a heat sink for the removal of process and operating heat from safety-related components during a design basis accident (DBA) or transient. The CCW system serves as a barrier to the release of radioactive byproducts between potentially radioactive systems and the NSCW and, thus, to the environment.

The principal safety-related function of the CCW system is the removal of decay heat from the reactor via the residual heat removal system. This may be during a normal or post-accident cooldown and shutdown.

The NSCW system provides a heat sink for the removal of process and operating heat from safety-related components during a DBA or transient. During normal operation and a normal shutdown, the NSCW system also provides this function for various safety-related and non-safety-related components. The principal safety-related function of the NSCW system is the removal of decay heat from the reactor via the CCW system.

AC Sources The Class 1 E AC electrical power distribution system and AC sources consist of the offsite power sources (preferred power sources, normal and alternates), and the onsite standby power sources (Train 'A' and Train 'B' diesel generators (DGs)). The AC electrical power system provides independent and redundant sources of power to the engineered safety feature (ESF) system.

The onsite Class 1 E AC distribution system is divided into redundant load groups (i.e., trains) so that the loss of any one group does not prevent the minimum safety functions from being performed. Each train has connections to two offsite power sources and a single DG.

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Enclosure to NL-19-0635 Basis for Proposed Change After a DG has started, it automatically ties to its respective bus after offsite power is tripped as a consequence of ESF bus undervoltage or degraded voltage, independent of, or coincident with, a safety injection (SI) signal. The DGs will also start and operate in the standby mode without tying to the ESF bus on an Sl signal alone.

DC Sources The station DC electrical power system provides the AC emergency power system with control power. It also provides both motive and control power to selected safety-related equipment and preferred AC vital bus power (via inverters). There are four safety features 125 VDC systems per unit.

The 125 VDC systems A and C form the Train 'A' safety features DC system, and their associated battery chargers receive power from two Class 1 E Train 'A' motor control centers. The 125 VDC systems 8 and D form the Train '8' safety features DC system, and their battery chargers receive power from two Class 1 E Train '8' motor control centers.

In the case of loss of normal power to the battery charger, the DC load is automatically powered from the station batteries.

Inverters Through use of an inverter, the station batteries can provide AC electrical power to the vital buses. The inverters provide the preferred source for the reactor protection system, engineered safety feature actuation system, the nuclear steam supply system control and instrumentation, the post-accident monitoring system, and the safety-related radiation monitoring system. The station batteries ensure that an uninterruptible power source is available for these end devices.

Electrical Distribution Systems The onsite Class 1 E AC electrical power distribution systems are divided by train into two redundant and independent AC electrical power distribution subsystems.

The DC and AC vital buses are divided into four channels of distribution, two channels of which are associated with each train. The AC electrical power subsystem for each train consists of a primary ESF 4.16 kV bus and secondary 480 and 120 V buses, distribution panels, motor control centers, and load centers.

2.2 Current Technical Specifications Requirements The current TS requirements for the CCW and NSCW systems and the electrical power and distribution systems are applicable in Modes 1, 2, 3, and 4.

In the condition when both CCW trains are inoperable or both NSCW trains are inoperable (Condition B ofTS 3.7.7 and TS 3.7.8}, the required action is to restore the trains to operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or in accordance with the risk informed completion time.

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Enclosure to N L 0635 Basis for Proposed Change In the condition when three or more required AC sources are inoperable (Condition G of TS 3.8.1 ), the required action is to restore the required AC sources to operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or in accordance with the risk informed completion time.

In the condition when two DC electrical power sources are inoperable (Condition D of TS 3.8.4), the required action is to restore at least one DC electrical power source to operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or in accordance with the risk informed completion time.

In the condition when two or more required inverters are inoperable (Condition B of TS 3.8.7), the required action is to restore the required inverters to operable status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or in accordance with the risk informed completion time.

In the condition when two or more electrical power distribution subsystems are inoperable that result in a loss of safety function (Condition D of TS 3.8.9), the required action is to restore the electrical power distribution subsystems to operable status to restore safety function within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or in accordance with the risk informed completion time.

If the required action and the associated completion times for these conditions are not met (Condition C of TS 3.7.7 and 3.7.8, Condition H of TS 3.8.1, ConditionE of TS 3.8.4, Condition C of TS 3.8.7, and ConditionE of TS 3.8.9),

the plant must be placed in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and be in Mode 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

2.3 Reason for the Proposed Change In September 2012, SNC submitted a proposed change toTS that would permit the use of risk informed completion times (RICTs) in accordance with Topical Report Nuclear Energy Institute (NEI) 06-09-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS)

Guidelines" (Refs. 1 and 2).

In May 2015, SNC submitted a proposed change toTS that would adopt Technical Specification Task Force (TSTF) traveler TSTF-432, "Change in Technical Specifications End States (WCAP-16294)" (Ref. 3) allowing a plant shutdown to hot conditions (Mode 4) instead of cold conditions (Mode 5) based on a Westinghouse analysis summarized in Topical Report, WCAP-16294-NP-A, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs" (Ref. 4).

In the TSTF-432 LAR, the proposed TS pages did not include proposed changes associated with the RICT LAR because at the time of submittal, the RICT LAR was not approved.

On May 31, 2016, the NRC approved license amendments 179 and 160 for VEGP Units 1 and 2, respectively, to implement TSTF-432 allowing a plant shutdown to hot conditions instead of cold conditions (Ref. 5).

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Enclosure to NL-19-0635 Basis for Proposed Change In 2017, SNC provided the NRC with updated TS pages for issuance of license amendments 188 and 171 for VEGP Units 1 and 2, respectively, which incorporated TS changes approved since the initial RICT LARin 2012. On August 8, 2017, the NRC approved license amendments 188 and 171 to permit the use of RICTs (Ref. 6).

The updated TS pages issued with amendments 188 and 171 incorporating the RICT TS changes resulted in unintended consequences. The RICT TS changes allowed a hot shutdown end state instead of cold shutdown end state following a loss of function condition for CCW, NSCW, and electrical distribution systems, and following a significant degradation of the electrical power systems.

2.4 Description of the Proposed Change As shown in Attachments 1 and 2 of this LAR, a new default condition and associated required actions are added in TS 3.7.7, 3.7.8, 3.8.1, 3.8.4, 3.8.7, and 3.8.9. The new default action states, as applicable:

[D]. Required Action and

[D].1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition [C]

AND not met.

[D].2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months The proposed default condition and required actions are numerated as follows for each TS:

TS 3.7.7-D TS 3.7.8-D TS 3.8.1 -I TS 3.8.4-F TS 3.8.7-D TS 3.8.9-F In addition, the current actions and loss of function actions are re-numerated and revised to accommodate the new actions as shown in Attachments 1 and 2 of this LAR.

3.0 TECHNICAL EVALUATION

The risk assessment methodology used and approved to evaluate a Mode 4 endstate in TSTF-432 and the VEGP TSTF-432 license amendment for VEGP Units 1 and 2, respectively, is summarized in topical report WCAP-16294-NP-A (Ref. 4). The NRC safety evaluations (SEs) related to WCAP-16294 and license amendments 179 and 160 for VEGP Units 1 and 2 (Refs. 5 and 7), respectively, state, in part:

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Enclosure to NL-19-0635 Basis for Proposed Change "The request is limited to inoperability of a single train of equipment or a restriction on a plant operational parameter, unless otherwise stated in the applicable technical specification, and the primary purpose is to correct the inoperable component(s) and return to power operation as soon as is practical."

Regarding the condition of more than one AC power source inoperable, the SE associated with WCAP-16294 further states, in part:

"Two trains of DGs are available if two offsite power circuits are inoperable and two offsite power circuits are available if two diesel generators are inoperable. If an offsite power circuit and/or a diesel generator are inoperable, at least one of each remains available.

... sufficient defense-in-depth is maintained when the end state is changed from Mode 5 to Mode 4 provided LCO 3.0.4.a is not applicable for entry into Mode 4."

The acceptability of changing the endstate action for AC sources did not extend to three or more required AC sources inoperable.

During the process of adopting RICTs in accordance with NEI 06-09, the VEGP TS were revised allowing the hot shutdown endstate action to apply to more than a single train of equipment.

The proposed change will restore the limitation that the hot shutdown endstate action apply to a single train of equipment and less than three required AC sources consistent with the intent stated in the NRC SEs related to WCAP-16294 and the VEGP TSTF-432 license amendments (Refs. 5 and 7).

The proposed default condition and required actions would require the plant to be placed in cold shutdown (Mode 5) within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months instead of hot shutdown (Mode 4) within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This change is considered a more restrictive change because the plant would be required to cooldown and depressurize to a condition such that the limiting condition for operation (LCO) does not apply (i.e., s 200°F). This change is considered acceptable because placing the unit in cold shutdown is considered a safe condition, since most design basis accidents and transients either cannot physically occur during cold shutdown, or would have significantly reduced plant impact and occur much less frequently due to the reduced temperatures and pressures in the plant.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements I Criteria The CCW and NSCW systems and safety-related electrical power and distribution systems satisfy 10 CFR 50.36, "Technical specifications," paragraph (c)(2)(ii), Criteria 3 and 4. The CCW and NSCW cooling functions and the safety-related electrical power and distribution systems are considered primary success paths in accident analyses. The CCW and NSCW cooling functions and electrical power and distributions systems also support the decay heat removal E-5

Enclosure to NL-19-0635 Basis for Proposed Change function, which is considered a function that operating experience has shown to be significant to public health and safety.

The proposed change does not delete these requirements and the LCOs continue to maintain requirements that are part of the primary success path and actuate to mitigate the related design basis accidents and transients and support the decay heat removal function which has been shown to be significant to public health and safety. The proposed change does not adversely alter the remedial actions or shutdown requirements required by 10 CFR 50.36(c)(2)(i); rather, the proposed amendment changes the end state requirement from hot shutdown (Mode 4) to cold shutdown (Mode 5) following a loss of function condition for CCW, NSCW, and electrical distribution systems, and following a significant degradation of the electrical power systems. The proposed TS actions are based on the expectation that this condition would result in a safe condition, since most design basis accidents and transients either cannot physically occur during cold shutdown, or would have significantly reduced plant impact and occur much less frequently due to the reduced temperatures and pressures in the plant.

The CCW and NSCW systems and safety-related electrical power and distribution systems are designed to the applicable criteria of 10 CFR Part 50, Appendix A General Design Criteria for Nuclear Power Plants, as previously licensed and approved by the NRC. The proposed change does not alter the design or operation of these systems and they continue to meet their applicable general design criteria.

4.2 No Significant Hazards Consideration Determination Analysis Pursuant to 1 0 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Vogtle Electric Generating Plant (VEGP) Unit 1 renewed operating license NPF-68 and Unit 2 renewed operating license NPF-81. The proposed change modifies action end states for cooling water and electrical power and distribution system technical specifications (TS) in conditions where more than one safety-related train is inoperable or the electrical power system is significantly degraded. Specifically, if the related required action statements are not met, instead of requiring the plant to achieve hot shutdown (i.e., Mode 4), an end state of cold shutdown (i.e., Mode 5) is required.

SNC has evaluated whether a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

(1) Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No The proposed change requires the plant to be placed in cold shutdown instead of hot shutdown when more than one safety-related train of the cooling water or electrical distribution systems are inoperable or when the electrical power system is significantly degraded (e.g., three or more required E-6

Enclosure to NL-19-0635 Basis for Proposed Change AC sources inoperable). Transitioning the plant from hot shutdown to cold shutdown is not an initiator of any accident previously evaluated but is assumed in the mitigation of accidents previously evaluated. Therefore, the probability of an accident previously evaluated is not adversely impacted by the proposed change.

Component cooling water (CCW) and nuclear service cooling water (NSCW) systems and the safety-related electrical power and distribution systems are assumed in accident mitigation. SNC concludes the proposed change to require the plant be placed in cold shutdown instead of hot shutdown is acceptable because placing the unit in cold shutdown is considered a safe condition, since most design basis accidents and transients either cannot physically occur during cold shutdown, or would have significantly reduced plant impact and occur much less frequently due to the reduced temperatures and pressures in the plant. Therefore, the consequences of any accident that assumes the cooling water systems or electrical power and distribution systems are not significantly affected by this change.

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

(2) Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not change the design function or operation of the cooling water systems or the electrical power and distribution systems.

No plant modifications or changes to the plant configuration or method of operation are involved. The proposed change will not introduce new failure modes or effects and will not, in the absence of other unrelated failures, lead to an accident whose consequences exceed the consequences of accidents previously evaluated.

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

(3) Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed change does not affect any of the controlling values of parameters used to avoid exceeding regulatory or licensing limits. The proposed change does not exceed or alter the design basis or safety limits, or any limiting safety system settings. The requirement for the CCW and NSCW systems to perform their designated support functions is unaffected. The requirement for the safety-related electrical power and distribution systems to perform their designated support functions is unaffected. The proposed change to require the plant be placed in cold shutdown instead of hot E-7

Enclosure to NL-19-0635 Basis for Proposed Change shutdown is acceptable because placing the unit in cold shutdown is considered a safe condition, since most design basis accidents and transients either cannot physically occur during cold shutdown, or would have significantly reduced plant impact and occur much less frequently due to the reduced temperatures and pressures in the plant.

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

Based on the above, SNC concludes that the proposed amendment does not involve a 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.

4.3 Conclusion In conclusion, based on the considerations 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 in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

S SNC has evaluated the proposed change for environmental considerations. The review has determined that the proposed change does not change an inspection or surveillance requirement.

The proposed change modifies action end states for cooling water systems and electrical power and distribution systems by requiring the plant to achieve cold shutdown instead of hot shutdown.

SNC has determined that this change does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment 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 amendment.

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Enclosure to N L 0635 Basis for Proposed Change

6.0 REFERENCES

1.

Letter from M.J. Ajluni (SNC) to Document Control Desk (SNC), "Vogtle Electric Generating 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,"" September 13, 2012 (NRC Agencywide Documents Access and Management System (ADAMS) Accession No. ML12258A055).

2.

Topical Report NEI 06-09-A, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0, November 2006 (NRC ADAMS Accession No. ML12286A322).

3.

Letter from C.R. Pierce (SNC) to Document Control Desk (NRC), "Vogtle Electric Generating Plant - Units 1 and 2 License Amendment Request for Adoption of TSTF-432-A, Rev. 1, "Change in Technical Specifications End States (WCAP-16294), Using the Consolidated Line Item Improvement Process,"" May 6, 2015 (NRC ADAMS Accession No. ML15128A239).

4.

Westinghouse Topical Report, WCAP-16294-NP-A, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," Revision 1, June 2010 (NRC ADAMS Accession No. ML103430249).

5.

Letter from A. E. Martin (NRC) to C.R. Pierce (SNC), "Vogtle Electric Generating Plant, Units 1 and 2-Issuance of Amendments RE: Technical Specification End States (CAC Nos. MF6197 and MF6198)," May 31, 2016 (NRC ADAMS Accession No. ML16130A577).

6.

Letter from G.E. Miller (NRC) to J.J. Hutto (SNC), "Vogtle Electric Generating Plant, Units 1 and 2 - Issuance of Amendments Regarding Implementation of Topical Report Nuclear Energy Institute NEI 06-09, "Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specification (RMTS)

Guidelines," Revision 0-A (CAC Nos. ME9555 and ME9556)," August 8, 2017 (NRC ADAMS Accession No. ML15127A669).

7.

NRC Safety Evaluation Report, "Final Safety Evaluation by the Office of Nuclear Reactor Regulation Topical ReportWCAP-16294-NP, Revision 0, "Risk-Informed Evaluation of Changes to Technical Specification Required Endstates for Westinghouse NSSS [Nuclear Steam Supply System] PWRs [Pressurized Water Reactors]," Nuclear Energy Institute Project No. 689" (NRC ADAMS Accession No. ML100770146).

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Vogtle Electric Generating Plant-Units 1 & 2 End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications VEGP Unit 1 and Unit 2 Technical Specifications Marked-Up Pages

3.7 PLANT SYSTEMS

3. 7. 7 Component Cooling Water (CCW) System LCO 3. 7. 7 Two CCW trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A

One CCW train A.1

NOTE inoperable.

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

for residual heat removal CCWSystem 3.7.7 COMPLETION TIME loops made inoperable by

---NOTES B.1

1. Not applicable when tru second CCW train intentionally made inoperable.

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

Two CCW trains inoperable.

Vogtle Units 1 and 2

ccw.

Restore CCW train to OPERABLE status.

Restore CCW trains to OPERABLE status.

3.7.7-1 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk lnforme~

Completion Time Program 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.188 (Unit 1)

Amendment No.171 (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION G.

Required Action and associated Completion Time of Condition A-arB not met.

G.1 Be in MODE 3.

~-NOTE----

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

!Jnsert 3.7.7-1 I SURVEILLANCE REQUIREMENTS SR 3.7.7.1 SR 3.7.7.2 SURVEILLANCE

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

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

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

Verify each CCW pump starts automatically on an actual or simulated actuation signal.

CCWSystem 3.7.7 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.7.7-2 Amendment No.188 (Unit 1)

Amendment No.171 (Unit 2)

Insert 3.7.7-1 D.

Required Action and D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C not AND met.

D.2 Be in MODE 5.

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

ACTIONS (continued)

CONDITION fffi*

NOTES---------

1. Not applicable when second NSCWtrain intentionally made inoperable.

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

Two NSCW trains inoperable.

G.

Required Action and lEI associated Completion Time of Condition A eF 8-not met.

~

!Insert 3.7.8-1 I Vogtle Units 1 and 2 REQUIRED ACTION

~

Restore NSCW trains to OPERABLE status.

G. 1 Be in MODE 3.

A~

G.2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

3.7.8-2 NSCW 3.7.8 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours Amendment No.188 (Unit 1)

Amendment No.111 (Unit 2)

Insert 3.7.8-1 D.

Required Action and D.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition C not AND met.

D.2 Be in MODE 5.

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

ACTIONS (continued_}

CONDITION F.

One automatic load sequencer inoperable.

G.

NOTES--------

01 Not applicable when three or more required AC sources intentionally made inoperable.

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

Three or more required AC sources inoperable.

.W.

Required Action and

§ associated Completion Time of Condition A, 8, C, D,E, ~ not met.

F ri

!Insert 3.8.1-1 I Vogtle Units 1 and 2 REQUIRED ACTION F.1 Restore automatic load sequencer to OPERABLE status.

G.1 Restore required ta inoperable AC sources to OPERABLE status.

.H.1 Be in MODE 3.

A~

H:2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

AC Sources - Operating 3.8.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Risk Informed Completion Time Program 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 3.8.1-6 Amendment No.188(Unit 1)

Amendment No.171 (Unit 2)

Insert 3.8.1-1 I.

Required Action and 1.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition H not AND met.

1.2 Be in MODE 5.

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

ACTIONS (continued)

CONDITION B.

One DC electrical power source inoperable due to inoperable battery C or D.

c.

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

/

EfJB.

~--NOTES---

1. Not applicable when second DC electrical power source intentionally made inoperable.

2. The following Section

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

h.

Two DC electrical power sources inoperable.

r-

!Insert 3.8.4-1 I Vogtle Units 1 and 2

REQUIRED ACTION B.1 Verify SAT available AND B.2 Restore DC electrical power source to OPERABLE status.

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

DC Sources-Operating 3.8.4 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program Q.1 Restore at least one DC 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months

\\m electrical power source to OPERABLE status.

3.8.4-2 OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No.188(Unit 1)

Amendment No.171 (Unit 2)

ACTIONS (continued)

CONDITION E-,

Required Action and Associated Completion Time of Condition A, B, G; or 9 not met.

§Y1 DC Sources - Operating 3.8.4 REQUIRED ACTION COMPLETION TIME E.1 Be in MODE 3.

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

~

e.2

NOTE-------

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SURVEILLANCE REQUIREMENTS SR 3.8.4.1 SURVEILLANCE Verify battery terminal voltage is greater than or equal to the minimum established float voltage.

Vogtle Units 1 and 2 3.8.4-3 FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Amendment No.188 (Unit 1)

Amendment No.171 (Unit 2)

Insert 3.8.4-1 F.

Required Action and F.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition E not AND met.

F.2 Be in MODE 5.

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

ACTIONS CONDITION REQUIRED ACTION

/

Restore required inverters ffJB

-NOTES-----

B.1

1. Not applicable when tm to OPERABLE status.

two or more inverters intentionally made inoperable.

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

h.

Two or more required inverters inoperable.

G.

Required Action and

~lnMODE3.

~

associated Completion T~notmet.

fi_

G.2

NOTE------

t of Condition A j LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

~

IJnsert 3.8.7-1 J SURVEILLANCE REQUIREMENTS SR 3.8.7.1 SURVEILLANCE Verify correct inverter voltage and alignment to required AC vital buses.

Inverters - Operating 3.8.7 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.7-2 Amendment No.188 (Unit 1)

Amendment No.171 (Unit 2)

D.

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

Insert 3.8.7-1 D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours

ACTIONS (continued)

CONDITION

c.

One or more DC electrical power distribution subsystems inoperable.

[;:

NOTES---

1. Not applicable when two or more electrical power subsystems intentionally made inoperable.

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

h.

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

E.

Required Action and mJ associated Completion Tic-not met.

f of Condition A, B, or C 3 r-t.

!Insert 3.8.9-1 I Vogtle Units 1 and 2 C.1 Distribution Systems - Operating 3.8.9 REQUIRED ACTION COMPLETION TIME Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power distribution subsystems to OR OPERABLE status.

In accordance with the Risk Informed Completion Time Program 9.1 Restore electrical power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months tm distribution subsystems to OPERABLE status to OR restore safety function.

In accordance with the Risk Informed Completion Time Program E.1 Be in MODE 3.

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

~--NOTE----

LCO 3.0.4.a is not applicable when entering MODE4. ------

Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 3.8.9-2 Amendment No.188 (Unit 1)

Amendment No.171 (Unit 2)

Insert 3.8.9-1 F.

Required Action and F.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition E not AND met.

F.2 Be in MODE 5.

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

Vogtle Electric Generating Plant-Units 1 & 2 End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications VEGP Unit 1 and Unit 2 Technical Specifications Clean-Typed Pages

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

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION A.

One CCW train A.1

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

inoperable.

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

for residual heat removal CCWSystem 3.7.7 COMPLETION TIME loops made inoperable by CCW.

Restore CCW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

OR In accordance with the Risk Informed Completion Time Program B.

Required Action and B.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

B.2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

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

Vogtle Units 1 and 2 3.7.7-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION C.

NOTES--------

C.1 Restore CCW trains to

1. Not applicable when OPERABLE status.

second CCW train intentionally made inoperable.

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

Two CCW trains inoperable.

D.

Required Action and D.1 Be in MODE 3.

associated Completion Time of Condition C not AND met.

D.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SURVEILLANCE CCWSystem 3.7.7 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY SR 3.7.7.1

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

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

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

Vogtle Units 1 and 2 3.7.7-2 In accordance with the Surveillance Frequency Control Program (continued)

Amendment No.

(Unit 1)

(Unit 2)

SR 3.7.7.2 SURVEILLANCE Verify each CCW pump starts automatically on an actual or simulated actuation signal.

Vogtle Units 1 and 2 3.7.7-3 CCWSystem 3.7.7 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION B.

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

C.

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

1. Not applicable when second NSCWtrain intentionally made inoperable.

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

Two NSCW trains inoperable.

D.

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

Vogtle Units 1 and 2 REQUIRED ACTION B.1 Be in MODE 3.

AND B.2

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

C. 1 Restore NSCW trains to OPERABLE status.

D.1 Be in MODE 3.

AND D.2 Be in MODE 5.

3.7.8-2 NSCW 3.7.8 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION F.

One automatic load F.1 sequencer inoperable.

G.

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

G.2 H.

NOTES----------

H.1

1. Not applicable when three or more required AC sources intentionally made inoperable.

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

Three or more required AC sources inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION Restore automatic load sequencer to OPERABLE status.

Be in MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

Restore required inoperable AC sources to OPERABLE status.

AC Sources - Operating 3.8.1 COMPLETION TIME 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program (contmued) 3.8.1-6 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION I.

Required Action and 1.1 Be in MODE 3.

associated Completion Time of Condition H not AND met.

1.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SR 3.8.1.1 SR 3.8.1.2 SURVEILLANCE Verify correct breaker alignment and indicated power availability for each required offsite circuit.

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

1.

Performance of SR 3.8.1.7 satisfies this SR.

2.

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

3.

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

Verify each DG starts from standby conditions and achieves steady state voltage ;;:: 4025 V and

~ 4330 V, and frequency;;:: 58.8 Hz and

~ 61.2 Hz.

AC Sources - Operating 3.8.1 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-7 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION B.

One DC electrical power B.1 source inoperable due to inoperable battery Cor D.

AND B.2

c. One DC electrical power C. 1 source inoperable for reasons other than Condition A or B.

D.

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

D.2 Vogtle Units 1 and 2 REQUIRED ACTION Verify SAT available Restore DC electrical power source to OPERABLE status.

Restore DC electrical power source to OPERABLE status.

Be in MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

DC Sources-Operating 3.8.4 COMPLETION TIME 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours (contmued) 3.8.4-2 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION DC Sources - Operating 3.8.4 COMPLETION TIME E.

NOTES----------

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

1. Not applicable when electrical power source second DC electrical to OPERABLE status.

power source intentionally made inoperable.

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

h.

Two DC electrical power sources inoperable.

F.

Required Action and F.1 Be in MODE 3.

associated Completion Time of Condition E not AND met.

F.2 Be in MODE 5.

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

Vogtle Units 1 and 2 3.8.4-3 OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY In accordance with the Surveillance Frequency Control Program (continued)

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS CONDITION B.

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

B.2 C.

NOTES-------

C.1

1. Not applicable when two or more inverters intentionally made inoperable.

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

h.

Two or more required inverters inoperable.

D.

Required Action and D.1 associated Completion Time of Condition C not AND met.

D.2 Vogtle Units 1 and 2 REQUIRED ACTION Be in MODE 3.

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE 4.

Restore required inverters to OPERABLE status.

Be in MODE 3.

Be in MODE 5.

Inverters-Operating 3.8.7 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours 3.8.7-2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

SURVEILLANCE REQUIREMENTS SR 3.8.7.1 SURVEILLANCE Verify correct inverter voltage and alignment to required AC vital buses.

Vogtle Units 1 and 2 3.8.7-3 Inverters-Operating 3.8.7 FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

ACTIONS (continued)

CONDITION C.

One or more DC

c. 1 electrical power distribution subsystems inoperable.

D.

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

D.2 E.

NOTES-------

E.1

1. Not applicable when two or more electrical power subsystems intentionally made inoperable.

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

h.

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

Vogtle Units 1 and 2 Distribution Systems - Operating 3.8.9 REQUIRED ACTION COMPLETION TIME Restore DC electrical 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months power distribution subsystems to OR OPERABLE status.

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

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

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

LCO 3.0.4.a is not applicable when entering MODE4.

Be in MODE4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Restore electrical power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months distribution subsystems to OPERABLE status to OR restore safety function.

In accordance with the Risk Informed Completion Time Program (contrnued) 3.8.9-2 Amendment No.

Amendment No.

(Unit 1)

(Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION F.

Required Action and F.1 Be in MODE 3.

associated Completion Time of Condition E not AND met.

F.2 Be in MODE 5.

SURVEILLANCE REQUIREMENTS SURVEILLANCE Distribution Systems - Operating 3.8.9 COMPLETION TIME 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.9-3 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

Vogtle Electric Generating Plant-Units 1 & 2 End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications VEGP Unit 1 and Unit 2 Technical Specifications Bases Marked-Up Pages (Information Only)

Bases Insert 1 D.1 and D.2 If the Required Actions of Condition C cannot be completed within the required Completion Times, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Bases Insert 2 1.1 and 1.2 If the Required Action of Condition H cannot be completed within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

Bases Insert 3 F.1 and F.2 If the Required Actions of Condition E cannot be completed within the required Completion Times, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

BASES

<Note: Rearrange Bases text based on relabel of Conditions.>

CCW System B 3.7.7 ACTIONS

~ 8.1 (continued)

With both trains of CCW inoperable, the heat load capacity of the CCW system is seriously degraded such that the system may be incapable of providing an adequate heat sink for normal and accident conditions. Consequently, one hour is provided to restore the CCW trains to OPERABLE status. Alternatively, a Completion Time can be determined under the Risk Informed Completion Time Program.

The CONDITION is modified by two Notes. The first Note states it is not applicable when the second CCW train is intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from service. The Required Action is intended only when the second CCW train is found inoperable with one CCW train already inoperable, or if two CCW trains are found inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Ref. 6).

&G.1and~

If the CCW train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 5). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth.

As stated in Reference 5, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal.

Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

0 Required Actio~.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if (continued)

Vogtle Units 1 and 2 B 3.7.7-4 REVISION 48

BASES

<Note: Rearrange Bases text based on relabel of Conditions.>

CCW System B 3.7.7 ACTIONS G.1 and G.2 (continued)

~

Bases Insert 1 SURVEILLANCE REQUIREMENTS Vogtle Units 1 and 2 appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SR 3.7.7.1 This SR is modified by a Note indicating that the isolation of the CCW flow to individual components may render those components inoperable but does not affect the OPERABILITY of the CCW System.

Verifying the correct alignment for manual, power operated, and automatic valves in the CCW flow path provides assurance that the proper flow paths exist for CCW operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these valves are verified to be in the correct position prior to locking, sealing, or securing. This SR also does not apply to valves that cannot be inadvertently misaligned, such as check valves. This Surveillance does not require any testing or valve manipulation; rather, it involves verification that those valves capable of being mispositioned are in the correct position.

The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.7.7.2 This SR verifies proper automatic operation of the CCW pumps on an actual or simulated actuation signal. The CCW System is a normally operating system that cannot be fully actuated as part of routine testing during normal operation. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

(continued)

B 3.7.7-5 REVISION 48

BASES (continued)

ACTIONS Vogtle Units 1 and 2

<Note: Rearrange Bases text based on relabel of Conditions.>

NSCW B 3.7.8 If one NSCW System train is inoperable, action must be taken to restore the train to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, the remaining OPERABLE NSCW System train is adequate to perform the heat removal function. However, the overall reliability is reduced because a single failure in the OPERABLE NSCW System train could result in loss of NSCW System function. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program. Required Action A.1 is modified by two Notes.

The first Note indicates that the applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources-Operating," should be entered if an inoperable NSCW System train results in an inoperable emergency diesel generator. The second Note indicates that the applicable Conditions and Required Actions of LCO 3.4.6, "RCS Loops-MODE 4," should be entered if an inoperable NSCW System train results in an inoperable decay heat removal train. This is an exception to LCO 3.0.6 and ensures the proper actions are taken for these components. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is based on the redundant capabilities afforded by the OPERABLE train, and the low probability of a DBA occurring during this time period.

With both trains of NSCW inoperable, the NSCW system may be incapable of providing an adequate heat sink for safety related components during design basis accident and transients.

Consequently, one hour is provided to restore the NSCW trains to OPERABLE status. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

The CONDITION is modified by two Notes. The first Note states it is not applicable when the second NSCW train is intentionally made inoperable. This Required Action is not intended for voluntary removal of redundant systems or components from service. The Required Action is intended only when the second NSCW train is found inoperable with one train already inoperable, or if two NSCW trains are found inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (Ref. 5).

(continued)

B 3.7.8-3 REVISION48

BASES ACTIONS (continued)

<Note: Rearrange Bases text based on relabel of Conditions.>

NSCW B 3.7.8 If the NSCW System train cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which overall plant risk is reduced. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal. Voluntary entry into MODE 5 may be made

~table from a risk perspective.

B Required Action G.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Bases Insert 1 SURVEILLANCE REQUIREMENTS Vogtle Units 1 and 2 The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging unit systems.

SR 3.7.8.1 This SR is modified by a Note indicating that the isolation of the NSCW System components or systems may render those components inoperable, but does not necessarily affect the OPERABILITY of the NSCW System.

(continued)

B 3.7.8-4 REVISION 48

BASES ACTIONS Vogtle Units 1 and 2

<Note: Rearrange Bases text based on relabel of Conditions.>

AC Sources-Operating B 3.8.1 E.1 (continued)

The CONDITION is modified by two Notes. The first Note states that it is not applicable when the second DG 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 DG is inoperable for any reason and the second DG is found to be inoperable, or if both DGs are found inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

E.1 The sequencer(s) is an essential support system to both the offsite circuit and the DG associated with a given ESF bus. Furthermore, the sequencer is on the primary success path for most major AC electrically powered safety systems powered from the associated ESF bus. The sequencers are required to provide the system response to both an Sl signal and a loss of or degraded ESF bus voltage signal. Therefore, loss of an ESF bus sequencer affects every major ESF system in the train. The 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Completion Time provides a period of time to correct the problem commensurate with the importance of maintaining sequencer OPERABILITY. This time period also ensures that the probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program (Ref. 15).

With three or more required AC sources inoperable the Required Action is to restore enough of the required inoperable AC sources to OPERABLE status within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to regain some level of redundancy in the AC electrical power supplies. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time is acceptable because it minimizes risk while allowing time for restoration of sufficient AC electrical power supplies. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program.

(continued)

B 3.8.1-13 REVISION 48

<Note: Rearrange Bases text based on relabel of Conditions.>

AC Sources-Operating B 3.8.1 BASES ACTIONS

~.1 (continued) of Condition The CONDITION is modified by two Notes. The first Note states it is not applicable when three or more required AC sources are 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 two required AC sources are inoperable for any reason and a third becomes inoperable, or if three AC sources are found to be inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO If the iRoperable I',G eleotrio power sou roes or a A automatie load sequeRoer oaRAot be restored to OPERABLE status witt:liA the required GoFApletioA Time, or Required Actions A, B, C, D, E, F;-or cannot be met within the re uired Com lotio imes, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 14). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth. As stated in Reference 14, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal.

Voluntary entry into MODE 5 may be made as it is also acceptable

[§]

from a risk perspective.

Required Action ~.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the (continued)

Vogtle Units 1 and 2 B 3.8.1-14 REVISION 48

<Note: Rearrange Bases text based on relabel of Conditions.>

AC Sources-Operating B 3.8.1 BASES

~

ACTIONS H.1 and H.2 (continued)

Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without

~

_ challenging plant systems.

~

SURVEILLANCE REQUIREMENTS Vogtle Units 1 and 2 The AC sources are designed to permit inspection and testing of all important areas and features, especially those that have a standby function, in accordance with 10 CFR 50, Appendix A, GDC 18 (Ref. 8). Periodic component tests are supplemented by extensive functional tests during refueling outages (under simulated accident conditions). The SRs for demonstrating the OPERABILITY of the DGs are in accordance with the recommendations of Regulatory Guide 1.9 (Ref. 3), Regulatory Guide 1.108 (Ref. 9), and Regulatory Guide 1.137 (Ref. 1 0), as addressed in the FSAR.

Where the SRs discussed herein specify voltage and frequency tolerances, the following is applicable. The minimum steady state output voltage of 3750 V is 90% of the nominal 4160 V output voltage.

This value, which is specified in ANSI C84.1 (Ref. 11 ), allows for voltage drop to the terminals of 4000 V motors whose minimum operating voltage is specified as 90% or 3600 V. It also allows for voltage drops to motors and other equipment down through the 120 V level where minimum operating voltage is also usually specified as 90% of name plate rating. The specified maximum steady state output voltage of 4330 V will limit the 480 V bus voltage to within the maximum operating voltage specified for 460 V motors. It ensures that for a lightly loaded distribution system, the voltage at the terminals of 460 V motors is no more than the maximum rated operating voltages. The specified minimum and maximum frequencies of the DG are 58.8 Hz and 61.2 Hz, respectively. These values are equal to +/- 2% of the 60 Hz nominal frequency and are derived from the recommendations given in Regulatory Guide 1.9 (Ref. 3).

SR 3.8.1.1 This SR ensures proper circuit continuity for the offsite AC electrical power supply to the onsite distribution network and availability of offsite AC electrical power. The breaker alignment verifies that each (continued)

B 3.8.1-15 REVISION 48

BASES ACTIONS Vogtle Units 1 and 2

<Note: Rearrange Bases text based on relabel of Conditions.>

DC Sources-Operating B 3.8.4 B.1 and B.2 (continued) maintenance, but it is only to provide for more orderly corrective maintenance for a battery.

Condition C represents one train with a loss of ability to completely respond to an event, and/or a potential loss of ability to remain energized during normal operation. The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is consistent with the allowed time for an inoperable DC distribution system train.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program (Ref. 1 0).

If one of the required DC electrical power sources is inoperable for reasons other than Condition A orB (e.g., inoperable battery charger or inoperable battery charger and associated inoperable battery), the remaining DC electrical power sources have the capacity to support a safe shutdown and to mitigate an accident condition. Since a subsequent worst case single failure could, however, result in the loss of the minimum necessary DC electrical sources to mitigate a worst case accident, continued power operation should not exceed 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time is based on Regulatory Guide 1.93 (Ref. 8) and reflects a reasonable time to assess unit status as a function of the inoperable DC electrical power source and, if the DC electrical power source is not restored to OPERABLE status, to prepare to effect an orderly and safe unit shutdown.

~

With two DC electrical power sources inoperable, the Required Action is to restore at least one of the required inoperable DC electrical power sources to OPERABLE status within one hour to regain control power for the AC emergency power system. The one hour Completion Time is acceptable because it minimizes risk while allowing time for restoration of at least one DC electrical power source. Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program (Ref 10).

(continued)

B 3.8.4-7 REVISION 48

BASES ACTIONS Required Actions of Condition A, B, or C cannot be met Vogtle Units 1 and 2

<Note: Rearrange Bases text based on relabel of Conditions.>

DC Sources-Operating B 3.8.4 9.1 (continued)

The Condition is modified by two Notes. The first Note states it is not applicable when the second DC electrical power source 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 DC electrical power source is inoperable for any reason and a second DC electrical power source is found to be inoperable, or if two DC electrical power sources are found to be inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than~

K.ndt.2 ~

~

If the

e a G elestrioal povver so~:.~rse sannot be to

=~~~~within the required Completion Time~t must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 9). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth.

As stated in Reference 9, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal.

Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

Required Action ~-2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk (continued)

B 3.8.4-8 REVISION 48

BASES ACTIONS Bases Insert 3 SURVEILLANCE REQUIREMENTS Vogtle Units 1 and 2

<Note: Rearrange Bases text based on relabel of Conditions.>

DC Sources-Operating B 3.8.4 F i' 0~----------

E.1 and E.2 (continued) assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SR 3.8.4.1 Verifying battery terminal voltage while on float charge for the batteries helps to ensure the effectiveness of the battery chargers, which support the ability of the batteries to perform their intended function. Float charge is the condition in which the charger is supplying the continuous charge required to overcome the internal losses of a battery and maintain the battery in a fully charged state while supplying the continuous steady state loads of the associated DC subsystem. On float charge, battery cells will receive adequate current to optimally charge the battery. The voltage requirements are based on the nominal design voltage of the battery and are consistent with the minimum float voltage established by the battery manufacturer (2.20 Vpc times the number of connected cells for the battery terminal voltage). This voltage maintains the battery plates in a condition that supports maintaining the grid life (expected to be approximately 20 years). The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

SR 3.8.4.2 This SR verifies the design capacity of the battery chargers (Ref. 4).

According to Regulatory Guide 1.32 (Ref. 5}, the battery charger supply is recommended to be based on the largest combined demands of the various steady state loads and the charging capacity to restore the battery from the design minimum charge state to the fully charged state, irrespective of the status of the unit during these (continued)

B 3.8.4-9 REVISION 48

<Note: Rearrange Bases text based on relabel of Conditions.>

Inverters-Operating B 3.8.7 BASES ACTIONS

~ 8.1 (continued)

With two or more inverters inoperable the Required Action is to restore at least one of the required inverters to OPERABLE status within one hour to regain AC electrical power to the vital buses. The one hour Completion Time is acceptable because it minimizes risk while allowing time for restoration of at least one required inverter.

Alternately, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program (Ref. 5).

The Condition is modified by two Notes. The first Note states it is not applicable when two or more required inverters are 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 required inverter is inoperable for any reason and a second required inverter is found to be inoperable, or if two required inverters are found to be inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

~G2 Required Action of Condition A cannot be met Vogtle Units 1 and 2 If the inoperable devioes or oofflponents san not be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth.

As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal.

Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

(continued)

B 3.8.7-5 REVISION 48

BASES ACTIONS Bases Insert 1 SURVEILLANCE REQUIREMENTS REFERENCES Vogtle Units 1 and 2

<Note: Rearrange Bases text based on relabel of Conditions.>

Inverters-Operating B 3.8.7

~

G.1 and G.2 Required Action

. is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

SR 3.8.7.1 This Surveillance verifies that the inverters are functioning properly with all required circuit breakers closed and AC vital buses energized from the inverter. The verification of proper voltage output ensures that the required power is readily available for the instrumentation of the RPS and ESFAS connected to the AC vital buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

FSAR, Chapter 8.

2.

FSAR, Chapter 6.

3.

FSAR, Chapter 15.

4.

WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

5.

Vogtle Electric Generating Plant, Units 1 and 2 - Issuance of Amendments Regarding Implementation of Topical Report Nuclear Energy Institute NEI 06-09, "Risk-Informed Technical Specifications Initiative 4B, Risk-Managed Technical Specifications (RMTS) Guidelines," Revision 0-A (CAC Nos.

ME9555 and ME9556).

B 3.8.7-6 REVISION 48

BASES ACTIONS Distribution Systems-Operating

<Note: Rearrange Bases text based on B 3.8.9 relabel of Conditions.>

C.1 (continued) the minimum required ESF functions not being supported. Therefore, the required DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

Alternatively, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program (Ref 5).

Condition C represents one or more DC subsystems without adequate DC power; potentially both with the battery significantly degraded and the associated charger nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all DC power.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that would be without power.

Taking exception to LCO 3.0.2 for components without adequate DC power, which would have Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months , is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (i.e., requiring a shutdown) while allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous applicable Conditions and Required Actions for components without DC power and not providing sufficient time for the operators to perform the necessary evaluations and actions for restoring power to the affected train; and

c.

The potential for an event in conjunction with a single failure of a redundant component.

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time for DC buses is consistent with 0-\\~gulatory Guide 1.93 (Ref. 3).

With two or more electrical power distribution subsystems inoperable that result in a loss of safety function, the Required Action is to restore sufficient electrical power distribution subsystems within one hour to restore safety function. The one hour Completion Time is acceptable because it minimizes risk while allowing time for restoration of sufficient electrical power distribution subsystems. Alternately, a Completion Time can be determined in accordance with the Risk Informed Completion Time Program (Ref 5).

(continued)

Vogtle Units 1 and 2 B 3.8.9-7 REVISION 48

BASES ACTIONS Distribution Systems-Operating

<Note: Rearrange Bases text based on 8 3*8*9 relabel of Conditions.>

"\\.1 (continued)

The CONDITION is modified by two Notes. The first Note states it is not applicable when two or more electrical distribution subsystems are 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 electrical power distribution subsystem is inoperable for any reason and a second electrical power distribution subsystem is found to be inoperable, or if two electrical power distribution subsystems are found to be inoperable at the same time. The second Note indicates the parts of Section 5.5.22, "Risk Informed Completion Time Program", which are applicable to this LCO Condition. The Risk Informed Completion Time for this LCO Condition can be no longer than 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

,..,....,,...........,..........,'"""""'....._..... ~

0

.1 an

.2 Required Actions of Condition A, B, or C cannot be met Vogtle Units 1 and 2 L..:~*"~=~~~;la1~within the required Completion Tim, the unit must be brought to a MODE in which overall plant risk is reduced. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Remaining within the Applicability of the LCO is acceptable to accomplish short duration repairs to restore inoperable equipment because the plant risk in MODE 4 is similar to or lower than MODE 5 (Ref. 4). In MODE 4 the Steam Generators and Residual Heat Removal System are available to remove decay heat, which provides diversity and defense in depth.

As stated in Reference 4, the steam turbine driven Auxiliary Feedwater Pump must be available to remain in MODE 4. Should Steam Generator cooling be lost while relying on this Required Action, there are preplanned actions to ensure long-term decay heat removal.

Voluntary entry into MODE 5 may be made as it is also acceptable from a risk perspective.

(continued)

B 3.8.9-8 REVISION 48

Distribution Systems-Operating

<Note: Rearrange Bases text based on B 3.8.9 BASES relabel of Conditions.>

rn~~

~

ACTIONS E.1 and E2 (continued)

D Required Action

.2 is modified by a Note that states that LCO 3.0.4.a is not applicable when entering MODE 4. This Note prohibits the use of LCO 3.0.4.a to enter MODE 4 during startup with the LCO not met.

However, there is no restriction on the use of LCO 3.0.4.b, if applicable, because LCO 3.0.4.b requires performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering MODE 4, and establishment of risk management actions, if appropriate. LCO 3.0.4 is not applicable to, and the Note does not preclude, changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit. The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

jBases Insert 3 h SURVEILLANCE REQUIREMENTS REFERENCES Vogtle Units 1 and 2 SR 3.8.9.1 This Surveillance verifies that the required AC, DC, and AC vital bus electrical power distribution systems are functioning properly, with correct circuit breaker alignment. The correct breaker alignment ensures the appropriate separation and independence of the electrical divisions is maintained, and the appropriate voltage is available to each required bus. The verification of proper voltage availability on the buses ensures that the required voltage is readily available for motive as well as control functions for critical system loads connected to these buses. The Surveillance Frequency is controlled under the Surveillance Frequency Control Program.

1.

FSAR, Chapter 6.

2.

FSAR, Chapter 15.

3.

Regulatory Guide 1.93, December 1974.

4.

WCAP-16294-NP-A, Rev. 1, "Risk-Informed Evaluation of Changes to Technical Specification Required Action Endstates for Westinghouse NSSS PWRs," June 2010.

(continued)

B 3.8.9-9 REVISION 48

v t e Letter Sequence Request
EPID:L-2019-LLA-0148, TSTF-432 (Approved, Closed)
Initiation Request, Request, Request, Request Acceptance Administration Meeting Questions 19 September 2019 Answers 17 October 2019 Results Approval Other:
MONTHYEAR2019-08-02 [Table View]

NL-19-0635, End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications

Text

Enclosure:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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NL-19-0635, End State Revision from Hot Shutdown to Cold Shutdown for Several Technical Specifications

Text

Enclosure:

SUMMARY

3.0 TECHNICAL EVALUATION

4.0 REGULATORY EVALUATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 REFERENCES

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