Text

Proposed Tech Specs to Convert Units 1 & 2 Based on NUREG 1431
	ML20117C415
Person / Time
Site:	Vogtle
Issue date:	08/23/1996
From:	; GEORGIA POWER CO.
To:	;
Shared Package
ML20117C361	List: ML20117C357; ML20117C415;
References
	RTR-NUREG-1431 NUDOCS 9608270385
	Download: ML20117C415 (32)
	v • d • e

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l Enclosure 1 Marked-Up TS and liases Pages Reficeting Extended DG AOT i

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i 9608270385 960823 PDR ADOCK 05000424 P PDR

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. AC Sources - Operating 3.8.1 l 1

ACTIONS l

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

AND l A.3 Restore required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months i offsite circuit to OPERABLE status. AND 14 days from discovery of l failure to meet LCO W

B. One DG inoperable. B./ Verify SAT available. I hour AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND I Perform SR 3.8.1.1 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months B.[3 for the required offsite circuit (s). AND AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter (continued)

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\ dres Aq/h50M of Wi/hin Jsq/ys/S Netterher i. /knf j i Vogtle Units 1 and 2 A 3.8-2 Amendment No. 9# 6(Unit 1) l Amendment No. 7)' (Unit 2) l l

1 AC Sources - Op3 rating 3.8.1 1

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. (continued) B.[, Declare required 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from y feature (s) sup)orted discovery of !

by the inoperaale DG Condition B inoperable when its concurrent with required redundant inoperability of feature (s)is redundant !

inoperable. required !

feature (s)

AND ;

B./.1 Determine OPERABLE DG 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 6 is not inoperable due to common cause failure.

DE !

B./.2 Perform SR 3.8.1.2 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 3 for OPERABLE DG.

AND B.g Restore DG to 14 days from OPERABLE status, discovery of 7 failure to meet ,

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Vogtle Units 1 and 2 3.8-3 Amendment No. 9 (Unit 1)

Amendment No. (Unit 2)

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' AC Sources - Operating I 3.8.1 ACTIONS (continued)

, CONDITION REQUIRED ACTION COMPLETION TIME w- - -

fC. Required Action 5 8.1, C.1 Restore DG to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months B.2 nd associated OPERABLE status.

Completion Time not met. _

D. Two required offsite D.1 Declare required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from g,(,./ or l circuits inoperable. feature (s) inoperable discovery of

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when its redundant Condition D 6.(,.2 required feature (s) concurrent with is inoperable.

inoperability of redundant required features AND D.2 Restore one required 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months offsite circuit to OPERABLE status.

E. One required offsite --_-----_--_ NOTE-------------

circuit inoperable. Enter applicable Conditions and Required Actions of AND LC0 3.8.9, " Distribution Systems - Operating," when One DG inoperable. Condition E is entered with no AC power source to one or more trains.

E.1 Restore required 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months offsite circuit to OPERABLE status.

DE E.2 Restore DG to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months OPERABLE status.

(continued)

Vogtle Units 1 and 2 3.8-4 Amendment No. 9 (Unit 1)

Amendment No. 7 (Unit 2)

AC Sources -- Operating 3.8.1 ACTIONS (continued) _.

CONDITION REQUIRED ACTION COMPLETION TIME F. Two DGs inoperable. F.1 Restore one DG to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months OPERABLE status.

G. One automatic load G.1 Restore automatic 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months sequencer inoperable. load sequencer to OPERABLE status.

H. Required Action and H.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months

,(ssociated Completion Time of Condition A, AND C, D, E, F, or G not met. H.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months i

QB 4 6 5 3 R irdd,Act n B . /, ,

B B.T.1, B. 2, or l B and associated i l pletion Time not I met. !

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I. Three or more required I.1 Enter LC0 3.0.3. Immediately l AC sources inoperable.

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l Vogtle Units 1 and 2 3.8-5 Amendment No. 9 ' Unit 1) l Amendment No. 72f Unit 2)

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. ,. AC Sources - Operating B 3.8.1 i

BASES l

LC0 train. For the DGs, separation and independence are (continued) complete. .

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, For the offsite AC sources, separation and independence are to the extent practical. A circuit may be connected to more than one ESF bus while the bus is being transferred to the other circuit.

APPLICABILITY The AC sources and sequencers are required to be OPERABLE in MODES 1, 2, 3, and 4 to ensure that:

a. Acceptable fuel design limits and reactor coolant pressure boundary limits are not exceeded as a result of A00s or abnormal transients; and

b. Adequate core cooling is provided and containment OPERABILITY and other vital functions are maintained in the event of a postulated DBA.

The AC power requirements for MODES 5 and 6 are covered in LCO 3.8.2, "AC Sources - Shutdown."

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4C'TlOtJ.$ A Note prior to the ACTIONS table prompts the user that when the SAT is being applied in accordance with LC0 3.8.1 as an offsite circuit for an ESF bus or to meet the requirements of an LC0 3.8.1 Condition (SAT available) for an ESF bus, it is not "available" for any of the other three 4.16 kV ESF buses during that time. The SAT is available when it is:

Operable in accordance with plant procedures;

Not being applied to any of the four 4.16 kV ESF buses for Units 1 and 2 in accordance with Specification 3.8.1 as either an offsite source or to meet the requirements of an LC0 3.8.1 Condition; and,

Not providing power to the other unit when that unit l is in MODE 5 or 6 or defueled.

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l Vogtle Units 1 and 2 B 3.8-5 Revision No. 0

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.. AC Sources - Operating B 3.8.1 BASES ACTION M (CodiMesb d

To ensure a highly reliable power source remains with one offsite circuit inoperable, it is necessary to verify the OPERABILITY of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies " perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

However, if a second required circuit fails SR 3.8.1.1, the second offsite circuit is inoperable, and Condition E, for two offsite circuits inoperable, is entered.

M Required Action A.2, which only applies if the train cannot be powered from an offsite source, is intended to provide assurance that an event coincident with a single failure of the associated DG will not result in a complete loss of safety function of critical redundant required features.

These features are powered from the redundant AC electrical i power train. This includes motor driven auxiliary feedwater !

pumps. Single train systems, such as turbine driven '

auxiliary feedwater pumps, may not be included.

The Completion Time for Required Action A.2 is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also allows for' an exception to .the nomal " time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both: ,

a. The train has no offsite power supplying it loads; and

b. A required feature on the other train is inoperable.

If at any time during the existence of Condition A (one offsite circuit inoperable) a redundant required feature subsequently becomes inoperable, this Completion Time begins to be tracked.

Discovering no offsite power to one train of the onsite l Class 1E Electrical Power Distribution System coincident ]

with one or more inoperable required support or supported ;

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Vogtle Units 1 and-2 B 3.8-6 Revisio'n No. O !

k AC Sources - Operating

B 3.8.1 BASES 2

ACTIONS M (continued) initial failure to meet the LCO, to restore the offsite ci rcuit. At this time, a DG could again become inoperable, the circuit restored OPERABLE, and an additional 3 days, or l 14 days depending on SAT availability, allowed prior to

! complete restoration of the LCO. The 14 day Completion Time

provides a limit on the time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which i Conditions A and B are entered concurrently. The "A_qn"

! connector between the 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months and 14 day Completion Times

! means that both Completion Times apply simultaneously, and the more restrictive' Completion Time must be met.

l Tracking the 14 day Completion Time is a requirement for

beginning the Completion Time " clock" that is in addition to

! the normal Completion Time requirements. With respect to the 14 day Completion Time, the " time zero" is specified as commencing at the time LCO 3.8.1 was initially not met, i instead of at the time Condition A was entered. This

! results in the requirement when in this Condition to track j the time elapsed from both the Condition A " time zero" and 1

! the " time zero" when LCO 3.8.1 was initially not met.

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/ JCT /0N S,f The 13.8/4.16 kV Standby Auxiliary Transformer (SAT) is a qualified offsite circuit that may be connected to the onsite Class IE distribution system independently of the

. RATS and may be utilized to meet the LCO 3.8.1 requirements J for an offsite circuit. Its availability permits an 1

j extension of the allowable out-of-service time for a DG to 14 days from the discovery of failure to meet LC0 3.8.1.

j The SAT is available when it ist i

Operable in accordance with plant procedures; i

Not being' applied to any of the four 4.16 kV ESF buses j for Units 1 and 2 in accordance with Specification

3.8.1 as either an offsite source or to meet the requirements of an LC0 3.8.1 Condition; and, 7

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Vogtle Units 1 and 2 B 3.8-8 Revision No. 0 )

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J Insert for New Required Action H.1 l Ill Required Action B.1 addresses the concem that there may be an increased potential for weather-related events that could cause electrical system grid disturbances and/or damage to the switchyard or electrical service to the switchyard during the period of time from July 15 through November 15. If at any time while in Condition B Required Action B.1 l cannot be met, then Condition C becomes applicable, and the DG must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months from entry into Condition C. Note that while the Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months begins upon entry into Condition C, the total time to l i

l restore an inoperable DG cannot exceed 14 days (per the Completion Time of Required Action B.7). Therefore, due to the constraint of Required Action B.1, a DG will not be l voluntarily removed from service for maintenance that would require an extended i Completion Time during the period from July 15 through November 15.

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AC Sources - Operating B 3.8.1 BASES 1

ACTIONS L I (continued)

Not providing power to the other unit when that unit is in MODE 5 or 6 or defueled.

When one or more of these criteria are not satisfied, the SAT is not available. These criteria are structured to ensure that the SAT is available as an alternate offsite source to support the extended DG Completion Time of 14 days. Therefore, when a DG is inoperable, it is necessary to verify the availability of the SAT within one hour and once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter. If Required Action B. is not g _ met or the status of the SAT changes after Required ction B y is initially met, Condition C must be entered concurrently.

To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies " perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

Required Action B / is intended to provide assurance that a loss of offsite power, during the period that a DG is inoperable, does not result in a complete loss of safety function of critical systems. These features are designed with redundant safety related trains. This includes motor driven auxiliary feedwater pumps. Single train systems, such as turbine driven auxiliary feedwater pumps, are not included. Redundant required feature failures consist of inoperable features associated with a train, redundant to the train that has an inoperable DG. '

The Completion Time for Required Action B. is intended to allow the operator time to evaluate and repair any discovered inoperabilities. This Completion Time also (continued)

Vogtle Units 1 and 2 B 3.8-9 Revision No. O

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, , AC Sources - Operating B 3.8.1 j BASES 1

ACTIONS (continued) .

allows for an exception to the normal " time zero" for beginning the allowed outage time " clock." In this Required Action, the Completion Time only begins on discovery that both:

a. An inoperable DG exists; and

b. A required feature on the other train (Train A or Train B) is inoperable.

If at any time during the existence of this Condition (one DG inoperable) a required feature subsequently becomes )

inoperable, this Completion Time would begin to be tracked.

Discovering one required DG inoperable coincident with one or more inoperable required support or supported features, or both, that are associated with the OPERABLE DG, results !

in starting the Completion Time for the Required Action. i Four hours from the discovery of these events existing I concurrently is acceptable because it minimizes risk while i allowing time for restoration before subjecting the unit to transients associated with shutdown.

In this Condition, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. Thus, on a component basis, single failure protection for the required feature's function may have been lost; however, function has not been lost. The 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the OPERABILITY of the redundant counterpart to the inoperable required feature. Additionally, the 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period, b S B./.1 and B.#,2 Required Actio B. 1 provides an allowance to avoid unnecessary testing of the OPERABLE DG. If it can be l determined that the cause of the inoperable OG does not

! exist on the OPERABLE DG, SR 3.8.1.2 does not have to be performed. If the cause of inoperability exists on the (continued) l Vogtle Units 1 and 2 B 3.8-10 Revision No. O i

AC Sources - Operating B 3.8.1 BASES 6 $

ACTIONS B.t.1 and B./.2 (continued) 5 other DG, the other DG would"be decla[ red inoperable upon discovery and Condition F of LC0 3.8.g would be entered.

Once the failure is repaired, the compon cause failure no longer exists, and Required Action B.J.1 is satisfied. If the cause of the initial inoperable DG cannot be confirmed not to exist on the remaining DG, performance of SR 3.8.1.2 suffices to provide assurance of continued OPERABILITY of that DG.

5 5 In the event the inoperable DG is re tored t OPERABLE status prior to completing either B.r.1 or B. 2, the applicable plant procedures will continue to require the evaluation of the common cause possibility. This continued evaluation, however, is no longer under the 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months constraint imposed while in Condition B.

According to Generic Letter 84-15 (Ref. 7), 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months is reasonable to confirm that the OPERABLE DG is not affected by the same problem as the inoperable DG.

(IAlstA T F04 NEW'--Av REWIRED AC7/0Af1 B.17 The availability of the SAT provides an additional AC source which permits operation to continue for a period not to exceed 14 days from discovery of failure to meet the LCO.

In Condition B, the remaining OPERABLE DG and offsite circuits are adequate to supply electrical power to the onsite Class 1E Distribution System. The 14 day Completion Time takes into account the enhanced reliability and availability of offsite sources due to the SAT, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

The Completion Time for Required Action B. also establishes a limit on the maximum time allowed for any combination of required AC power sources to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an offsite circuit is inoperable, the LC0 may already have been not met for up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . If the offsite circuit is restored within the required 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , this could lead to a total of (continued)

Vogtle Units 1 and 2 B 3.8-11 Revision No. O

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l In:,crt for New Required Actions B.6.1 and B.6.2 B.6.1 and B.6.2 l

Required Action B.6.1 provides assurance that an enhanced black-start combustion

! turbine generator (CTG) is functional when a DG is out of service for greater than 72 l l hours. Required Action B.6.1 is only applicable provided that the two enhanced black- !

start CTGs have a combined reliability of 2 95 % based on a minimum of 20 tests per l l enhanced black-start CTG and quarterly testing thereafter. This quarterly testing will subject each enhanced black-start CTG to a start and load-run test. The black-start diesel ,

I generator will also be tested quarterly, but separately from the enhanced black-start l CTGs. Required Action B.6.1 may be met by starting either of the enhanced black-start i CTGs and the black-start diesel generator and verifying that it achieves steady state l

voltage and frequency. The black-start diesel generator may be started separately.

If a DG is to be removed from service voluntarily for greater than 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , it may be advantageous to test an enhanced black start CTG prior to taking the DG out of service. l In such cases where advance notice of removing a DG from service is available, Required l Action B.6.1 may be performed up to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months prior to entry into Condition B. In other cases, Required Action B.6.1 must be performed within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months after entry into I Condition B. If the reliability of the enhanced black-start CTGs has not been '

demonstrated or maintained 2 95 %, the option of starting and running any one of the six l CTGs while in Condition B is available in the form of Required Action B.6.2. In the event of preplanned maintenance that would exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , any one of the six CTGs must be started prior to entry into Condition B and allowed to run for the duration of Condition B. Otherwise, any one of the six CTGs must be started within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (and allowed to run) after entry into Condition B. If the running CTG should fail while in Condition B, any one of the remaining CTGs must be started within I hour. If one of the

six CTGs cannot be started within I hour, Condition C becomes applicable. Note that

! Required Action B.6.1 requires that one of the two enhanced black-start CTGs be started, I

but any one of the six CTGs could be started to satisfy Required Action B.6.2. Since a CTG is started and running while the DG is inoperable, it is not necessary that the CTG have enhanced black-start capability.

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ACTIONS d (continued) 17 days, since initial failure to meet the LCO, to restore compliance with the LCO (i.e., restore the DG). However, the 14 day Completion Time provides a limit on time allowed in a specified condition after discovery of failure to meet the LCO. This limit is considered reasonable for situations in which Conditions A and B (and consequently Condition E) are entered concurrently.

Tracking the 14 day Completion Time is a requirement for beginning the Completion Time " clock" that is in addition tc the normal Completion Time requirements. With respect to the Completion Time, the " time zero" is specified as commencing at the time LC0 3.8.1 was initially not met, instead of at the time Condition B was entered. This results in the requirement when in this Condition to track

, the time elapsed from both the Condition B " time zero" and the " time zero" when LCO 3.8.1 was initially not met.

W 'fsto CTc:p inref.s Msr C.1 "'"N orDN k i m B.C./ B.4.zS*fulY'Y

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'p,[f the availability of the SAT cannot be verifi d a /or !

maintained in accordance with Required Action B./, he DG yjoFgjjgI must be restored to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . The

! [a//J od 0/u/44r 72-hour Completion Time begins upon entry into Condition C.

However, the total time to restore an inoperable DG cannot l

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, exceed 14 days (per the Completion Time of Required MN N /6 /d Action B.5).

Occordonce. WiM l t The Completion Time of 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months (in the absence of the SAT) 08["/ is consistent with Regulatory Guide 1.93 (Ref. 6). The 72-hour Completion Time takes into account the capacity and bgy gr _ capability of the remaining AC sources, a reasonable time for repairs, and low probability of a DBA occurring during this period.

D.1 and D.2 Required Action D.1, which applies when two offsite circuits are inoperable, is intended to provide assurance that an event with a coincident single failure will not result in a

complete loss of redundant required safety functions. The r

(continued)

Vogtle Units 1 and 2 B 3.8-12 Revision No. 0 l

r AC Sources - Operating '

B 3.8.1 BASES l

ACTIONS f.d (continued)

According to Reference 6, with both DGs inoperable, operation may continue for a period that should not exceed l 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months .

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l L.l 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 SI 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 l OPERABILITY. This time period also ensures that the l probability of an accident (requiring sequencer OPERABILITY) occurring during periods when the sequencer is inoperable is minimal.

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l H.1 and H.2 g,gu /J, f,L g,/ & g

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If the inoperable lectric power sources or an automatic load sequencer cannot be r red to OPERABLE status within the required Completion Time, he unit must be brought to a MODE in which the LC0 does not apply. 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 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 unit conditions from full power conditions in an orderly manner and without challenging plant systems.

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l Condition I corresponds to a level of degradation in which l all redundancy in the AC electrical power supplies has been

lost. At this severely degraded level, any further losses (continued)

Vogtle Units 1 and 2 B 3.8-16 Revision No. O

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Enclosure 2 Evaluation of Risk Impact Due to Extended DG AOT 1

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EVALUA TIONOFRISKIMPACTDUE TO EXTENDED DG AOT I

The following are the calculations and quantitative PRA results due to the AOT extension 1 l

- with and without credit taken for compensatory actions (or plant improvements) nel credited in the IPE submitted to the NRC in response to GL 88-20.

l Change in average CDF (Am(CDF)):

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1 m(CDF) = average CDF (per year) i i m2(CDF) = The conditional m(CDF) with the proposed 14 day AOT in place mi(CDF) = The original m(CDF) with the current 3 day AOT in place Therefore, Am(CDF) = m2(CDF)- mi(CDF)

I Without SAT /CTGs, l m2(CDF) = 3.675E-05 y('

j mi(CDF) = 3.211E-05 y('

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Am(CDF) = 3.675E-05 y(' - 3.211E-05 y('

Am(CDF) = 4.637E-06 y('

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i With SAT /CTGs, I m2(CDF) = 2.176E-05 yf' i l

i mi(CDF) = 2.092E-05 yf' l

Am(CDF) = 2.176E-05 y(' - 2.092E-05 y('

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[ Am(CDF) = 8.416E-07 y('

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. -. . _ . . . . . . . . - . - . - . . . - . . -. - = . - . - . - . _ _ - _ . . - . - . = - -

Enclosure 2

' Evidioation ofRisk Impact Due to Extended DG ACT (continued)

Page 2 Change in instantaneous CDF (ACDF): i

! CDF,(2) = The conditional CDF when the plant is in the AOT l

CDF,(1) = The CDP when the plant is act in the AOT i = AOT configuration with one EDG unavailable Therefore, ACDF i = CDFj(2) - CDFj(1)

Without SAT /CTGs, CDF;(2) = 1.366E-04 y('

CDFi (1) = 2.217E-05 yf' ACDFi = 1.366E-04 yf' - 2.217E-05 y('

ACDF i = 1.145E-04 yf' With SAT /CTGs, CDFi (2) = 5.372E-05 yf' CDFi (1) = 1.605E-05 y('

ACDFi = 5.372E-05 yf' - 1.60aE-05 yf' ACDFi = 3.767E-05 y('

Change in conditional core damage prebability (ACCDP):

CCDP(2) = The CCDP while the plant is in the AOT CCDP(1) = The CCDP while the plant is nat in the AOT Therefore, ACCDP = CCDP(2) - CCDP(l) l l

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. Enclosure 2 l Erblimtion ofRisk Impact Due to Evtended DG A0T(continued)

Page 3 Without SAT /CTGs, ACCDPya,,n was calculated in our risk analysis (PSA-V-96-011) with the following result:

l ACCDPna,,n = 4.523E-06 ,

l r

With SAT /CTGs, l ACCDPna,,g was calculated in our risk analysis (PSA-V-96-011) with the following result:

ACCDPna;,y = 8.142E-07 Change in average large early release frequency (ALERF):

LERF(2) = LERF with proposed AOT in place LERF(l) = LERF with current AOT in place Therefore, ALERF = LERF(2) - LERF(l)

, A review of the first 500 sequences of revision 1 of the VEGP model reveals that no LOSP 1

initiating event results in a large early release. Therefore within the limits of our analyses, we can conclude that there is no increase in LERF due to a DG in maintenance.

RISK ANALYSIS CALCULATION RESULTS AND KEY ASSUMPTIONS :

l

! . The risk analysis is based on the top 180 most frequent core damage sequences from the Rev. I Vogtle IPE .

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. The SAT is able to supply any two of four 4160-V class 1-E switchgear (2/4).

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. Single unit LOSP (assume Unit 1), one DG fails (assume DG-l A): In this scenario, core l damage might occur if some of the equipment on train 1B fails. The operator could recover train l A power and cool down the unit in the following ways:

i e if the CTG switchyard were available, an operator would be able to align the SAT to

. train 1 A, or

. If the CTG switchyard were not available, one operator would be able to black-start one-of-two CTGs and another operator would be able to align the SAT to train l A or

, Enchnure 2 Evaluation ofRisk hnpact Due to Extended DG ACT(continued)

Page 4 j

to cross-tie one of three diesels (2A,2B, or 1B) and cool down Unit I using train 1 A equipment.

. Single unit LOSP (assume Unit 1), both DG-l A and 1B fail: In this scenario core damage might occur, e if offsite power is not recovered , or e if offsite power is recovered and subsequently some of the equipment fails or an operator action fails.

The operator is assumed to recover only one train of power (even though he could recover two) and cool down Unit 1 in the following ways:

. If the CTG switchyard were available, an operator would be able to align the SAT to one Unit I train, or

. If the CTG switchyard were not available, one operator wotJd be able to black-start one of two CTGs and another operator would be able to align the SAT to one Unit 1 train or to cross-tie one of two diesels from the other unit and cool down the unit using either train A or train B equipment.

. Dual unit LOSP, one DG fails on Unit 1 (assume DG-1 A): In this scenario core damage might occur if some of the equipment on train 1B fails. The operator could recover train i 1 A power and cool down the unit in the following ways:

e if the CTG switchyard were available, an operator would be able to align the SAT to l train 1 A (and align either train 2A or 2B to the SAT,if necessary);

1

. If the CTG switchyard were not available, one operator would be able to black-start l one of two CTGs and another operator would be able to align the SAT to train l A or to cross-tie one of three diesels (2A,2B, or 1B) and cool down Unit 1 using train l A equipment. These recovery actions include cool down of both units with SAT / CTG or a single diesel generator.

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. Dual unit LOSP, both DGs fail on Unit 1: In this scenario core damage might occur, l . If offsite power is not recovered , or

. If offsite power is recovered and subsequently some of the equipment fails or an operator action fails.

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. Enclosure 2 Erblication of Risk hnpact Due to Extended DG A CT(continued)

Page 5 The operator is assumed to recover only one train of power (even though he could recover two) and cool down Unit 1 in the following ways:

If the CTG switchyard were available, an operator would be able to align the SAT to train 1 A or 1B, or l

If the CTG switchyard were not available, one operator would be able to black-start one of two CTGs and another operator would be able to align the SAT to train l A or iB or to cross-tie one of two diesels from Unit 2 and cool down Unit 1 using train l A or i B equipment. These recovery actions include cool down of both units with SAT / CTG or a single diesel generator.

. in the event of a station blackout event, a source of power is assumed to be available that can be cross-tied from a single diesel generator or aligned from the SAT. The failure of four of thur diesels and SAT / CTG is considered highly unlikely. The CTG switchyard {

has historically been available about 364 days per year. The probability of failure to l black-start one of two CTGs is approximately 0.1 (or lower if an operator is stationed at the CTG site). )

e A conditional probability was calculated for the event that train A is reconnected with I power, but core damage still occurs due to failure of other train A equipment. This I conditional CDF is 0.0017.

. A conditional probability was calculated fbr the event that train B is reconnected with power, but core damage still occurs due to f ailure of other train B equipment. This conditional CDF is 0.0031.

. It is assumed for an LOSP event in which either AA02 or BA03 has power recovered, the conditional probability used is the average of the train A and B values above or 0.0024.

. Station blackout frequencies were calculated for various seismic frequency intervals using a best estimate fbr the seismic fragility ofinsulators in the switchyard and a conservative estimate Ihr the fragility of diesel generators.

. A tornado frequency was calculated based on historical data to estimate the change in risk due to high winds fbr the new design.

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. , Enclosure 2 Erialuation ofRisk Impact Due to Extended DG A 0T (continued)

Page 6

. The following IIRA factors were calculated by a TilERP analysis for use in the

calculation

[

! DESCRIPTION IIEP LOSP,1 DG in maintenance, operator aligns I bus (SAT or cross-tie 1 hr) 4.96E-02 LOSP,1 DG in maintenance, operator aligns I bus (SAT or cross-tie 4 hr) 4.73E-03 LOSP, no DG maintenance, operator aligns 1 bus (SAT or cross-tie I hr) 6.20E-02 LOSP, no DG maintenance, operator aligns i bus (SAT or cross-tie 4 hr) 7.39E-03 l

The results of the DCDP analysis are driven by the absolute values of the single and dual unit l

initiating event frequencies and by sequences where the offsite power is recovered and subsequently some of the equipment fails or an operator action fails. The impact on DCDP is insignificant when the SAT / CTG and DG cross-tic recovery factors are changed by a factor of 2. Therefore, changing the recovery factors for the fraction of LOSP events which involve l a fault in the switchyard that would disable the SAT or DG cross-tie recovery would have little impact on the DCDP.

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Enclosure 3 4 Miscellaneous Editorial Corrections l

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. QPTR 3.2.4 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) g Once per 7 days thereafter M

A.4 Reevaluate safety analyses Prior to and confim results remain increasing valid for duration of THERMAL POWER operation under this above the limit condition. of Required Action A.1 and A.2.2 AND A.5 --------NOTE---------

Perfom Required Action A.5 only after Required Action A.4 is completed.

Calibrate excore detectors Prior to

to show QPTR = 1.00. increasing THERMAL POWER above the limit of Required Action A.1 and A.2.2 AND A.6 --------NOTE---------

Perfom Required Action A.6 only after Required Action A.5 is e J

(@y p N

1 completed.

[

Perfom SR 3.2.1.1 and -----NOTE---- . f. .

one of the SR 3.2.2.1. 0nl folkowing Congletion Times,

[ff/

whichever becomes ( . i applicable first, '

must be met.

k (continued)

Vogtle Units 1 and 2 3.2-11 Amendment No. 9/(p Unit 1 AmendmentNo.7/ Unit 2

i ' -

QPTR

3.2.4 j ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

(

4 A. (continued) Within 24 houts

] after reaching RTP J

QB l Within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months j after increasing THERMAL POWER above the limit of

{ Required Action

A.1 and A.2.2 i

i j B. Required Action and B.1 Reduce THERMAL POWER to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months associated Completion s 50% RTP.

Time not met.

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! bt \ l

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, Vogtle Units 1 and 2 3.2-12 AmendmentNo.9M(Unit 1) j AmendmentNo.7g(Unit 2)

QPTR 3.2.4 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.2.4.1 -------------------NOTE--------------------

With one power range channel inoperable, the maaining thme power range channels can be used for calculating QPTR.

Verify QPTR is within limit by calculation. 7 days M

Once within

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months and every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months themafter with the QPTR alann

inoperable

, SR 3.2.4.2 -----------__------NOTE--------------------

Only required to be perfonned if one power range j channel is inoperable with THERMAL POWER

2: 75% RTP.

] Confinn that the nonnalized synnetric power Once within

distribution is consistent with QPTR. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months i S i

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter 1

\ j.

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Vogtle Units 1 and 2 3.2-13 AmendmentNo.9/ (Unit 1)

AmendmentNo.7/

Y(Unit 2)

, RTS Instrumentaticn 3.3.1 Table 3.3.1 1 (page 5 of 8)

Reactor Trip Systee Instrumentation APPLICASLE MODES OR OTHER SPECIFIED REQUIRED SURVEILLANCE ALLOWASLE TRIP FUNCTION CON 0!TIONS CHANNELS CONDITIONS REQUIREMENTS VALUE SETPOINT

.4. Turbine Trip

e. Low Fluid oil IIII 3 0 SR 3.3.1.10 t 500 pois a 580 peig Pressure SR 3.3.1.16

b. Turbine Stop 1(II 4 P SR 3.3.1.10 2 96.7% a 96.7%

velve closure SR 3.3.1.14 open open

15. Safety 1.2 2 traine o SR 3.3.1.13 NA NA Injection (SI)

Input from Engineered Safety Feature Actuation System (ESFAS)

16. Reactor Trip System Interlocks

e. Intermediate 2(d) 2 R SR 3.3.1.11 t SE.11 see t 1E.10 esp Range Neutron SR 3.3.1.12 Flux. P.8

b. Low Power 1 1 per 3 SR 3.3.1.5 NA NA Reactor Trips train Block. P.T

c. Power Range g 4 S SR 3.3.1.11 5 50.3% RTP s 48% RTP Neutron Flux, SR 3.3.1.12 P.8

d. Power Range 4 3 SR 3.3.1.11 s 52.3% RTP s 50% RTP Neutron Flun. 1 SR 3.3.1.12 3777o 710%

f

e. Power Range 4 R SR 3.3.1.11 6 RTP *s=40E RTP Neutron Flux. 1.2 SR 3.3.1.12 P 10

f. Turbine Impulse 2 3 SR 3.3.1.10 s 12.3% 5 10%

Pressure P.13 1 SR 3.3.1.12 lopulse lopulse Pressure Pressure Equivalent Equivalent turbine turbine (continued)

(d) 8elow the P 6 (Intermediate Range Neutron Flux) interlocks.

(j) Above the P.9 (Power Range Neutron Flux) interlock.

Vogtle Units 1 and 2 3.3-18 AmendmentNo.9[(Unit 1)

Amendment No. 72

$ (Unit 2) 1 j

.. _ _ _ = . .- . - . -.

, COPS 3.4.12

~

3.4 REACTORCbOLANTSYSTEM(RCS) 3.4.12 Cold Overpressure Protection Systems (COPS)

LC0 3.4.12 A COPS shall be OPERABLE with all safety injection pumps i incapable of injecting into the RCS and the accumulators isolated and either a or b below.

a. Two RCS relief valves, as follows:

1. Two power operated relief valves (PORVs) with lift settings within the limits specified in the PTLR, or

2. Two residual heat removal (RHR) suction relief valves with setpoints 2 440 psig and s 460 psig, or i l

) 3. One PORV with a lift setting within the limits .

specified in the PTLR and one RHR suction relief l valve with a setpoint within specified limits.

b. The RCS depressurized and an RCS vent of 2 2.14 square inches (baedonanequivalentlengthof10feetofpipe). l l APPLICABILITY: MODE 4, 4 MODE 5, MODE 6 when the reactor vessel head is on.

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

1. Accumulator isolation is only required when accumulator

pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR.

2. The safety injection pumps are not required to be incapable of injecting into the RCS until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after l entering MODE 4 from MODE 3 provided the temperature of l

_ _ _ _ _ . . . . . . . . . . _ _ _ , _ _ _ _ _ _ _ _ _ _ . . . . . . . . . . . . _ _ _ _ . . . . . . . . . . .l L

Vogtle Units 1 and 2 3.4-25 Amendment No. 94 Unit 1)

Amendment No. 7 Unit 2)

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, Distribution Systems - Operating 3.8.9 l 3.8 ELECTRICAi.POWERSYSTEMS

3.8.9 Distribution Systems - Operating i

l LCO 3.8.9 The required AC, DC, and AC vital bus electrical power j distri ution subsystems shall be OPERABLE. ;

} --------------------------NOTE--------------------- ------. ,

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2. The r dundant emergency buses of 4160 V switchgear % 2 ;

an A03 may be manually connected within the uni y tie '

breakers in order to allow transfer of preferred offsite i

power sources provided SR 3.8.1.1 is successfully performed 1

within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to the interconnection. The 1' interconnection shall be implemented without adversely

impacting the ability to simultaneously sequence both trains i of LOCA loads.

)

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

)

! ACTIONS l CONDITION REQUIRED ACTION COMPLETION TIME

! l

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

subsystems inoperable. OPERABLE status.

16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from .

! discovery of l l failure to meet

LC0 i

! B. One or more AC vital B.1 Restore AC vital bus 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months a bus electrical power electrical power

! distribution distribution M i subsystems inoperable. subsystems to i OPERABLE status. 16 hours1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months from discovery of failure to meet j LC0 (continued) i l 4 i Vogtle Units 1 and 2 3.8-37 Amendment No. 94 i Amendment No. 77 (Unit 1) 4

% (Unit 2)

. Distribution Systems - Shutdown 3.8.10 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued) A.2.4 Initiate actions to Immediately restore required AC, DC, and AC vital bus electrical oower distributio'n subsystems to OPERABLE status.

AND A.2.5 Declare associated Immediately required residual heat removal subsystem (s) inoperable and not in operation.

1 l

l SURVEILLANCE REQUIREMENTS l i

SURVEILLANCE FREQUENCY l l

SR 3.8.10.1 Verify correct breaker alignments and 7 days voltage to required AC, DC, and AC vital i bus electrical power distribution l subsystems.

r 'Gr l

Vogtle Units 1 and 2 3.8-40 Amendment No. 9/ (Unit 1)

Amendment No. 7 (Unit 2)

,. . Table 5.5.9-2 (page 1 of 1)

Steam Generator Tube Inspection 3RD SAMPLE IST SAMPLE INSPECTION 2ND SANPLE INSPECTION INSPECTION Sample Size Result Action Result Action Result Action Required Required Required A minimum of C-1 None NA NA NA NA

$ Tubes per SG C-2 Plug defective C-1 None NA NA tubes and inspect C-2 Plug C-1 None additional 25 defective tubes in this tubes and SG inspect C-2 Plug additional defective 45 tubes in tubes this SG C-3 Perform action for C-3 result i of first j sample

$ C-3 Perform NA NA j action for

C-3 result i

of first

{ sample

$ C-3 Inspect all All other None NA NA j tubes in this SGs are C-1

SG, plug i defective j tubes, and inspect 25 Some SGs Perform NA NA j tubes in each are C-2, action for

other SG but no C-2 result 4

additional of second 1

Notification SGs are C-3 sample i to NRC

pursuant to Additional Inspect all NA NA i e50.72 (b)(2) SG is C-3 tubes in i of 10 CFR Part each SG and j 50 plug defective tubes.

li Notification

! to NRC

, pursuant to l j

! e50.72 i

(b)(2)of10 f CFR Part 50 i

S=3N% Where N is the number of steam generators in the unit, and n is the number of steam generators 1

n l ipcted during an inspection.

f

uf J M% W l

{ wid & ~ {yP y

(#

I Vogtle Units 1 and 2 5.0-19 AmendmentNo.9/ (Unit 1)

, Amendment No. 77 (. Unit 2) i 1

Ccntrol Bank Ins;rtion Licits B 3.1.6 (Futy Withdrawn *)

(28.0%.225; #

220

/ / (78.0%,225)---

/ /

[ BANK B [

,, / /

( %,161) (100.0%,161) 160 ,

iBANK C e !/I i /

5 120 f , j 5 /l I /

2 100 f f I / /

h [ [ BANK D 60

/ / i fof UI\thfkiM ch.

20 I /l I

' I (30.2%. 0) / !

0 20 40 60 80 100 (Fully inserted)

POWER (percent of 3565 MWt)

Futy withdrawn shall be me conditon wnere convoi foos are at a posson wittun me moorval 3225 and 1231 steps withdrawn Note: The rod bank mserton kmits are based on me conwel bank withdrawal seatence A.8.C.D and a conrol bank bp-to4p distance of 115 steps

-Nj'..C 3.1.N-3 Figure B 3.1.6-1 (page 1 of 1)

Rod Bank Insertion Limits vs. Thermal Power Vogtle Units 1 and 2 B 3.1-43 Revision No. O

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Enclosure 4 Clean Typed Copy t

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ML20117C415

Text

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