Text

Issuance of Amendment Nos. 358 and 352 Regarding Technical Specifications Task Force Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4B
	ML22210A118
Person / Time
Site:	Sequoyah
Issue date:	08/24/2022
From:	David Wrona; Plant Licensing Branch II
To:	Jim Barstow; Tennessee Valley Authority
	Buckberg P
References
	EPID L-2021-LLA-0145
	Download: ML22210A118 (156)
	v • d • e

August 24, 2022 Mr. James Barstow Vice President, Nuclear Regulatory Affairs and Support Services Tennessee Valley Authority 1101 Market Street, LP 4A-C Chattanooga, TN 37402-2801

SUBJECT:

SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 358 AND 352 REGARDING TECHNICAL SPECIFICATIONS TASK FORCE TRAVELER TSTF-505, REVISION 2, PROVIDE RISK-INFORMED EXTENDED COMPLETION TIMES - RITSTF INITIATIVE 4B (EPID L-2021-LLA-0145)

Dear Mr. Barstow:

The U.S. Nuclear Regulatory Commission (Commission) has issued the enclosed Amendment No. 358 to Renewed Facility Operating License No. DPR-77, and Amendment No. 352 to Renewed Facility Operating License No. DPR-79, for the Sequoyah Nuclear Plant, Units 1 and 2, respectively. These amendments are in response to your application dated August 5, 2021, as supplemented by letters dates April 28, 2022, May 13, 2022, and July 1, 2022.

The amendment modifies technical specifications to permit the use of risk-informed completion times in accordance with Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision 2, "Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b,"

(ADAMS Accession No. ML18183A493). A copy of our related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

Perry H. Buckberg, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-327 and 50-328

Enclosures:

1. Amendment No. 358 to DPR-77

2. Amendment No. 352 to DPR-79

3. Safety Evaluation cc: Listserv

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-327 SEQUOYAH NUCLEAR PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 358 Renewed License No. DPR-77

1. The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated August 5, 2021, as supplemented by letters dates April 28, 2022, May 13, 2022, and July 1, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations set forth in Title 10 of the Code of Federal Regulations (10 CFR)

Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-77 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 358 are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: August 24, 2022 David J.

Wrona Digitally signed by David J. Wrona Date: 2022.08.24 15:12:16 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 358 SEQUOYAH NUCLEAR PLANT, UNIT 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-77 DOCKET NO. 50-327 Replace page 3 of the Renewed Facility Operating License with the attached page 3.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 1.3-10 3.3.1-1 3.3.1-2 3.3.1-3 3.3.1-5 3.3.1-6 3.3.1-7 3.3.1-8 3.3.1-9 3.3.1-10 3.3.1-11 3.3.1-12 3.3.1-13 3.3.1-17 3.3.1-18 3.3.1-19 3.3.2-1 3.3.2-2 3.3.2-3 3.3.2-4 3.3.2-5 3.3.2-6 3.3.2-7 3.3.2-8 3.3.2-9 3.3.2-10 3.3.2-17 3.3.2-18 3.3.2-19 3.3.5-1 1.3-10 1.3-11 3.3.1-1 3.3.1-2 3.3.1-3 3.3.1-5 3.3.1-6 3.3.1-7 3.3.1-8 3.3.1-9 3.3.1-10 3.3.1-11 3.3.1-12 3.3.1-13 3.3.1-17 3.3.1-18 3.3.1-19 3.3.2-1 3.3.2-2 3.3.2-3 3.3.2-4 3.3.2-5 3.3.2-6 3.3.2-7 3.3.2-8 3.3.2-9 3.3.2-10 3.3.2-17 3.3.2-18 3.3.2-19 3.3.5-1 3.4.11-1 3.4.11-2 3.5.2-1 3.6.2-3 3.6.3-2 3.6.3-3 3.6.6-1 3.6.8-1 3.6.11-1 3.6.11-2 3.7.2-1 3.7.5-1 3.7.5-2 3.7.5-3 3.7.5-4 3.7.7-1 3.7.8-2 3.8.1-2 3.8.1-3 3.8.1-4 3.8.1-5 3.8.1-6 3.8.4-1 3.8.4-2 3.8.7-1 3.8.7-2 3.8.9-1 3.8.9-2 3.8.9-3 5.5-17 3.4.11-1 3.4.11-2 3.5.2-1 3.6.2-3 3.6.3-2 3.6.3-3 3.6.6-1 3.6.8-1 3.6.11-1 3.6.11-2 3.7.2-1 3.7.5-1 3.7.5-2 3.7.5-3 3.7.5-4 3.7.7-1 3.7.8-2 3.8.1-2 3.8.1-3 3.8.1-4 3.8.1-5 3.8.1-6 3.8.4-1 3.8.4-2 3.8.7-1 3.8.7-2 3.8.9-1 3.8.9-2 3.8.9-3 5.5-17 5.5-18 Amendment No. 358 Renewed License No. DPR-77 (3)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the Sequoyah and Watts Bar Unit 1 Nuclear Plants.

C.

This renewed license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The Tennessee Valley Authority is authorized to operate the facility at reactor core power levels not in excess of 3455 megawatts thermal.

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 358 are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3)

Initial Test Program The Tennessee Valley Authority shall conduct the post-fuel-loading initial test program (set forth in Section 14 of Tennessee Valley Authoritys Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a.

Elimination of any test identified in Section 14 of TVAs Final Safety Analysis Report as amended as being essential;

b.

Modification of test objectives, methods, or acceptance criteria for any test identified in Section 14 of TVAs Final Safety Analysis Report as amended as being essential;

Completion Times 1.3 SEQUOYAH - UNIT 1 1.3-10 Amendment 334, 358 1.3 Completion Times EXAMPLES (continued)

Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter" interval begins upon performance of Required Action A.1.

If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or any subsequent 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval from the previous performance (plus the extension allowed by SR 3.0.2), Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.

EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.

A.1 Restore subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.

Completion Times 1.3 SEQUOYAH - UNIT 1 1.3-11 Amendment 358 1.3 Completion Times EXAMPLES (continued)

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

If the 7 day Completion Time clock of Condition A has expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start.

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

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-1 Amendment 334, 358 3.3 INSTRUMENTATION 3.3.1 Reactor Trip System (RTS) Instrumentation LCO 3.3.1 The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.1-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one or more required channels or trains inoperable.

A.1 Enter the Condition referenced in Table 3.3.1-1 for the channel(s) or train(s).

Immediately B. One Manual Reactor Trip channel inoperable.

B.1 Restore channel to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program C. One channel or train inoperable.

C.1 Restore channel or train to OPERABLE status.

UOR C.2.1 Initiate action to fully insert all rods.

UAND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 48 hours

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-2 Amendment 334 343, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2.2 Place the Rod Control System in a condition incapable of rod withdrawal.

49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months D. One Power Range Neutron Flux - High channel inoperable.

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

1.

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing and setpoint adjustment of other channels.

2.

Perform SR 3.2.4.2 if input to QPTR from one or more Power Range Neutron Flux channels are inoperable with THERMAL POWER > 75% RTP.

D.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-3 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

E.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program F.

One Intermediate Range Neutron Flux channel inoperable.

F.1 Reduce THERMAL POWER to < P-6.

UOR F.2 Increase THERMAL POWER to > P-10.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours G. Two Intermediate Range Neutron Flux channels inoperable.

G.1

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

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

Suspend operations involving positive reactivity additions.

UAND G.2 Reduce THERMAL POWER to < P-6.

Immediately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-5 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K. One channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

K.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program L.

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

L.1 Reduce THERMAL POWER to < P-7.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months M. One Turbine Trip channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

M.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program N. Required Action and associated Completion Time of Condition M not met.

N.1 Reduce THERMAL POWER to < P-9.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-6 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME O. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

O.1 Restore train to OPERABLE status.

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 P. One reactor trip breaker train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing, provided the other train is OPERABLE.

P.1 Restore train to OPERABLE status.

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 Q. One or more channels inoperable.

Q.1 Verify interlock is in required state for existing unit conditions.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months R. One or more channels inoperable.

R.1 Verify interlock is in required state for existing unit conditions.

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-7 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME S. Required Action and associated Completion Time of Condition R not met.

S.1 Be in MODE 2.

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

One trip mechanism inoperable for one reactor trip breaker.

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

The reactor trip breaker train shall not be bypassed while one of the diverse trip features is inoperable except for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for performing maintenance to restore the breaker to OPERABLE status T.1 Restore trip mechanism to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program U. One channel inoperable.

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

The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

U.1 For the affected protection set, adjust the Trip Time Delay for one affected steam generator (TRS R) to match the Trip Time Delay for multiple affected steam generators (TRM R).

UAND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-8 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME U.2 Place channel in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program V.

One channel inoperable.

V.1 For the affected protection set, adjust the Steam Generator Water Level -

Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Water Level - Low-Low (Adverse).

UOR V.2 For the affected protection set, place the Steam Generator Water level--Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 6 hours OR In accordance with the Risk Informed Completion Time Program W. One channel inoperable.

W.1 For the affected protection set, adjust the Trip Time Delays (TRS R and TRM R) threshold power level for zero seconds time delay to 0% RTP.

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME W.2 For the affected protection set, place the Steam Generator Water Level--

Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program X. Required Action and associated Completion Time of Condition B, D, E, O, P, Q, T, U, V, or W not met.

X.1 Be in MODE 3.

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

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

Refer to Table 3.3.1-1 to determine which SRs apply for each RTS Function.

SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.2

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 15% RTP.

Compare results of calorimetric heat balance calculation to power range channel output. Adjust power range channel output if absolute difference is

> 2%.

In accordance with the Surveillance Frequency Control Program (continued)

Amendment 334, 356, 358

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-10 Amendment 334, 356, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.3

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

Not required to be performed until 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after THERMAL POWER is 15% RTP.

Compare results of the core power distribution measurements to Nuclear Instrumentation System (NIS) AFD. Adjust NIS channel if absolute difference is 3%.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.4

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

This Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.5 Perform ACTUATION LOGIC TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.6

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is 50% RTP.

Calibrate excore channels to agree with core power distribution measurements.

In accordance with the Surveillance Frequency Control Program (continued)

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-11 Amendment 334, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.7

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

Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

Perform COT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.8

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

This Surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions.

Perform COT.

NOTE--------

Only required when not performed within the Frequency specified in the Surveillance Frequency Control Program Prior to reactor startup 0BAND Four hours after reducing power below P-6 for source range instrumentation 1BAND (continued)

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-12 Amendment 334, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Twelve hours after reducing power below P-10 for power and intermediate range instrumentation 2BAND In accordance with the Surveillance Frequency Control Program SR 3.3.1.9

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

Verification of setpoint is not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.10

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

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program (continued)

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-13 Amendment 334, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.11

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

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.12

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

Verification of setpoint is not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.13

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

Verification of setpoint is not required.

Perform TADOT.

Prior to exceeding the P-9 interlock whenever the unit has been in MODE 3, if not performed within the previous 31 days SR 3.3.1.14

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

Neutron detectors are excluded from response time testing.

Verify RTS RESPONSE TIME is within limits.

In accordance with the Surveillance Frequency Control Program

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-17 Amendment 334, 358 40TTable 3.3.1-1 (page 4 of 9) 40TReactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT

12. Underfrequency RCPs 1P(g) 1 per bus K

SR 3.3.1.9 SR 3.3.1.10P(b)(c)

SR 3.3.1.14 56.973 Hz 57.0 Hz

13. Steam Generator (SG) Water Level a.

Low-Low (Adverse) 1,2 3 per SG U

SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 14.4% NR Span 15.0% NR Span Coincident with Containment Pressure (EAM) 1,2 4

V SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 0.6 psig 0.5 psig and RCS Loop T 1,2 4

W SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 RCS Loop T variable input nominal trip setpoint +

2.5% RTP RCS Loop T variable input 50% RTP with Time Delay TRSR if one SG is affected (1.01)TRSR (Note 3)

TRS R(Note 3) or Time Delay TRmR if two or more SGs are affected (1.01)TRmR (Note 3)

TRm R(Note 3)

(b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

(g)

Above the P-7 (Low Power Reactor Trips Block) interlock.

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-18 Amendment 334, 349, 358 40TTable 3.3.1-1 (page 5 of 9) 40TReactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT b.

Low-Low (EAM) 1,2 3 per SG U

SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 10.1% NR Span 10.7% NR Span Coincident with RCS Loop T 1,2 4

W SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 RCS Loop T variable input nominal trip setpoint +

2.5% RTP RCS Loop T variable input 50% RTP with Time Delay TRSR if one SG is affected (1.01)TRSR (Note 3)

TRS R(Note 3) or Time Delay TRmR if two or more SGs are affected (1.01)TRmR (Note 3)

TRm R(Note 3)

14. Turbine Trip a.

Low Fluid Oil Pressure 1P(h) 3 M

SR 3.3.1.10P(b)(c)

SR 3.3.1.13 710 psig 800 psig b.

Turbine Stop Valve Closure 1P(h) 4 M

SR 3.3.1.10 SR 3.3.1.13 1% open 1% open

15. Safety Injection (SI)

Input from Engineered Safety Feature Actuation System (ESFAS) 1,2 2 trains O

SR 3.3.1.12 NA NA (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

(h)

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 1 3.3.1-19 Amendment 334, 358 40TTable 3.3.1-1 (page 6 of 9) 40TReactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT

16. Reactor Trip System Interlocks a.

Intermediate Range Neutron Flux, P-6 2P(f) 2 Q

SR 3.3.1.11 6 x 10P-5 P% RTP 1 x 10P-4 P%

RTP b.

Low Power Reactor Trips Block, P-7 1

1 per train R

SR 3.3.1.5 NA NA c.

Power Range Neutron Flux, P-8 1

4 R

SR 3.3.1.11 37.4% RTP 35% RTP d.

Power Range Neutron Flux, P-9 1

4 R

SR 3.3.1.11 52.4% RTP 50% RTP e.

Power Range Neutron Flux, P-10 1,2 4

Q SR 3.3.1.11 7.6% RTP and 12.4% RTP 10% RTP f.

Turbine Impulse Pressure, P-13 1

2 R

SR 3.3.1.10 12.4%

turbine power 10% turbine power

17. Reactor Trip BreakersP(i)

P 1,2 2 trains P

SR 3.3.1.4 NA NA 3P(a)

P, 4P(a)

P, 5P(a) 2 trains C

SR 3.3.1.4 NA NA

18. Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms 1,2 1 each per reactor trip breaker T

SR 3.3.1.4 NA NA 3P(a)

P, 4P(a)

P, 5P(a) 1 each per reactor trip breaker C

SR 3.3.1.4 NA NA

19. Automatic Trip Logic 1,2 2 trains O

SR 3.3.1.5 NA NA 3P(a)

P, 4P(a)

P, 5P(a) 2 trains C

SR 3.3.1.5 NA NA (a)

With Rod Control System capable of rod withdrawal or one or more rods not fully inserted.

(f)

Below the P-6 (Intermediate Range Neutron Flux) interlocks.

(i)

Including any reactor trip bypass breakers that are racked in and closed for bypassing a reactor trip breaker.

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-1 Amendment 334, 358 3.3 INSTRUMENTATION 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation LCO 3.3.2 The ESFAS instrumentation for each Function in Table 3.3.2-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.2-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one or more required channels or trains inoperable.

A.1 Enter the Condition referenced in Table 3.3.2-1 for the channel(s) or train(s).

Immediately B. One channel or train inoperable.

B.1 Restore channel or train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

C.1 Restore train to OPERABLE status.

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 D. One channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

D.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-3 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One Containment Pressure channel inoperable.

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

One additional channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

E.1 Place channel in bypass.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months F.

One channel inoperable.

F.1 Restore channel to OPERABLE status.

OR F.2 Declare the associated Main Steam Isolation Valve inoperable.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months G. One channel or train inoperable.

G.1 Restore channel or train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-4 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

H.1 Restore train to OPERABLE status.

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 I.

One channel inoperable.

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

The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

I.1 For the affected protection set, the Trip Time Delay for one affected steam generator (TS) is adjusted to match the Trip Time Delay for multiple affected steam generators (TM).

AND I.2 Place channel in trip.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 6 hours OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-5 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J.

One channel inoperable.

J.1 For the affected protection set, adjust the Steam Generator Water Level -

Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Water Level -- Low-Low (Adverse).

OR J.2 For the affected protection set, place the Steam Generator Water Level--

Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 6 hours K. One channel inoperable.

K.1 For the affected protection set, adjust the Trip Time Delays (TS and TM) threshold power level for zero seconds time delay to 0% RTP.

OR K.2 For the affected protection set, place the Steam Generator Water level--

Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 6 hours OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-6 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME L.

One voltage sensor channel inoperable.

L.1 Restore the inoperable channel to OPERABLE status.

OR L.2 Declare the associated auxiliary feedwater pump inoperable.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-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 M. Two or more voltage sensor channels inoperable.

OR One required load shed timer channel inoperable.

M.1.1 Restore all but one voltage sensor channel to an OPERABLE status.

AND M.1.2 Restore required load shed timer channel to an OPERABLE status.

OR M.2 Declare the associated auxiliary feedwater pump inoperable.

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

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-7 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME N.

One Main Feedwater Pumps trip channel inoperable.

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

One channel may be inoperable during MODE 1 for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service.

N.1 Restore channel to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program O. Required Action and associated Completion Time of Condition N not met.

O.1 Be in MODE 3.

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

One channel P.1 Declare the associated auxiliary feedwater pump inoperable.

Immediately Q. One channel inoperable.

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

One additional channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

Q.1 Place channel in bypass.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months R. One or more channels inoperable.

R.1 Verify interlock is in required state for existing unit condition.

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

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-8 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME S. Required Action and associated Completion Time of Conditions B, C, or Q not met.

S.1 Be in MODE 3.

AND S.2 Be in MODE 5.

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

Required Action and associated Completion Time of Conditions D, E, G, H, I, J, K, or R not met.

T.1 Be in MODE 3.

AND T.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours U. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

U.1 Be in MODE 3.

AND U.2 Be in MODE 5.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 42 hours SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-9 Amendment 334, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.2 Perform ACTUATION LOGIC TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.3 Perform MASTER RELAY TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.4 Perform COT.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.5 Perform SLAVE RELAY TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.6

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

Verification of relay setpoints not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-10 Amendment 334, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.7

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

Verification of setpoint not required for manual initiation functions.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.8

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

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.9

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

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after SG pressure is 842 psig.

Verify ESFAS RESPONSE TIMES are within limit.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.10

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

Verification of setpoint not required.

Perform TADOT.

Once per reactor trip breaker cycle

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-17 Amendment 334, 358 Table 3.3.2-1 (page 7 of 9)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT 6.

Auxiliary Feedwater c.

Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

d.

Loss of Offsite Power (1) Voltage Sensors 1,2,3 3 per shutdown board(j)

L,M SR 3.3.2.6 SR 3.3.2.8(b)(c)

SR 3.3.2.9 Refer to Function 1 of Table 3.3.5-1 for setpoints and allowable values.

(2) Load Shed Timer 1,2,3 1 per shutdown board(j)

M SR 3.3.2.8(b)(c)

SR 3.3.2.9 Refer to Function 1 of Table 3.3.5-1 for setpoints and allowable values.

e.

Trip of all Main Feedwater Pumps 1,2(k) 1 per pump N

SR 3.3.2.7 SR 3.3.2.9 NA NA f.

Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low 1,2,3 3 per pump P

SR 3.3.2.8(b)(c) 2.44 psig (motor driven pump) 12 psig (turbine driven pump) 3.21 psig (motor driven pump) 13.9 psig (turbine driven pump)

(b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

(j)

Unit 1 shutdown boards only.

(k)

When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators.

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-18 Amendment 334, 358 Table 3.3.2-1 (page 8 of 9)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT 6.

Auxiliary Feedwater g.

Auxiliary Feedwater Suction Transfer Time Delays (1) Motor-Driven Pump 1,2,3 1 per pump P

SR 3.3.2.8(b)(c) 4.4 seconds and 3.6 seconds 4 seconds (2) Turbine-Driven Pump 1,2,3 2 per pump P

SR 3.3.2.8(b)(c) 6.05 seconds and 4.95 seconds 5.5 seconds 7.

Automatic Switchover to Containment Sump a.

Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains U

SR 3.3.2.2 SR 3.3.2.3 SR 3.3.2.5 NA NA b.

RWST Level -

Low 1,2,3,4 4

Q SR 3.3.2.1 SR 3.3.2.4(b)(c)

SR 3.3.2.8(b)(c)

SR 3.3.2.9 132.71" and 127.29" from tank base 130" from tank base Coincident with Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

and Coincident with Containment Sump Level -

High 1,2,3,4 4

Q SR 3.3.2.1 SR 3.3.2.4(b)(c)

SR 3.3.2.8(b)(c)

SR 3.3.2.9 31.68 in.

and 28.32 in.

above el.

680 ft 30 in. above el. 680 ft (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 1 3.3.2-19 Amendment 334, 358 Table 3.3.2-1 (page 9 of 9)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT 8.

ESFAS Interlocks a.

Reactor Trip, P-4 1,2,3 1 per train, 2 trains G

SR 3.3.2.10 NA NA b.

Pressurizer Pressure, P-11/

Not P-11 (1) Not P-11, Automatic Unblock of Safety Injection on Increasing Pressure 1,2,3 3

R SR 3.3.2.8 1975.2 psig 1970 psig (2) P-11, Enable Manual Block of Safety Injection on Decreasing Pressure 1,2,3 3

R SR 3.3.2.8 1956.8 psig 1962 psig

LOP DG Start Instrumentation 3.3.5 SEQUOYAH - UNIT 1 3.3.5-1 Amendment 334, 345, 358 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation LCO 3.3.5 The LOP DG start instrumentation for each Function in Table 3.3.5-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one voltage sensor channel inoperable.

A.1 Restore the inoperable channel to OPERABLE status.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program B. One or more Functions with two or more voltage sensor channels inoperable.

OR One or more Functions with one required timer inoperable.

B.1.1 Restore all but one voltage sensor channel to OPERABLE status.

AND B.1.2 Restore required timer to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour C. One or more unbalanced voltage relays inoperable.

C.1 Restore unbalanced voltage relays to OPERABLE status.

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

Pressurizer PORVs 3.4.11 SEQUOYAH - UNIT 1 3.4.11-1 Amendment 334, 358 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

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

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

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

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs inoperable and capable of being manually cycled.

A.1 Close and maintain power to associated block valve.

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

B.1 Close associated block valve.

AND B.2 Remove power from associated block valve.

AND B.3 Restore PORV to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program

Pressurizer PORVs 3.4.11 SEQUOYAH - UNIT 1 3.4.11-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One block valve inoperable.

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

Required Actions C.1 and C.2 do not apply when block valve is inoperable solely as a result of complying with Required Action B.2 or E.2.

C.1 Place associated PORV in manual control.

AND C.2 Restore block valve to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two PORVs inoperable and not capable of being manually cycled.

E.1 Close associated block valves.

AND E.2 Remove power from associated block valves.

AND E.3 Be in MODE 3.

AND E.4 Be in MODE 4.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours

ECCS - Operating 3.5.2 SEQUOYAH - UNIT 1 3.5.2-1 Amendment 334, 358 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

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

1.

In MODE 3, both safety injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 3.4.14.1.

2.

In MODE 3, ECCS pumps may be made incapable of injecting to support transition into or from the Applicability of LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP) System," for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or until the temperature of all RCS cold legs exceeds Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR plus 25°F, whichever comes first.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more trains inoperable.

A.1 Restore train(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours C. Less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.

C.1 Enter LCO 3.0.3.

Immediately

Containment Air Locks 3.6.2 SEQUOYAH - UNIT 1 3.6.2-3 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Lock an OPERABLE door closed in the affected air lock.

AND B.3

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

Air lock doors in high radiation areas may be verified locked closed by administrative means.

Verify an OPERABLE door is locked closed in the affected air lock.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Once per 31 days C. One or more containment air locks inoperable for reasons other than Condition A or B.

C.1 Initiate action to evaluate overall containment leakage rate per LCO 3.6.1.

AND C.2 Verify a door is closed in the affected air lock.

AND C.3 Restore air lock to OPERABLE status.

Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 hours OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time not met.

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

Containment Isolation Valves 3.6.3 SEQUOYAH - UNIT 1 3.6.3-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more penetration flow paths with one containment isolation valve inoperable for reasons other than Conditions E, F, and G.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Category 1 or 8 CIVs AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for Category 2 or 9 CIVs AND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Category 3 or 10 CIVs AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Category 4 or 11 CIVs AND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for Category 5 or 12 CIVs AND 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for Category 6 or 13 CIVs AND 7 days for Category 7 or 14 CIVs OR In accordance with the Risk Informed Completion Time Program

Containment Isolation Valves 3.6.3 SEQUOYAH - UNIT 1 3.6.3-3 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2

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

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

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

Once per 31 days following isolation for isolation devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment B. ------------NOTE------------

Only applicable to penetration flow paths with two containment isolation valves.

One or more penetration flow paths with two containment isolation valves inoperable for reasons other than Conditions E, F, and G.

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

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

Containment Spray System 3.6.6 SEQUOYAH - UNIT 1 3.6.6-1 Amendment 334, 358 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

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

RHR spray trains are not required to be OPERABLE in MODE 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray subsystem inoperable.

A.1 Restore containment spray subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 84 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray train manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

In accordance with the Surveillance Frequency Control Program

HMS 3.6.8 SEQUOYAH - UNIT 1 3.6.8-1 Amendment 334, 358 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Mitigation System (HMS)

LCO 3.6.8 Two HMS trains shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One HMS train inoperable.

A.1 Restore HMS train to OPERABLE status.

OR A.2 Perform SR 3.6.8.1 on the OPERABLE train.

7 days OR In accordance with the Risk Informed Completion Time Program Once per 7 days B. One containment region with no OPERABLE hydrogen ignitor.

B.1 Restore one hydrogen ignitor in the affected containment region to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

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

ARS 3.6.11 SEQUOYAH - UNIT 1 3.6.11-1 Amendment 334, 358 3.6 CONTAINMENT SYSTEMS 3.6.11 Air Return System (ARS)

LCO 3.6.11 Two ARS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ARS train inoperable.

A.1 Restore ARS train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.11.1 Verify each ARS fan starts on an actual or simulated actuation signal, after a delay of 9.0 minutes and 11.0 minutes, and operates for 15 minutes.

In accordance with the Surveillance Frequency Control Program

ARS 3.6.11 SEQUOYAH - UNIT 1 3.6.11-2 Amendment 334, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.11.2 Verify, with the ARS fan dampers closed, each ARS fan motor current is 24.5 amps and 39.5 amps.

In accordance with the Surveillance Frequency Control Program SR 3.6.11.3 Verify, with the ARS fan not operating, each ARS fan damper opens when 68.1 in-lb of torque is applied to the counterweight.

In accordance with the Surveillance Frequency Control Program

MSIVs 3.7.2 SEQUOYAH - UNIT 1 3.7.2-1 Amendment 334, 358 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 Four MSIVs shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when all MSIVs are closed.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One MSIV inoperable in MODE 1.

A.1 Restore MSIV to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 2.

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

Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.

C.1 Close MSIV.

AND C.2 Verify MSIV is closed.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Once per 7 days D. Required Action and associated Completion Time of Condition C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours

AFW System 3.7.5 SEQUOYAH - UNIT 1 3.7.5-1 Amendment 334, 358 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

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

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY:

MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

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

LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW train inoperable due to one inoperable steam supply.

OR

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

Only applicable if MODE 2 has not been entered following refueling.

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

A.1 Restore affected equipment to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program

AFW System 3.7.5 SEQUOYAH - UNIT 1 3.7.5-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train inoperable in MODE 1, 2, or 3 for reasons other than Condition A.

B.1 Restore AFW train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program C. Turbine driven AFW train inoperable due to one inoperable steam supply.

AND One motor driven AFW train inoperable.

C.1 Restore the steam supply to the turbine driven train to OPERABLE status.

OR C.2 Restore the motor driven AFW train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 48 hours D. Required Action and associated Completion Time of Condition A, B, or C not met.

OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 18 hours

AFW System 3.7.5 SEQUOYAH - UNIT 1 3.7.5-3 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Three AFW trains inoperable in MODE 1, 2, or 3.

E.1

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

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

Initiate action to restore one AFW train to OPERABLE status.

Immediately F.

Required AFW train inoperable in MODE 4.

F.1 Initiate action to restore AFW train to OPERABLE status.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1

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

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program

AFW System 3.7.5 SEQUOYAH - UNIT 1 3.7.5-4 Amendment 334, 358 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.2

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

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 842 psig in the steam generator.

Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

In accordance with the Inservice Testing Program SR 3.7.5.3

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

1.

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

2.

Only required to be met in MODES 1, 2, and 3.

Verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.7.5.4

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

1.

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 842 psig in the steam generator.

2.

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

3.

Only required to be met in MODES 1, 2, and 3.

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

In accordance with the Surveillance Frequency Control Program

CCS 3.7.7 SEQUOYAH - UNIT 1 3.7.7-1 Amendment 334, 358 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water System (CCS)

LCO 3.7.7 Two CCS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCS train inoperable.

A.1

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

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

MODE 4," for residual heat removal loops made inoperable by CCS.

Restore CCS train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

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

ERCW System 3.7.8 SEQUOYAH - UNIT 1 3.7.8-2 Amendment 334 336, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One ERCW System train inoperable for reasons other than Condition A.

B.1

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

1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating,"

for emergency diesel generator made inoperable by ERCW System.

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

Restore ERCW System train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program C. Required Action and associated Completion Time of Condition A or B not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

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

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 1 3.8.1-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore offsite circuit to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. One or more Train A DG(s) inoperable.

OR One or more Train B DG(s) inoperable.

B.1 Perform SR 3.8.1.1 for the offsite circuits.

AND B.2 Declare required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable.

AND B.3.1 Determine OPERABLE DGs are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DGs.

AND B.4 Restore DG(s) to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 7 days OR

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 1 3.8.1-3 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME In accordance with the Risk Informed Completion Time Program C. One offsite circuit inoperable solely due to an offsite power source to 6.9 kV Shutdown Board 2A-A or 2B-B inoperable.

C.1 Perform SR 3.8.1.1 for OPERABLE offsite circuit.

AND C.2 Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

AND C.3 Restore offsite circuit to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to 6.9 kV Shutdown Board 2A-A or 2B-B concurrent with inoperability of redundant required feature(s) 7 days OR In accordance with the Risk Informed Completion Time Program

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 1 3.8.1-4 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two offsite circuits inoperable.

D.1 Declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

AND D.2 Restore one offsite circuit to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition D concurrent with inoperability of redundant required features 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program E. One offsite circuit inoperable for reasons other than Condition C.

AND DG 1A-A or 1B-B inoperable.

E.1 Restore offsite circuit to OPERABLE status.

OR E.2 Restore DG to OPERABLE status.

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 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

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 1 3.8.1-5 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

One or more Train A DG(s) inoperable.

AND One or more Train B DG(s) inoperable.

F.1 Restore one train of DGs to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months G. Required Action and associated Completion Time of Condition A, B, C, D, E, or F not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours H. Two offsite circuits inoperable.

AND One or more Train A DG(s) inoperable.

OR One or more Train B DG(s) inoperable.

H.1 Enter LCO 3.0.3.

Immediately I.

One offsite circuit inoperable.

AND One or more Train A DG(s) inoperable.

AND One or more Train B DG(s) inoperable.

I.1 Enter LCO 3.0.3.

Immediately

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 1 3.8.1-6 Amendment 334, 341, 358 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuit.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.2

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

1.

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

2.

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 6800 V and 7260 V, and frequency 59.8 Hz and 60.2 Hz.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.3

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

1.

DG loadings may include gradual loading as recommended by the manufacturer.

2.

Momentary transients outside the load range do not invalidate this test.

3.

This Surveillance shall be conducted on only one DG at a time.

4.

This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

Verify each DG is synchronized and loaded and operates for 60 minutes at a load 3960 kW and 4400 kW.

In accordance with the Surveillance Frequency Control Program

DC Sources - Operating 3.8.4 SEQUOYAH - UNIT 1 3.8.4-1 Amendment 334, 358 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 Two Vital DC electrical power trains and four diesel generator (DG) DC electrical power subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or two vital battery chargers on one train inoperable.

A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage.

AND A.2 Verify battery float current 2 amps.

AND A.3 Restore vital battery chargers to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7 days OR In accordance with the Risk Informed Completion Time Program B. One vital DC electrical power train inoperable for reasons other than Condition A.

B.1 Restore vital DC electrical power train to OPERABLE status.

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

DC Sources - Operating 3.8.4 SEQUOYAH - UNIT 1 3.8.4-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and Associated Completion Time of Condition A or B not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours D. One or more DG DC electrical power subsystem(s) inoperable.

D.1 Declare associated DG(s) inoperable.

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

In accordance with the Surveillance Frequency Control Program SR 3.8.4.2 Verify each vital battery charger supplies 150 amps at greater than or equal to the minimum established float voltage for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

OR Verify each vital battery charger can recharge the battery to the fully charged state within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

In accordance with the Surveillance Frequency Control Program

Inverters - Operating 3.8.7 SEQUOYAH - UNIT 1 3.8.7-1 Amendment 334, 358 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

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

Two inverters may be disconnected from their associated DC source for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an equalizing charge on their associated common battery, provided:

a.

The associated AC vital instrument power board(s) are energized from their inverter using internal AC source, and b.

All other AC vital instrument power boards are energized from their associated OPERABLE inverters connected to their DC source.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required inverter inoperable.

A.1

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

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital instrument power board de-energized.

Restore inverter to OPERABLE status.

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

Inverters - Operating 3.8.7 SEQUOYAH - UNIT 1 3.8.7-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency, and alignment to required AC vital instrument power boards.

In accordance with the Surveillance Frequency Control Program

Distribution Systems - Operating 3.8.9 SEQUOYAH - UNIT 1 3.8.9-1 Amendment 334, 358 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Two electrical power distribution trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC electrical power distribution subsystems inoperable due to one or more Unit 1 AC shutdown boards inoperable.

A.1

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

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for vital DC electrical power trains made inoperable by inoperable AC electrical power distribution subsystems.

Restore Unit 1 AC electrical power distribution subsystem(s) to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program B. One or more AC vital instrument power distribution subsystems inoperable.

B.1 Restore AC vital instrument power distribution subsystem(s) to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program

Distribution Systems - Operating 3.8.9 SEQUOYAH - UNIT 1 3.8.9-2 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more vital DC electrical power distribution subsystems inoperable.

C.1 Restore vital DC electrical power distribution subsystem(s) to OPERABLE status.

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

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

1.

Only applicable during planned maintenance.

2.

Only applicable when Unit 1 is defueled or in MODE 6 following defueled with Unit 1 refueling water cavity level 23 ft. above top of reactor vessel flange.

D. One or more AC electrical power distribution subsystems inoperable due to one or more Unit 1 AC shutdown boards inoperable.

D.1 Declare associated required feature(s) inoperable.

Immediately E. One or more AC electrical power distribution subsystems inoperable due to one or more Unit 1 AC shutdown boards inoperable for reasons other than Condition D.

E.1 Restore Unit 1 AC electrical power distribution subsystem(s) to OPERABLE status.

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

One or more DG DC electrical power distribution panels inoperable.

F.1 Declare associated supported DG inoperable.

Immediately

Distribution Systems - Operating 3.8.9 SEQUOYAH - UNIT 1 3.8.9-3 Amendment 334, 358 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Required Action and associated Completion Time not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours H. Two or more electrical power distribution subsystems inoperable that result in a loss of safety function.

H.1 Enter LCO 3.0.3.

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

In accordance with the Surveillance Frequency Control Program

Programs and Manuals 5.5 SEQUOYAH - UNIT 1 5.5-17 5.5 Programs and Manuals 5.5.16 Control Room Envelope (CRE) Habitability Program (continued) f.

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

5.5.17 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

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

a.

The RICT may not exceed 30 days; b.

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

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

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

Amendment 334, 358

Programs and Manuals 5.5 SEQUOYAH - UNIT 1 5.5-18 Amendment 358 2.

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

3.

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

G

For emergent conditions, if the extent of condition evaluation for

inoperable structures, systems, or components (SSCs) is not complete

prior to exceeding the Completion Time, the RICT shall account for the

increased possibility of common cause failure (CCF) by either:

Numerically accounting for the increased possibility of CCF in the

RICT calculation; or

Risk Management Actions (RMAs) not already credited in the

RICT calculation shall be implemented that support redundant or

diverse SSCs that perform the function(s) of the inoperable SSCs,

and, if practicable, reduce the frequency of initiating events that

challenge the function(s) performed by the inoperable SSCs.

7KHULVNDVVHVVPHQWDSSURDFKHVDQGPHWKRGVVKDOOEH

DFFHSWDEOHWRWKH15&7KHSODQW35$VKDOOEHEDVHGRQWKHDV

EXLOWDVRSHUDWHGDQGPDLQWDLQHGSODQWDQGUHIOHFWWKHRSHUDWLQJ

H[SHULHQFHDWWKHSODQWDVVSHFLILHGLQ5HJXODWRU\\*XLGH

5HYLVLRQ0HWKRGVWRDVVHVVWKHULVNIURPH[WHQGLQJWKH

&RPSOHWLRQ7LPHVPXVWEH35$PHWKRGVDSSURYHGIRUXVHZLWK

WKLVSURJUDPRURWKHUPHWKRGVDSSURYHGE\\WKH15&IRUJHQHULF

XVHDQGDQ\\FKDQJHLQWKH35$PHWKRGVWRDVVHVVULVNWKDWDUH

RXWVLGHWKHVHDSSURYDOERXQGDULHVUHTXLUHSULRU15&DSSURYDO

H

TENNESSEE VALLEY AUTHORITY DOCKET NO. 50-328 SEQUOYAH NUCLEAR PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 352 Renewed License No. DPR-79

1.

The U.S. Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Tennessee Valley Authority (the licensee) dated August 5, 2021, as supplemented by letters dates April 28, 2022, May 13, 2022, and July 1, 2022, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to the Technical Specifications as indicated in the attachment to this license amendment and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-79 is hereby amended to read as follows:

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 352 are hereby incorporated in the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION David J. Wrona, Chief Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to the Renewed Facility Operating License and Technical Specifications Date of Issuance: August 24, 2022 David J.

Wrona Digitally signed by David J. Wrona Date: 2022.08.24 15:13:20 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 352 SEQUOYAH NUCLEAR PLANT, UNIT 2 RENEWED FACILITY OPERATING LICENSE NO. DPR-79 DOCKET NO. 50-328 Replace page 3 of the Renewed Facility Operating License with the attached page 3.

Replace the following pages of the Appendix A Technical Specifications with the attached pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Page Insert Page 1.3-10 3.3.1-1 3.3.1-2 3.3.1-3 3.3.1-5 3.3.1-6 3.3.1-7 3.3.1-8 3.3.1-9 3.3.1-10 3.3.1-11 3.3.1-12 3.3.1-13 3.3.1-17 3.3.1-18 3.3.1-19 3.3.2-1 3.3.2-2 3.3.2-3 3.3.2-4 3.3.2-5 3.3.2-6 3.3.2-7 3.3.2-8 3.3.2-9 3.3.2-10 3.3.2-17 3.3.2-18 3.3.2-19 3.3.5-1 1.3-10 1.3-11 3.3.1-1 3.3.1-2 3.3.1-3 3.3.1-5 3.3.1-6 3.3.1-7 3.3.1-8 3.3.1-9 3.3.1-10 3.3.1-11 3.3.1-12 3.3.1-13 3.3.1-17 3.3.1-18 3.3.1-19 3.3.2-1 3.3.2-2 3.3.2-3 3.3.2-4 3.3.2-5 3.3.2-6 3.3.2-7 3.3.2-8 3.3.2-9 3.3.2-10 3.3.2-17 3.3.2-18 3.3.2-19 3.3.5-1 3.4.11-1 3.4.11-2 3.5.2-1 3.6.2-3 3.6.3-2 3.6.3-3 3.6.6-1 3.6.8-1 3.6.11-1 3.6.11-2 3.7.2-1 3.7.5-1 3.7.5-2 3.7.5-3 3.7.5-4 3.7.7-1 3.7.8-2 3.8.1-2 3.8.1-3 3.8.1-4 3.8.1-5 3.8.1-6 3.8.4-1 3.8.4-2 3.8.7-1 3.8.7-2 3.8.9-1 3.8.9-2 3.8.9-3 5.5-17 3.4.11-1 3.4.11-2 3.5.2-1 3.6.2-3 3.6.3-2 3.6.3-3 3.6.6-1 3.6.8-1 3.6.11-1 3.6.11-2 3.7.2-1 3.7.5-1 3.7.5-2 3.7.5-3 3.7.5-4 3.7.7-1 3.7.8-2 3.8.1-2 3.8.1-3 3.8.1-4 3.8.1-5 3.8.1-6 3.8.4-1 3.8.4-2 3.8.7-1 3.8.7-2 3.8.9-1 3.8.9-2 3.8.9-3 5.5-17 5.5-18 Amendment No. 352 Renewed License No. DPR 79 (3)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (4)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; and (5)

Pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the Sequoyah and Watts Bar Unit 1 Nuclear Plants.

C.

This renewed license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter I and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect; and is subject to the additional conditions specified or incorporated below:

(1)

Maximum Power Level The Tennessee Valley Authority is authorized to operate the facility at reactor core power levels not in excess of 3455 megawatts thermal.

(2)

Technical Specifications The Technical Specifications contained in Appendices A and B, as revised through Amendment No. 352 are hereby incorporated into the renewed license. The licensee shall operate the facility in accordance with the Technical Specifications.

(3)

Initial Test Program The Tennessee Valley Authority shall conduct the post-fuel-loading initial test program (set forth in Section 14 of Tennessee Valley Authority's Final Safety Analysis Report, as amended), without making any major modifications of this program unless modifications have been identified and have received prior NRC approval. Major modifications are defined as:

a.

Elimination of any test identified in Section 14 of TVA's Final Safety Analysis Report as amended as being essential;

Completion Times 1.3 SEQUOYAH - UNIT 2 1.3-10 Amendment 327, 352 1.3 Completion Times EXAMPLES (continued)

Required Action A.1 has two Completion Times. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time begins at the time the Condition is entered and each "Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter" interval begins upon performance of Required Action A.1.

If after Condition A is entered, Required Action A.1 is not met within either the initial 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months or any subsequent 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months interval from the previous performance (plus the extension allowed by SR 3.0.2), Condition B is entered. The Completion Time clock for Condition A does not stop after Condition B is entered, but continues from the time Condition A was initially entered. If Required Action A.1 is met after Condition B is entered, Condition B is exited and operation may continue in accordance with Condition A, provided the Completion Time for Required Action A.2 has not expired.

EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.

A.1 Restore subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.

Completion Times 1.3 SEQUOYAH - UNIT 2 1.3-11 Amendment 352 1.3 Completion Times EXAMPLES (continued)

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

If the 7 day Completion Time clock of Condition A has expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition B is also entered and the Completion Time clocks for Required Actions B.1 and B.2 start.

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

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-1 Amendment 327, 352 3.3 INSTRUMENTATION 3.3.1 Reactor Trip System (RTS) Instrumentation LCO 3.3.1 The RTS instrumentation for each Function in Table 3.3.1-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.1-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one or more required channels or trains inoperable.

A.1 Enter the Condition referenced in Table 3.3.1-1 for the channel(s) or train(s).

Immediately B. One Manual Reactor Trip channel inoperable.

B.1 Restore channel to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program C. One channel or train inoperable.

C.1 Restore channel or train to OPERABLE status.

UOR C.2.1 Initiate action to fully insert all rods.

UAND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 48 hours

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-2 Amendment 327, 336, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.2.2 Place the Rod Control System in a condition incapable of rod withdrawal.

49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months D. One Power Range Neutron Flux - High channel inoperable.

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

1.

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing and setpoint adjustment of other channels.

2.

Perform SR 3.2.4.2 if input to QPTR from one or more Power Range Neutron Flux channels are inoperable with THERMAL power >75% RTP.

D.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-3 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

E.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program F.

One Intermediate Range Neutron Flux channel inoperable.

F.1 Reduce THERMAL POWER to < P-6.

UOR F.2 Increase THERMAL POWER to > P-10.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours G. Two Intermediate Range Neutron Flux channels inoperable.

G.1

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

Limited plant cooldown or boron dilution is allowed provided the change is accounted for in the calculated SDM.

Suspend operations involving positive reactivity additions.

UAND G.2 Reduce THERMAL POWER to < P-6.

Immediately 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-5 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME K. One channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

K.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program L.

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

L.1 Reduce THERMAL POWER to < P-7.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months M. One Turbine Trip channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

M.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program N. Required Action and associated Completion Time of Condition M not met.

N.1 Reduce THERMAL POWER to < P-9.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-6 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME O. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

O.1 Restore train to OPERABLE status.

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 P. One reactor trip breaker train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing, provided the other train is OPERABLE.

P.1 Restore train to OPERABLE status.

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 Q. One or more channels inoperable.

Q.1 Verify interlock is in required state for existing unit conditions.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months R. One or more channels inoperable.

R.1 Verify interlock is in required state for existing unit conditions.

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-7 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME S. Required Action and associated Completion Time of Condition R not met.

S.1 Be in MODE 2.

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

One trip mechanism inoperable for one reactor trip breaker.

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

The reactor trip breaker train shall not be bypassed while one of the diverse trip features is inoperable except for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for performing maintenance to restore the breaker to OPERABLE status T.1 Restore trip mechanism to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program U. One channel inoperable.

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

The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

U.1 For the affected protection set, adjust the Trip Time Delay for one affected steam generator (TRS R) to match the Trip Time Delay for multiple affected steam generators (TRM R).

UAND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-8 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME U.2 Place channel in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program V.

One channel inoperable.

V.1 For the affected protection set, adjust the Steam Generator Water Level -

Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Water Level - Low-Low (Adverse).

UOR V.2 For the affected protection set, place the Steam Generator Water level--Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 6 hours OR In accordance with the Risk Informed Completion Time Program W. One channel inoperable.

W.1 For the affected protection set, adjust the Trip Time Delays (TRS R and TRM R) threshold power level for zero seconds time delay to 0% RTP.

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME W.2 For the affected protection set, place the Steam Generator Water Level--

Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program X. Required Action and associated Completion Time of Condition B, D, E, O, P, Q, T, U, V, or W not met.

X.1 Be in MODE 3.

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

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

Refer to Table 3.3.1-1 to determine which SRs apply for each RTS Function.

SURVEILLANCE FREQUENCY SR 3.3.1.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.2

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

Not required to be performed until 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after THERMAL POWER is 15% RTP.

Compare results of calorimetric heat balance calculation to power range channel output. Adjust power range channel output if absolute difference is

> 2%.

In accordance with the Surveillance Frequency Control Program (continued)

Amendment 327, 349, 352

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-10 Amendment 327, 349, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.3

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

Not required to be performed until 96 hours0.00111 days 0.0267 hours 1.587302e-4 weeks 3.6528e-5 months after THERMAL POWER is 15% RTP.

Compare results of the core power distribution measurements to Nuclear Instrumentation System (NIS) AFD. Adjust NIS channel if absolute difference is 3%.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.4

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

This Surveillance must be performed on the reactor trip bypass breaker prior to placing the bypass breaker in service.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.5 Perform ACTUATION LOGIC TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.6

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

Not required to be performed until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after THERMAL POWER is 50% RTP.

Calibrate excore channels to agree with core power distribution measurements.

In accordance with the Surveillance Frequency Control Program (continued)

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-11 Amendment 327, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.7

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

Not required to be performed for source range instrumentation prior to entering MODE 3 from MODE 2 until 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months after entry into MODE 3.

Perform COT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.8

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

This Surveillance shall include verification that interlocks P-6 and P-10 are in their required state for existing unit conditions.

Perform COT.

NOTE--------

Only required when not performed within the Frequency specified in the Surveillance Frequency Control Program Prior to reactor startup 0BAND Four hours after reducing power below P-6 for source range instrumentation 1BAND (continued)

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-12 Amendment 327, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY Twelve hours after reducing power below P-10 for power and intermediate range instrumentation 2BAND In accordance with the Surveillance Frequency Control Program SR 3.3.1.9

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

Verification of setpoint is not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.10

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

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program (continued)

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-13 Amendment 327, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.1.11

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

Neutron detectors are excluded from CHANNEL CALIBRATION.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.12

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

Verification of setpoint is not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.1.13

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

Verification of setpoint is not required.

Perform TADOT.

Prior to exceeding the P-9 interlock whenever the unit has been in MODE 3, if not performed within the previous 31 days SR 3.3.1.14

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

Neutron detectors are excluded from response time testing.

Verify RTS RESPONSE TIME is within limits.

In accordance with the Surveillance Frequency Control Program

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-17 Amendment 327, 352 40TTable 3.3.1-1 (page 4 of 9) 40TReactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT

12. Underfrequency RCPs 1P(g) 1 per bus K

SR 3.3.1.9 SR 3.3.1.10P(b)(c)

SR 3.3.1.14 56.973 Hz 57.0 Hz

13. Steam Generator (SG) Water Level a.

Low-Low (Adverse) 1,2 3 per SG U

SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 14.4% NR Span 15.0% NR Span Coincident with Containment Pressure (EAM) 1,2 4

V SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 0.6 psig 0.5 psig and RCS Loop T 1,2 4

W SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 RCS Loop T variable input nominal trip setpoint +

2.5% RTP RCS Loop T variable input 50% RTP with Time Delay TRSR if one SG is affected (1.01)TRSR (Note 3)

TRS R(Note 3) or Time Delay TRmR if two or more SGs are affected (1.01)TRmR (Note 3)

TRm R(Note 3)

(b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

(g)

Above the P-7 (Low Power Reactor Trips Block) interlock.

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-18 Amendment 327, 343, 352 40TTable 3.3.1-1 (page 5 of 9) 40TReactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT b.

Low-Low (EAM) 1,2 3 per SG U

SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 10.1% NR Span 10.7% NR Span Coincident with RCS Loop T 1,2 4

W SR 3.3.1.1 SR 3.3.1.7P(b)(c)

SR 3.3.1.10P(b)(c)

SR 3.3.1.14 RCS Loop T variable input nominal trip setpoint +

2.5% RTP RCS Loop T variable input 50% RTP with Time Delay TRSR if one SG is affected (1.01)TRSR (Note 3)

TRS R(Note 3) or Time Delay TRmR if two or more SGs are affected (1.01)TRmR (Note 3)

TRm R(Note 3)

14. Turbine Trip a.

Low Fluid Oil Pressure 1P(h) 3 M

SR 3.3.1.10P(b)(c)

SR 3.3.1.13 710 psig 800 psig b.

Turbine Stop Valve Closure 1P(h) 4 M

SR 3.3.1.10 SR 3.3.1.13 1% open 1% open

15. Safety Injection (SI)

Input from Engineered Safety Feature Actuation System (ESFAS) 1,2 2 trains O

SR 3.3.1.12 NA NA (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

(h)

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

RTS Instrumentation 3.3.1 SEQUOYAH - UNIT 2 3.3.1-19 Amendment 327, 352 40TTable 3.3.1-1 (page 6 of 9) 40TReactor Trip System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT

16. Reactor Trip System Interlocks a.

Intermediate Range Neutron Flux, P-6 2P(f) 2 Q

SR 3.3.1.11 6 x 10P-5 P% RTP 1 x 10P-4 P%

RTP b.

Low Power Reactor Trips Block, P-7 1

1 per train R

SR 3.3.1.5 NA NA c.

Power Range Neutron Flux, P-8 1

4 R

SR 3.3.1.11 37.4% RTP 35% RTP d.

Power Range Neutron Flux, P-9 1

4 R

SR 3.3.1.11 52.4% RTP 50% RTP e.

Power Range Neutron Flux, P-10 1,2 4

Q SR 3.3.1.11 7.6% RTP and 12.4% RTP 10% RTP f.

Turbine Impulse Pressure, P-13 1

2 R

SR 3.3.1.10 12.4%

turbine power 10% turbine power

17. Reactor Trip BreakersP(i)

P 1,2 2 trains P

SR 3.3.1.4 NA NA 3P(a)

P, 4P(a)

P, 5P(a) 2 trains C

SR 3.3.1.4 NA NA

18. Reactor Trip Breaker Undervoltage and Shunt Trip Mechanisms 1,2 1 each per reactor trip breaker T

SR 3.3.1.4 NA NA 3P(a)

P, 4P(a)

P, 5P(a) 1 each per reactor trip breaker C

SR 3.3.1.4 NA NA

19. Automatic Trip Logic 1,2 2 trains O

SR 3.3.1.5 NA NA 3P(a)

P, 4P(a)

P, 5P(a) 2 trains C

SR 3.3.1.5 NA NA (a)

With Rod Control System capable of rod withdrawal or one or more rods not fully inserted.

(f)

Below the P-6 (Intermediate Range Neutron Flux) interlocks.

(i)

Including any reactor trip bypass breakers that are racked in and closed for bypassing a reactor trip breaker.

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-1 Amendment 327, 352 3.3 INSTRUMENTATION 3.3.2 Engineered Safety Feature Actuation System (ESFAS) Instrumentation LCO 3.3.2 The ESFAS instrumentation for each Function in Table 3.3.2-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.2-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one or more required channels or trains inoperable.

A.1 Enter the Condition referenced in Table 3.3.2-1 for the channel(s) or train(s).

Immediately B. One channel or train inoperable.

B.1 Restore channel or train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

C.1 Restore train to OPERABLE status.

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 D. One channel inoperable.

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

The inoperable channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

D.1 Place channel in trip.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-3 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. One Containment Pressure channel inoperable.

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

One additional channel may be bypassed for up to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for surveillance testing of other channels.

E.1 Place channel in bypass.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months F.

One channel inoperable.

F.1 Restore channel to OPERABLE status.

OR F.2 Declare the associated Main Steam Isolation Valve inoperable.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months G. One channel or train inoperable.

G.1 Restore channel or train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-4 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

H.1 Restore train to OPERABLE status.

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 I.

One channel inoperable.

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

The inoperable channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing of other channels.

I.1 For the affected protection set, the Trip Time Delay for one affected steam generator (TS) is adjusted to match the Trip Time Delay for multiple affected steam generators (TM).

AND I.2 Place channel in trip.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 6 hours OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-5 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J.

One channel inoperable.

J.1 For the affected protection set, adjust the Steam Generator Water Level -

Low-Low (EAM) channels trip setpoint to the same value as Steam Generator Water Level -- Low-Low (Adverse).

OR J.2 For the affected protection set, place the Steam Generator Water Level--

Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 6 hours K. One channel inoperable.

K.1 For the affected protection set, adjust the Trip Time Delays (TS and TM) threshold power level for zero seconds time delay to 0% RTP.

OR K.2 For the affected protection set, place the Steam Generator Water level--

Low-Low channel(s) in trip.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 6 hours OR In accordance with the Risk Informed Completion Time Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-6 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME L.

One voltage sensor channel inoperable.

L.1 Restore the inoperable channel to OPERABLE status.

OR L.2 Declare the associated auxiliary feedwater pump inoperable.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-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 M. Two or more voltage sensor channels inoperable.

OR One required load shed timer channel inoperable.

M.1.1 Restore all but one voltage sensor channel to an OPERABLE status.

AND M.1.2 Restore required load shed timer channel to an OPERABLE status.

OR M.2 Declare the associated auxiliary feedwater pump inoperable.

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

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-7 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME N.

One Main Feedwater Pumps trip channel inoperable.

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

One channel may be inoperable during MODE 1 for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months when placing the second main feedwater (MFW) pump in service or removing one of two MFW pumps from service.

N.1 Restore channel to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OR In accordance with the Risk Informed Completion Time Program O. Required Action and associated Completion Time of Condition N not met.

O.1 Be in MODE 3.

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

One channel P.1 Declare the associated auxiliary feedwater pump inoperable.

Immediately Q. One channel inoperable.

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

One additional channel may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing.

Q.1 Place channel in bypass.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months R. One or more channels inoperable.

R.1 Verify interlock is in required state for existing unit condition.

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

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-8 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME S. Required Action and associated Completion Time of Conditions B, C, or Q not met.

S.1 Be in MODE 3.

AND S.2 Be in MODE 5.

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

Required Action and associated Completion Time of Conditions D, E, G, H, I, J, K, or R not met.

T.1 Be in MODE 3.

AND T.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours U. One train inoperable.

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

One train may be bypassed for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for surveillance testing provided the other train is OPERABLE.

U.1 Be in MODE 3.

AND U.2 Be in MODE 5.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 42 hours SURVEILLANCE REQUIREMENTS

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

Refer to Table 3.3.2-1 to determine which SRs apply for each ESFAS Function.

SURVEILLANCE FREQUENCY SR 3.3.2.1 Perform CHANNEL CHECK.

In accordance with the Surveillance Frequency Control Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-9 Amendment 327, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.2 Perform ACTUATION LOGIC TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.3 Perform MASTER RELAY TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.4 Perform COT.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.5 Perform SLAVE RELAY TEST.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.6

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

Verification of relay setpoints not required.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-10 Amendment 327, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.3.2.7

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

Verification of setpoint not required for manual initiation functions.

Perform TADOT.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.8

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

This Surveillance shall include verification that the time constants are adjusted to the prescribed values.

Perform CHANNEL CALIBRATION.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.9

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

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after SG pressure is 842 psig.

Verify ESFAS RESPONSE TIMES are within limit.

In accordance with the Surveillance Frequency Control Program SR 3.3.2.10

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

Verification of setpoint not required.

Perform TADOT.

Once per reactor trip breaker cycle

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-17 Amendment 327, 352 Table 3.3.2-1 (page 7 of 9)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT 6.

Auxiliary Feedwater c.

Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

d.

Loss of Offsite Power (1) Voltage Sensors 1,2,3 3 per shutdown board(j)

L,M SR 3.3.2.6 SR 3.3.2.8(b)(c)

SR 3.3.2.9 Refer to Function 1 of Table 3.3.5-1 for setpoints and allowable values.

(2) Load Shed Timer 1,2,3 1 per shutdown board(j)

M SR 3.3.2.8(b)(c)

SR 3.3.2.9 Refer to Function 1 of Table 3.3.5-1 for setpoints and allowable values.

e.

Trip of all Main Feedwater Pumps 1,2(k) 1 per pump N

SR 3.3.2.7 SR 3.3.2.9 NA NA f.

Auxiliary Feedwater Pump Suction Transfer on Suction Pressure - Low 1,2,3 3 per pump P

SR 3.3.2.8(b)(c) 2.44 psig (motor driven pump) 12 psig (turbine driven pump) 3.21 psig (motor driven pump) 13.9 psig (turbine driven pump)

(b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

(j)

Unit 2 shutdown boards only.

(k)

When one or more Main Feedwater Pump(s) are supplying feedwater to steam generators.

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-18 Amendment 327, 352 Table 3.3.2-1 (page 8 of 9)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT 6.

Auxiliary Feedwater g.

Auxiliary Feedwater Suction Transfer Time Delays (1) Motor-Driven Pump 1,2,3 1 per pump P

SR 3.3.2.8(b)(c) 4.4 seconds and 3.6 seconds 4 seconds (2) Turbine-Driven Pump 1,2,3 2 per pump P

SR 3.3.2.8(b)(c) 6.05 seconds and 4.95 seconds 5.5 seconds 7.

Automatic Switchover to Containment Sump a.

Automatic Actuation Logic and Actuation Relays 1,2,3,4 2 trains U

SR 3.3.2.2 SR 3.3.2.3 SR 3.3.2.5 NA NA b.

RWST Level -

Low 1,2,3,4 4

Q SR 3.3.2.1 SR 3.3.2.4(b)(c)

SR 3.3.2.8(b)(c)

SR 3.3.2.9 132.71" and 127.29" from tank base 130" from tank base Coincident with Safety Injection Refer to Function 1 (Safety Injection) for all initiation functions and requirements.

and Coincident with Containment Sump Level -

High 1,2,3,4 4

Q SR 3.3.2.1 SR 3.3.2.4(b)(c)

SR 3.3.2.8(b)(c)

SR 3.3.2.9 31.68 in.

and 28.32 in.

above el.

680 ft 30 in. above el. 680 ft (b)

If the as-found channel setpoint is outside its predefined as-found tolerance, then the channel shall be evaluated to verify that it is functioning as required before returning the channel to service.

(c)

The instrument channel setpoint shall be reset to a value that is within the as-left tolerance around the Nominal Trip Setpoint (NTSP) at the completion of the surveillance; otherwise, the channel shall be declared inoperable. Setpoints more conservative than the NTSP are acceptable provided that the as-found and as-left tolerances apply to the actual setpoint implemented in the Surveillance procedures (field setting) to confirm channel performance. The methodologies used to determine the as-found and as-left tolerances are specified in UFSAR, Section 7.1.2.

ESFAS Instrumentation 3.3.2 SEQUOYAH - UNIT 2 3.3.2-19 Amendment 327, 352 Table 3.3.2-1 (page 9 of 9)

Engineered Safety Feature Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS ALLOWABLE VALUE NOMINAL TRIP SETPOINT 8.

ESFAS Interlocks a.

Reactor Trip, P-4 1,2,3 1 per train, 2 trains G

SR 3.3.2.10 NA NA b.

Pressurizer Pressure, P-11/

Not P-11 (1) Not P-11, Automatic Unblock of Safety Injection on Increasing Pressure 1,2,3 3

R SR 3.3.2.8 1975.2 psig 1970 psig (2) P-11, Enable Manual Block of Safety Injection on Decreasing Pressure 1,2,3 3

R SR 3.3.2.8 1956.8 psig 1962 psig

LOP DG Start Instrumentation 3.3.5 SEQUOYAH - UNIT 2 3.3.5-1 Amendment 327, 339, 352 3.3 INSTRUMENTATION 3.3.5 Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation LCO 3.3.5 The LOP DG start instrumentation for each Function in Table 3.3.5-1 shall be OPERABLE.

APPLICABILITY:

According to Table 3.3.5-1.

ACTIONS

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

Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions with one voltage sensor channel inoperable.

A.1 Restore the inoperable channel to OPERABLE status.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months OR In accordance with the Risk Informed Completion Time Program B. One or more Functions with two or more voltage sensor channels inoperable.

OR One or more Functions with one required timer inoperable.

B.1.1 Restore all but one voltage sensor channel to OPERABLE status.

AND B.1.2 Restore required timer to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour C. One or more unbalanced voltage relays inoperable.

C.1 Restore unbalanced voltage relays to OPERABLE status.

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

Pressurizer PORVs 3.4.11 SEQUOYAH - UNIT 2 3.4.11-1 Amendment 327, 352 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

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

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS

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

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

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs inoperable and capable of being manually cycled.

A.1 Close and maintain power to associated block valve.

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

B.1 Close associated block valve.

AND B.2 Remove power from associated block valve.

AND B.3 Restore PORV to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program

Pressurizer PORVs 3.4.11 SEQUOYAH - UNIT 2 3.4.11-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One block valve inoperable.

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

Required Actions C.1 and C.2 do not apply when block valve is inoperable solely as a result of complying with Required Action B.2 or E.2.

C.1 Place associated PORV in manual control.

AND C.2 Restore block valve to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 72 hours OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time of Condition A, B, or C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours E. Two PORVs inoperable and not capable of being manually cycled.

E.1 Close associated block valves.

AND E.2 Remove power from associated block valves.

AND E.3 Be in MODE 3.

AND E.4 Be in MODE 4.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 1 hour 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours

ECCS - Operating 3.5.2 SEQUOYAH - UNIT 2 3.5.2-1 Amendment 327, 352 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

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

1.

In MODE 3, both safety injection (SI) pump flow paths may be isolated by closing the isolation valves for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to perform pressure isolation valve testing per SR 3.4.14.1.

2.

In MODE 3, ECCS pumps may be made incapable of injecting to support transition into or from the Applicability of LCO 3.4.12, "Low Temperature Overpressure Protection (LTOP) System," for up to 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months or until the temperature of all RCS cold legs exceeds Low Temperature Overpressure Protection (LTOP) arming temperature specified in the PTLR plus 25°F, whichever comes first.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more trains inoperable.

A.1 Restore train(s) to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours C. Less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.

C.1 Enter LCO 3.0.3.

Immediately

Containment Air Locks 3.6.2 SEQUOYAH - UNIT 2 3.6.2-3 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.2 Lock an OPERABLE door closed in the affected air lock.

AND B.3

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

Air lock doors in high radiation areas may be verified locked closed by administrative means.

Verify an OPERABLE door is locked closed in the affected air lock.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Once per 31 days C. One or more containment air locks inoperable for reasons other than Condition A or B.

C.1 Initiate action to evaluate overall containment leakage rate per LCO 3.6.1.

AND C.2 Verify a door is closed in the affected air lock.

AND C.3 Restore air lock to OPERABLE status.

Immediately 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months 24 hours OR In accordance with the Risk Informed Completion Time Program D. Required Action and associated Completion Time not met.

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

Containment Isolation Valves 3.6.3 SEQUOYAH - UNIT 2 3.6.3-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more penetration flow paths with one containment isolation valve inoperable for reasons other than Conditions E, F, and G.

A.1 Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

AND 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months for Category 1 or 8 CIVs AND 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months for Category 2 or 9 CIVs AND 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months for Category 3 or 10 CIVs AND 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months for Category 4 or 11 CIVs AND 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months for Category 5 or 12 CIVs AND 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months for Category 6 or 13 CIVs AND 7 days for Category 7 or 14 CIVs OR In accordance with the Risk Informed Completion Time Program

Containment Isolation Valves 3.6.3 SEQUOYAH - UNIT 2 3.6.3-3 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.2

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

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

2. Isolation devices that are locked, sealed, or otherwise secured may be verified by use of administrative means.

Verify the affected penetration flow path is isolated.

Once per 31 days following isolation for isolation devices outside containment AND Prior to entering MODE 4 from MODE 5 if not performed within the previous 92 days for isolation devices inside containment B. ------------NOTE------------

Only applicable to penetration flow paths with two containment isolation valves.

One or more penetration flow paths with two containment isolation valves inoperable for reasons other than Conditions E, F, and G.

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

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

Containment Spray System 3.6.6 SEQUOYAH - UNIT 2 3.6.6-1 Amendment 327, 352 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray System LCO 3.6.6 Two containment spray subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

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

RHR spray trains are not required to be OPERABLE in MODE 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment spray subsystem inoperable.

A.1 Restore containment spray subsystem to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 84 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify each containment spray train manual, power operated, and automatic valve in the flow path that is not locked, sealed, or otherwise secured in position is in the correct position.

In accordance with the Surveillance Frequency Control Program

HMS 3.6.8 SEQUOYAH - UNIT 2 3.6.8-1 Amendment 327, 352 3.6 CONTAINMENT SYSTEMS 3.6.8 Hydrogen Mitigation System (HMS)

LCO 3.6.8 Two HMS trains shall be OPERABLE.

APPLICABILITY:

MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One HMS train inoperable.

A.1 Restore HMS train to OPERABLE status.

OR A.2 Perform SR 3.6.8.1 on the OPERABLE train.

7 days OR In accordance with the Risk Informed Completion Time Program Once per 7 days B. One containment region with no OPERABLE hydrogen ignitor.

B.1 Restore one hydrogen ignitor in the affected containment region to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program C. Required Action and associated Completion Time not met.

C.1 Be in MODE 3.

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

ARS 3.6.11 SEQUOYAH - UNIT 2 3.6.11-1 Amendment 327, 352 3.6 CONTAINMENT SYSTEMS 3.6.11 Air Return System (ARS)

LCO 3.6.11 Two ARS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One ARS train inoperable.

A.1 Restore ARS train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.11.1 Verify each ARS fan starts on an actual or simulated actuation signal, after a delay of 9.0 minutes and 11.0 minutes, and operates for 15 minutes.

In accordance with the Surveillance Frequency Control Program

ARS 3.6.11 SEQUOYAH - UNIT 2 3.6.11-2 Amendment 327, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.11.2 Verify, with the ARS fan dampers closed, each ARS fan motor current is 24.5 amps and 39.5 amps.

In accordance with the Surveillance Frequency Control Program SR 3.6.11.3 Verify, with the ARS fan not operating, each ARS fan damper opens when 68.1 in-lb of torque is applied to the counterweight.

In accordance with the Surveillance Frequency Control Program

MSIVs 3.7.2 SEQUOYAH - UNIT 2 3.7.2-1 Amendment 327, 352 3.7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs)

LCO 3.7.2 Four MSIVs shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when all MSIVs are closed.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One MSIV inoperable in MODE 1.

A.1 Restore MSIV to OPERABLE status.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 2.

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

Separate Condition entry is allowed for each MSIV.

One or more MSIVs inoperable in MODE 2 or 3.

C.1 Close MSIV.

AND C.2 Verify MSIV is closed.

4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months Once per 7 days D. Required Action and associated Completion Time of Condition C not met.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 12 hours

AFW System 3.7.5 SEQUOYAH - UNIT 2 3.7.5-1 Amendment 327, 352 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

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

Only one AFW train, which includes a motor driven pump, is required to be OPERABLE in MODE 4.

APPLICABILITY:

MODES 1, 2, and 3, MODE 4 when steam generator is relied upon for heat removal.

ACTIONS

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

LCO 3.0.4.b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW train inoperable due to one inoperable steam supply.

OR

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

Only applicable if MODE 2 has not been entered following refueling.

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

A.1 Restore affected equipment to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program

AFW System 3.7.5 SEQUOYAH - UNIT 2 3.7.5-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train inoperable in MODE 1, 2, or 3 for reasons other than Condition A.

B.1 Restore AFW train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program C. Turbine driven AFW train inoperable due to one inoperable steam supply.

AND One motor driven AFW train inoperable.

C.1 Restore the steam supply to the turbine driven train to OPERABLE status.

OR C.2 Restore the motor driven AFW train to OPERABLE status.

48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months 48 hours D. Required Action and associated Completion Time of Condition A, B, or C not met.

OR Two AFW trains inoperable in MODE 1, 2, or 3 for reasons other than Condition C.

D.1 Be in MODE 3.

AND D.2 Be in MODE 4.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 18 hours

AFW System 3.7.5 SEQUOYAH - UNIT 2 3.7.5-3 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Three AFW trains inoperable in MODE 1, 2, or 3.

E.1

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

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

Initiate action to restore one AFW train to OPERABLE status.

Immediately F.

Required AFW train inoperable in MODE 4.

F.1 Initiate action to restore AFW train to OPERABLE status.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1

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

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW manual, power operated, and automatic valve in each water flow path, and in both steam supply flow paths to the steam turbine driven pump, that is not locked, sealed, or otherwise secured in position, is in the correct position.

In accordance with the Surveillance Frequency Control Program

AFW System 3.7.5 SEQUOYAH - UNIT 2 3.7.5-4 Amendment 327, 352 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.7.5.2

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

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 842 psig in the steam generator.

Verify the developed head of each AFW pump at the flow test point is greater than or equal to the required developed head.

In accordance with the Inservice Testing Program SR 3.7.5.3

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

1.

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

2.

Only required to be met in MODES 1, 2, and 3.

Verify each AFW automatic valve that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

In accordance with the Surveillance Frequency Control Program SR 3.7.5.4

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

1.

Not required to be performed for the turbine driven AFW pump until 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months after 842 psig in the steam generator.

2.

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

3.

Only required to be met in MODES 1, 2, and 3.

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

In accordance with the Surveillance Frequency Control Program

CCS 3.7.7 SEQUOYAH - UNIT 2 3.7.7-1 Amendment 327, 352 3.7 PLANT SYSTEMS 3.7.7 Component Cooling Water System (CCS)

LCO 3.7.7 Two CCS trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One CCS train inoperable.

A.1

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

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

MODE 4," for residual heat removal loops made inoperable by CCS.

Restore CCS train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time of Condition A not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

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

ERCW System 3.7.8 SEQUOYAH - UNIT 2 3.7.8-2 Amendment 327 329, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One ERCW System train inoperable for reasons other than Condition A.

B.1

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

1. Enter applicable Conditions and Required Actions of LCO 3.8.1, "AC Sources - Operating,"

for emergency diesel generator made inoperable by ERCW System.

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

Restore ERCW System train to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program C. Required Action and associated Completion Time of Condition A or B not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

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

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 2 3.8.1-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME A.3 Restore offsite circuit to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program B. One or more Train A DG(s) inoperable.

OR One or more Train B DG(s) inoperable.

B.1 Perform SR 3.8.1.1 for the offsite circuits.

AND B.2 Declare required feature(s) supported by the inoperable DG inoperable when its required redundant feature(s) is inoperable.

AND B.3.1 Determine OPERABLE DGs are not inoperable due to common cause failure.

OR B.3.2 Perform SR 3.8.1.2 for OPERABLE DGs.

AND B.4 Restore DG(s) to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months from discovery of Condition B concurrent with inoperability of redundant required feature(s) 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months 24 hours 7 days OR

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 2 3.8.1-3 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME In accordance with the Risk Informed Completion Time Program C. One offsite circuit inoperable solely due to an offsite power source to 6.9 kV Shutdown Board 2A-A or 2B-B inoperable.

C.1 Perform SR 3.8.1.1 for OPERABLE offsite circuit.

AND C.2 Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

AND C.3 Restore offsite circuit to OPERABLE status.

1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to 6.9 kV Shutdown Board 2A-A or 2B-B concurrent with inoperability of redundant required feature(s) 7 days OR In accordance with the Risk Informed Completion Time Program

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 2 3.8.1-4 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. Two offsite circuits inoperable.

D.1 Declare required feature(s) inoperable when its redundant required feature(s) is inoperable.

AND D.2 Restore one offsite circuit to OPERABLE status.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months from discovery of Condition D concurrent with inoperability of redundant required features 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months OR In accordance with the Risk Informed Completion Time Program E. One offsite circuit inoperable for reasons other than Condition C.

AND DG 2A-A or 2B-B inoperable.

E.1 Restore offsite circuit to OPERABLE status.

OR E.2 Restore DG to OPERABLE status.

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 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

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 2 3.8.1-5 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

One or more Train A DG(s) inoperable.

AND One or more Train B DG(s) inoperable.

F.1 Restore one train of DGs to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months G. Required Action and associated Completion Time of Condition A, B, C, D, E, or F not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours H. Two offsite circuits inoperable.

AND One or more Train A DG(s) inoperable.

OR One or more Train B DG(s) inoperable.

H.1 Enter LCO 3.0.3.

Immediately I.

One offsite circuit inoperable.

AND One or more Train A DG(s) inoperable.

AND One or more Train B DG(s) inoperable.

I.1 Enter LCO 3.0.3.

Immediately

AC Sources - Operating 3.8.1 SEQUOYAH - UNIT 2 3.8.1-6 Amendment 327, 334, 352 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.1.1 Verify correct breaker alignment and indicated power availability for each offsite circuit.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.2

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

1.

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

2.

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 6800 V and 7260 V, and frequency 59.8 Hz and 60.2 Hz.

In accordance with the Surveillance Frequency Control Program SR 3.8.1.3

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

1.

DG loadings may include gradual loading as recommended by the manufacturer.

2.

Momentary transients outside the load range do not invalidate this test.

3.

This Surveillance shall be conducted on only one DG at a time.

4.

This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7.

Verify each DG is synchronized and loaded and operates for 60 minutes at a load 3960 kW and 4400 kW.

In accordance with the Surveillance Frequency Control Program

DC Sources - Operating 3.8.4 SEQUOYAH - UNIT 2 3.8.4-1 Amendment 327, 352 3.8 ELECTRICAL POWER SYSTEMS 3.8.4 DC Sources - Operating LCO 3.8.4 Two Vital DC electrical power trains and four diesel generator (DG) DC electrical power subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or two vital battery chargers on one train inoperable.

A.1 Restore battery terminal voltage to greater than or equal to the minimum established float voltage.

AND A.2 Verify battery float current 2 amps.

AND A.3 Restore vital battery chargers to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 7 days OR In accordance with the Risk Informed Completion Time Program B. One vital DC electrical power train inoperable for reasons other than Condition A.

B.1 Restore vital DC electrical power train to OPERABLE status.

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

DC Sources - Operating 3.8.4 SEQUOYAH - UNIT 2 3.8.4-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required Action and Associated Completion Time of Condition A or B not met.

C.1 Be in MODE 3.

AND C.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours D. One or more DG DC electrical power subsystem(s) inoperable.

D.1 Declare associated DG(s) inoperable.

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

In accordance with the Surveillance Frequency Control Program SR 3.8.4.2 Verify each vital battery charger supplies 150 amps at greater than or equal to the minimum established float voltage for 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months .

OR Verify each vital battery charger can recharge the battery to the fully charged state within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months while supplying the largest combined demands of the various continuous steady state loads, after a battery discharge to the bounding design basis event discharge state.

In accordance with the Surveillance Frequency Control Program

Inverters - Operating 3.8.7 SEQUOYAH - UNIT 2 3.8.7-1 Amendment 327, 352 3.8 ELECTRICAL POWER SYSTEMS 3.8.7 Inverters - Operating LCO 3.8.7 The required Train A and Train B inverters shall be OPERABLE.

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

Two inverters may be disconnected from their associated DC source for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to perform an equalizing charge on their associated common battery, provided:

a.

The associated AC vital instrument power board(s) are energized from their inverter using internal AC source, and b.

All other AC vital instrument power boards are energized from their associated OPERABLE inverters connected to their DC source.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required inverter inoperable.

A.1

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

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems - Operating" with any AC vital instrument power board de-energized.

Restore inverter to OPERABLE status.

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

Inverters - Operating 3.8.7 SEQUOYAH - UNIT 2 3.8.7-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.7.1 Verify correct inverter voltage, frequency, and alignment to required AC vital instrument power boards.

In accordance with the Surveillance Frequency Control Program

Distribution Systems - Operating 3.8.9 SEQUOYAH - UNIT 2 3.8.9-1 Amendment 327, 352 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 Two electrical power distribution trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more AC electrical power distribution subsystems inoperable due to one or more Unit 2 AC shutdown boards inoperable.

A.1

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

Enter applicable Conditions and Required Actions of LCO 3.8.4, "DC Sources -

Operating," for vital DC electrical power trains made inoperable by inoperable AC electrical power distribution subsystems.

Restore Unit 2 AC electrical power distribution subsystem(s) to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program B. One or more AC vital instrument power distribution subsystems inoperable.

B.1 Restore AC vital instrument power distribution subsystem(s) to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months OR In accordance with the Risk Informed Completion Time Program

Distribution Systems - Operating 3.8.9 SEQUOYAH - UNIT 2 3.8.9-2 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One or more vital DC electrical power distribution subsystems inoperable.

C.1 Restore vital DC electrical power distribution subsystem(s) to OPERABLE status.

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

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

1.

Only applicable during planned maintenance.

2.

Only applicable when Unit 1 is defueled or in MODE 6 following defueled with Unit 1 refueling water cavity level 23 ft. above top of reactor vessel flange.

D. One or more AC electrical power distribution subsystems inoperable due to one or more Unit 1 AC shutdown boards inoperable.

D.1 Declare associated required feature(s) inoperable.

Immediately E. One or more AC electrical power distribution subsystems inoperable due to one or more Unit 1 AC shutdown boards inoperable for reasons other than Condition D.

E.1 Restore Unit 1 AC electrical power distribution subsystem(s) to OPERABLE status.

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

One or more DG DC electrical power distribution panels inoperable.

F.1 Declare associated supported DG inoperable.

Immediately

Distribution Systems - Operating 3.8.9 SEQUOYAH - UNIT 2 3.8.9-3 Amendment 327, 352 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Required Action and associated Completion Time not met.

G.1 Be in MODE 3.

AND G.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours H. Two or more electrical power distribution subsystems inoperable that result in a loss of safety function.

H.1 Enter LCO 3.0.3.

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

In accordance with the Surveillance Frequency Control Program

Programs and Manuals 5.5 SEQUOYAH - UNIT 2 5.5-17 Amendment 327, 352 5.5 Programs and Manuals 5.5.16 Control Room Envelope (CRE) Habitability Program (continued) f.

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

5.5.17 Surveillance Frequency Control Program This program provides controls for Surveillance Frequencies. The program shall ensure that Surveillance Requirements specified in the Technical Specifications are performed at intervals sufficient to assure the associated Limiting Conditions for Operation are met.

a.

The Surveillance Frequency Control Program shall contain a list of Frequencies of those Surveillance Requirements for which the Frequency is controlled by the program.

b.

Changes to the Frequencies listed in the Surveillance Frequency Control Program shall be made in accordance with NEI 04-10, "Risk-Informed Method for Control of Surveillance Frequencies," Revision 1.

c.

The provisions of Surveillance Requirements 3.0.2 and 3.0.3 are applicable to the Frequencies established in the Surveillance Frequency Control Program.

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

a.

The RICT may not exceed 30 days; b.

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

When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1.

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

Programs and Manuals 5.5 SEQUOYAH - UNIT

5.5-18 Amendment 352 2.

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

3.

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

G

For emergent conditions, if the extent of condition evaluation forinoperable structures, systems, or components (SSCs) is not completeprior to exceeding the Completion Time, the RICT shall account for theincreased possibility of common cause failure (CCF) by either:

Numerically accounting for the increased possibility of CCF in the

RICT calculation; or

Risk Management Actions (RMAs) not already credited in theRICT calculation shall be implemented that support redundant ordiverse SSCs that perform the function(s) of the inoperable SSCs,and, if practicable, reduce the frequency of initiating events thatchallenge the function(s) performed by the inoperable SSCs.

7KHULVNDVVHVVPHQWDSSURDFKHVDQGPHWKRGVVKDOOEHDFFHSWDEOHWRWKH

15&7KHSODQW35$VKDOOEHEDVHGRQWKHDVEXLOWDVRSHUDWHGDQG

PDLQWDLQHGSODQWDQGUHIOHFWWKHRSHUDWLQJH[SHULHQFHDWWKHSODQWDV

VSHFLILHGLQ5HJXODWRU\\*XLGH5HYLVLRQ0HWKRGVWRDVVHVVWKH

ULVNIURPH[WHQGLQJWKH&RPSOHWLRQ7LPHVPXVWEH35$PHWKRGVDSSURYHG

IRUXVHZLWKWKLVSURJUDPRURWKHUPHWKRGVDSSURYHGE\\WKH15&IRU

JHQHULFXVHDQGDQ\\FKDQJHLQWKH35$PHWKRGVWRDVVHVVULVNWKDWDUH

RXWVLGHWKHVHDSSURYDOERXQGDULHVUHTXLUHSULRU15&DSSURYDO

H

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 358 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-77 AND AMENDMENT NO. 352 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-79 TENNESSEE VALLEY AUTHORITY SEQUOYAH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-327 AND 50-328

1.0 INTRODUCTION

By application dated August 5, 2021 [1], Tennessee Valley Authority (TVA, the licensee) submitted a license amendment request (LAR) for Sequoyah Nuclear Plant, Units 1 and 2 (Sequoyah). The amendments would revise technical specification (TS) requirements to permit the use of risk-informed completion times (RICTs) for actions to be taken when limiting conditions for operation (LCOs) are not met. The proposed changes are based on Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, dated July 2, 2018 [2]. The U.S. Nuclear Regulatory Commission (NRC or the Commission) issued a final model safety evaluation (SE) approving TSTF-505, Revision 2, on November 21, 2018 [3].

The licensee has proposed variations from the TS changes approved in TSTF-505, Revision 2, which are provided in Section 2.3 of the LAR and evaluated in Section 3.2.1 of this SE.

The NRC staff participated in a regulatory audit from September 30, 2021, through March 31, 2022 [4], to ascertain the information needed to support its review of the application and to develop requests for additional information (RAIs), as needed. On April 27, 2022, the NRC staff issued an audit summary [5]. Following the regulatory audit, TVA submitted a supplement letter dated April 28, 2022 [6], that included additional information resulting from the audit. On May 13, 2022 [7] and July 1, 2022 [8], TVA submitted additional supplemental letters.

The supplemental letters provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staffs original proposed no significant hazards consideration determination as published in the Federal Register on October 5, 2021 (86 FR 55013).

2.0 REGULATORY EVALUATION

Title 10 of the Federal Code of Regulations (10 CFR) Part 50 provides the general provisions for Domestic Licensing of Production and Utilization Facilities. The general provisions include but are not limited to establishing the regulatory requirements that a licensee must adhere to for the submittal of a license application. The NRC staff has identified the following applicable Sections within 10 CFR Part 50, along with the provision provided in 10 CFR Part 20 for the staffs review of a licensees application to adopt TSTF-505, Revision 2.

10 CFR 50.36, Technical Specifications, including paragraphs 50.36 (b), (c)(2), and (c)(5) 10 CFR 50.55a(h), Protection and Safety Systems of 10 CFR 50.55.55a, Codes and Standards 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants (i.e., the Maintenance Rule) 10 CFR Part 20, Standard for Protection Against Radiation NRC Regulatory Guides (RGs) provide one way to ensure that the codified regulations continue to be met. The NRC staff considered the following guidance, along with industry guidance endorsed by the NRC, during its review of the proposed changes:

Regulatory Guide 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities [9].

RG 1.174, Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis [10].

RG 1.177, Revision 2, Plant-Specific, Risk-Informed Decision-making: Technical Specifications [11].

NUREG-1855, Revision 1, Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decisionmaking [12].

Nuclear Energy Institute (NEI) Topical Report (TR) 06-09-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines [13], provides guidance for risk-informed TS. The NRC staff issued a final model SE approving NEI 06-09 with limitation and conditions on May 17, 2007 [14]. NEI issued NEI 06-09-A which incorporates NRC limitations and conditions.

The licensees submittal cites Revision 2 of RG 1.200 [9]. The RG has been updated to Revision 3 of RG 1.200 [15]. The update does not include any technical changes that would impact the consistency with NEI 06-09-A [13], therefore the NRC staff finds the updated revision to RG 1.200 also applicable for use in the licensees adoption of TSTF-505, Revision 2.

2.1 Description of Risk-Informed Completion Time Program The TS LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO is not met, the licensee must shut down the reactor or follow any remedial or required action (e.g., testing, maintenance, or repair activity) permitted by the TSs until the condition can be met. The remedial actions (i.e., ACTIONS) associated with an LCO contain conditions that typically describe the ways in which the requirements of the LCO can fail to be met. Specified with each stated Condition are Required Action(s) and Completion Time(s) (CT). The CTs are referred to as the front stops in the context of this SE. For certain conditions, the TSs require exiting the Mode of Applicability of an LCO (i.e., shut down the reactor).

The licensees submittal requested approval to add a RICT program to the Administrative Controls Section of the TS, and modify selected CTs to permit extending the CTs, provided risk is assessed and managed as described in NEI 06-09-A.

The effect of the proposed changes when implemented will allow CTs to vary, based on the risk significance of the given plant configuration (i.e., the equipment out-of-service at any given time), provided that the system(s) retain(s) the capability to perform the applicable safety function(s) without any further failures (e.g., one train of a two-train system is inoperable). These restrictions on inoperability of all required trains of a system ensure that consistency with the defense-in-depth (D-I-D) philosophy is maintained by following existing guidance when the capability to perform TS safety function(s) is lost.

The proposed RICT program uses plant-specific operating experience for component reliability and availability data. Thus, the allowances permitted by the RICT program are directly reflective of actual component performance in conjunction with component risk significance.

For TS use and application:

Example 1.3-8, will be added to TS 1.3, CTs, and will read as follows:

EXAMPLE 1.3-8 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.

A.1 Restore subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 5.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 36 hours When a subsystem is declared inoperable, Condition A is entered.

The 7 day Completion Time may be applied as discussed in Example 1.3-2. However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time.

The RICT cannot exceed 30 days. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.

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

If the 7 day Completion Time clock of Condition A has expired and subsequent changes in plant condition result in exiting the applicability of the Risk Informed Completion Time Program without restoring the inoperable subsystem to OPERABLE status, Condition B is also entered, and the Completion Time clocks for Required Actions B.1 and B.2 start.

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

3.0 TECHNICAL EVALUATION

An acceptable approach for making risk-informed decisions about proposed TS changes, including both permanent and temporary changes, is to demonstrate that the proposed licensing basis (LB) changes meet the five key principles provided in Section C of RG 1.174, and the three-tiered approach outlined in Section C of RG 1.177. These key principles and tiers are:

Principle 1:

The proposed LB change meets the current regulations unless it is explicitly related to a requested exemption.

Principle 2:

The proposed LB change is consistent with the defense in depth (D-I-D) philosophy.

Principle 3:

The proposed LB change maintains sufficient safety margins.

Principle 4:

When the proposed LB change results in an increase in risk, the increase should be small and consistent with the intent of the Commissions policy statement on safety goals for the operations of nuclear power plants.

Tier 1: PRA Capability and Insights Tier 2: Avoidance of Risk-Significant Plant Configurations Tier 3: Risk-Informed Configuration Risk Management Principle 5:

The impact of the proposed LB change should be monitored by using performance measures strategies.

3.1 Method of Staff Review Each of the key principles and tiers are addressed in NEI 06-09-A and approved in the final model safety evaluation issued by the NRC for TSTF-505, Revision 2. The industry guidance provides a methodology for extending existing CTs, and thereby, delay exiting the operational mode of applicability or taking Required Actions if risk is assessed and managed within the limits and programmatic requirements established by a RICT program. The NRC staffs evaluation of the licensees proposed use of RICTs against the key safety principles of RG 1.174 and RG 1.177 is discussed below.

3.2 Review of Key Principles 3.2.1 Key Principle 1: Evaluation of Compliance with Current Regulations Paragraph 50.36(c)(2) of 10 CFR requires that LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the condition can be met.

The CTs in the current TSs were established using experiential data, risk insights, and engineering judgement. The RICT program provides the necessary administrative controls to permit extension of CTs and, thereby, delay reactor shutdown or Required Actions, if risk is assessed and managed appropriately within specified limits and programmatic requirements and the safety margins and D-I-D remains sufficient. The option to determine the extended CT in accordance with the RICT program allows the licensee to perform an integrated evaluation in accordance with the methodology prescribed in NEI 06-09-A and TS 5.5.18. The RICT is limited to a maximum of 30 days (termed the back stop).

The typical CT is modified by the application of the RICT program as shown in the following example. The changed portion is indicated in italics.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.

A.1 Restore subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program In Attachment 2 and Enclosure 1 of the LAR, as supplemented, the licensee provided a list of the TSs, associated LCOs, and Required Actions for the CTs that included modifications and variations from the approved TSTF-505. The modifications and variations consisted of proposed changes to the Required Actions and CTs. The NRC staff reviewed the proposed changes to the TS, associated LCOs, Required Actions and CTs provided by the licensee for the scope of the RICT program and concluded, with the incorporation of the RICT program, that the required performance levels of equipment specified in LCOs are not changed, only the required CT for the Required Actions are modified, such that 10 CFR 50.36(c)(2) will remain met. Based on the discussion provided above, the NRC staff finds that the TS program provided in Section 2.0 of this SE, LCOs, Required Actions, and CTs meet the first key principle of RG 1.174 and RG 1.177.

3.2.2 Key Principle 2: Evaluation of Defense in Depth (D-I-D)

In RG 1.174, the NRC identified the following considerations used for evaluation of how the LB change is maintained for the D-I-D philosophy:

Preserve a reasonable balance among the layers of defense.

Preserve adequate capability of design features without an overreliance on programmatic activities as compensatory measures.

Preserve system redundancy, independence, and diversity commensurate with the expected frequency and consequences of challenges to the system, including consideration of uncertainty.

Preserve adequate defense against potential common cause failures (CCFs).

Maintain multiple fission product barriers.

Preserve sufficient defense against human errors.

Continue to meet the intent of the plants design criteria.

The licensee requested to use the RICT program to extend the existing CTs for the respective TS LCOs prescribed in Attachment 2 of the LAR, as supplemented. For the TS LCOs in, Section 3, Evaluation of Instrumentation and Control Systems, of the LAR, as supplemented [6], the licensee provided a description and assessment of the redundancy and diversity for the proposed changes. The NRC staffs evaluation of the proposed changes for these LCOs assessed Sequoyahs redundant or diverse means to mitigate accidents to ensure consistency with the plant LB requirements using the guidance prescribed in RG 1.174, RG 1.177, and TSTF-505, to ensure adequate D-I-D (for each of the functions) to operate the facility in the proposed manner (i.e., that the changes are consistent with the D-I-D criteria).

of the LAR, as supplemented [6], provided information supporting the Sequoyah evaluation of the redundancy, diversity, and D-I-D for each TS LCO and TS Required Action as it related to instrumentation and controls (I&C) and electrical power systems. The NRC staff confirmed that for the following TS LCOs, the above D-I-D criteria were applicable except for the criteria for maintaining multiple fission product barriers.

TS 3.3.1, Reactor Trip System (RPS) Instrumentation [I&C specific]

TS 3.3.2.2, Engineered Safety Feature Actuation System (ESFAS) Instrumentation [I&C specific]

TS 3.3.5, Loss of Power (LOP) Diesel Generator (DG) Start Instrumentation [electrical specific]

TS 3.8.1, AC [Alternating Current] Sources - Operating [power-related]

TS 3.8.4, DC [Direct Current] Sources - Operating [power-related]

TS 3.8.7, Inverters - Operating [electrical-related]

TS 3.8.9, Distribution Systems - Operating [power-related]

For the TS LCOs specific to I&C, the NRC staff reviewed the specific trip logic arrangements, redundancy, backup systems, manual actions, and diverse trips specified for each of the protective safety functions and associated instrumentation as described in the associated Updated Final Safety Analysis Report (UFSAR) [16] sections, and as reflected in Enclosure 1 of the LAR, as supplemented [6], for each I&C LCO above. The NRC staff verified, that in accordance with the Sequoyah UFSAR and equipment and actions credited in Enclosure 1 of the LAR, as supplemented [6], in all applicable operating modes, the affected protective feature would perform its intended function by ensuring the ability to detect and mitigate the associated event or accident when the CT of a channel is extended. Furthermore, the NRC staff concludes that there is sufficient redundancy, diversity, and D-I-D, to protect against CCFs and potential single failure for the Sequoyah instrumentation systems evaluated in Enclosure 1 of the LAR, as supplemented [6], during a RICT. There is at least one diverse means specified by the licensee for initiating mitigating action for each accident event, thus providing D-I-D against a failure of instrumentation during the RICT for each TS LCO. The D-I-D specified by the licensee does not overly rely on manual actions as the diverse means; therefore, there is not over-reliance of programmatic activities as compensatory measures. Therefore, the NRC staff finds that the intent of the plants design criteria (e.g., safety functions) for the above TS LCOs related to I&C are maintained.

For the TS Section 3.8 LCOs specific to electrical power systems, the Sequoyah UFSAR states that they are designed such that their safety functions are maintained assuming a single failure.

Since the LAR changes are only for extensions to electrical LCO CTs, a review of the electrical power systems design was not necessary. The NRC staff reviewed the LAR, and its supplements for the proposed CT extensions for the 11 TS Section 3.8 LCOs for each unit that covers offsite power systems, emergency diesel generators (EDGs), direct current (DC) sources, inverters, and distribution systems (alternating current (AC) electrical power, AC vital instrument power, and vital DC electrical power). The NRC staff reviewed each unit independently to verify their LCOs (with some nuances for each unit) can be entered voluntarily or involuntarily into the RICT program in accordance with NEI 06-09-A, as identified in the LAR.

Based on staffs evaluations of the electrical power systems affected by each LCO, the NRC staff determined that the capability of those affected electrical power systems to perform their safety functions (assuming no additional failures) is maintained given the CT extensions and decreased redundancy for each electrical LCO. The NRC staff verified that the design success criteria in LAR Table E1-1 for the affected TS LCOs reflect the absolute minimum electrical power source required to be operable to support the safety functions necessary to mitigate postulated design-basis accidents (DBAs), safely shutdown the reactor, and maintain the reactor in a safe shutdown condition. In addition, the NRC staff reviewed the risk management action (RMA) examples that provide reasonable assurance that the appropriate RMAs will be implemented to monitor and control risk for each LCO. The NRC staff finds that the intent of the plants design criteria (e.g., safety functions) applicable to the electrical power systems for TS Section 3.8 LCOs referred to above are maintained.

The NRC staff notes that while in a TS LCO condition, the redundancy of the function will be temporarily relaxed and, consequently, the system reliability will be degraded accordingly. The NRC staff examined the design information from the Sequoyah UFSAR and the risk-informed TS LCO conditions for the affected safety functions. Based on this information, the NRC staff confirmed that under any given DBA evaluated in the Sequoyah UFSAR, the affected protective features maintain adequate D-I-D.

Considering that the CT extensions will be implemented in accordance with the NEI 06-09-A guidance, that also considers RMAs, and the redundancy of the offsite and onsite power system, the NRC staff finds that the plant will maintain adequate defense-in-depth. Therefore, the NRC staff finds that the TS LCOs proposed by the licensee in Attachment 2 of the LAR, as supplemented, are acceptable for the RICT program.

The NRC staff reviewed all TS LCOs proposed by the licensee in Attachment 2 of the LAR, as supplemented, and concludes that the proposed changes do not alter the ways in which the Sequoyah systems fail, do not introduce new CCF modes, and the system independence is maintained. The NRC staff finds that some proposed changes reduce the level of redundancy of the affected systems, and this reduction may reduce the level of defense against some CCFs; however, such reductions in redundancy and defense against CCFs are acceptable due to existing diverse means available to maintain adequate D-I-D against a potential single failure during a RICT. The NRC staff finds that extending the selected CTs with the RICT program following loss of redundancy, but maintaining the capability of the system to perform its safety function, is an acceptable reduction in D-I-D during the proposed RICT period provided that the licensee identifies and implements compensatory measures in accordance with the RICT program during the extended CT.

Based on the above, the NRC staff finds that the licensees proposed changes are consistent with the NRC-endorsed guidance prescribed in NEI 06-09-A and satisfy the second key principle in RG 1.174 and RG 1.177. Additionally, the NRC staff concludes that the changes are consistent with the D-I-D philosophy as described in RG 1.174.

3.2.3 Key Principle 3: Evaluation of Safety Margins Paragraph 50.55a(h) of 10 CFR (Codes and Standards) requires in part, that protection systems of nuclear power reactors of all types must meet the requirements specified in this paragraph. Section 2.2.2 of RG 1.177 states, in part, that sufficient safety margins are maintained when:

Codes and standards or alternatives approved for use by the NRC are met.

Safety analysis acceptance criteria in the final safety analysis report are met or proposed revisions provide sufficient margin to account for analysis and data uncertainties.

The licensee is not proposing in this application to change any quality standard, material, or operating specification. In the LAR, the licensee proposed to add a new program, Risk Informed Completion Time Program, in Section 5.0, Administrative Controls, of the TSs, which would require adherence NEI 06-09-A.

The NRC staff evaluated the effect on safety margins when the RICT is applied to extend the CT up to a backstop of 30 days in a TS condition with sufficient trains remaining operable to fulfill the TS safety function. Although the licensee will be able to have design-basis equipment out of service longer than the current TS allow, any increase in unavailability is expected to be insignificant and is addressed by the consideration of the single failure criterion in the design-basis analyses. Acceptance criteria for operability of equipment are not changed and, if sufficient trains remain operable to fulfill the TS safety function, the operability of the remaining train(s) ensures that the current safety margins are maintained. The NRC staff finds that if the specified TS safety function remains operable, sufficient safety margins would be maintained during the extended CT of the RICT program.

Safety margins are also maintained if PRA functionality is determined for the inoperable train which would result in an increased CT. Credit for PRA functionality, as described in NEI 06-09-A, is limited to the inoperable train, LOOP, or component.

Based on the above, the NRC staff finds that the design-basis analyses for Sequoyah remains applicable and unchanged, sufficient safety margins would be maintained during the extended CT and the proposed changes to the TSs do not include any change in the standards applied or the safety analysis acceptance criteria. The NRC staff concludes that the proposed changes meet 10 CFR 50.55a(h), and therefore, the third key principle in RG 1.174 and RG 1.177.

3.2.4 Key Principle 4: Change in Risk Consistent with the Safety Goal Policy Statement NEI 06-09-A provides a methodology for a licensee to evaluate and manage the risk impact of extensions to TS CTs. Permanent changes to the fixed TS CTs are typically evaluated by using the three-tiered approach described in Chapter 16.1 of the Standard Review Plan [17],

RG 1.177, and RG 1.174. This approach addresses the calculated change in risk as measured by the change in core damage frequency (CDF) and large early release frequency (LERF), as well as the incremental conditional core damage probability and incremental conditional large early release probability; the use of compensatory measures to reduce risk; and the implementation of a configuration risk management program (CRMP) to identify risk-significant plant configurations.

The NRC staff evaluated the licensees processes and methodologies for determining that the change in risk from implementation of RICTs will be small and consistent with the intent of the Commissions Safety Goal Policy Statement. In addition, the NRC staff evaluated the licensees proposed changes against the three-tiered approach in RG 1.177 for the licensees evaluation of the risk associated with a proposed TS CT change. The results of the NRC staffs review are discussed below.

3.2.4.1 Tier 1: PRA Capability and Insights The first tier evaluates the impact of the proposed changes on plant operational risk. The Tier 1 review involves two aspects: (1) scope and acceptability of the PRA models and their application to the proposed changes, and (2) a review of the PRA results and insights described in the licensees application.

Enclosures 2 and 4 of the LAR identified the following modeled hazards and alternate methodologies the licensee proposed to be used in the Sequoyah RICT program to assess the risk contribution for extending the CT of a TS LCO.

Internal Events PRA model (includes internal floods)

Internal Fire Events PRA model Seismic Hazard PRA model Other External Hazards: screened out from RICT program based on Appendix 6A of the American Society of Mechanical Engineers (ASME)/American Nuclear Society (ANS)

RA-Sa-2009 PRA Standard Evaluation of Internal Events and Fire PRA Models The internal events PRA (IEPRA) and fire PRA (FPRA) models supporting the RICT program are discussed in Enclosure 2 of the LAR, as supplemented [6]. The licensee stated that the PRA models had been peer reviewed using the ASME/ANS RA-Sa-2009 PRA Standard [18], as endorsed by RG 1.200, Revision 2. In Enclosure 2 of the LAR, in combination with previously docketed information relevant to the NRC staffs review of the IEPRA for Sequoyahs adoption of 10 CFR 50.69, Risk-Informed Categorization of Treatment of Structures, Systems, and Components in Nuclear Power Reactors [19], the licensee stated that the Sequoyah IEPRA model received a full-scope peer review in January 2011 using NEI 05-04 [20], the ASME/ANS RA-Sa-2009 PRA Standard, and RG 1.200, Revision 2. Subsequently, in May 2017, the licensee conducted an Independent Assessment for closure of the finding-level facts and observations (F&Os) and concluded that all IEPRA (including internal flooding) F&Os had been closed. The F&Os closure review was performed in accordance with Appendix X to NEI 05-04, 07-12, and 12-13 [21], as accepted with conditions by the NRC staff in its May 3, 2017 letter

[22]. NRC staff has previously reviewed the Independent Assessment report [19]. The NRC staff finds that the Sequoyah IEPRA (includes internal floods) was appropriately peer reviewed consistent with RG 1.200, Revision 2, F&Os reviewed consistent with Appendix X guidance, as accepted, and all F&O findings have been closed. Therefore, the NRC staff concludes that the Sequoyah IEPRA (including internal flooding) is acceptable for use in the RICT program.

Based on Enclosure 2 of the LAR, the licensees FPRA model received a full-scope peer review using NEI 07-12 [23], the ASME/ANS PRA Standard RA-Sa-2009, and RG 1.200, Revision 2.

The F&Os identified from the FPRA peer review were addressed during a subsequent update of the FPRA. In April 2020, the licensee conducted an Independent Assessment for closure of the F&Os in accordance with Appendix X, as accepted with conditions by the NRC staff [22]. As a result of the Independent Assessment, all F&O findings from the full-scope peer review have been closed. Supporting requirements of ASME/ANS RA-Sa-2009 that were originally found to be NOT MET or MET at capability category (CC) I were assessed to be MET at CC-II or better.

NRC staff reviewed the Independent Assessment and concluded that all F&Os were appropriately assessed to assure that no new methods and/or upgrades were inadvertently incorporated into the FPRA without a peer review in accordance with the ASME/ANS RA-Sa-2009 PRA standard as endorsed by the NRC. Based on its review of the LAR submittal, as supplemented [6], related to the FPRA, the NRC staff finds that the Sequoyah FPRA was appropriately peer reviewed consistent with RG 1.200, Revision 2, fire methodologies were appropriately considered and implemented, and all F&O findings were closed consistent with Appendix X. Therefore, the Sequoyah FPRA is acceptable for use in the RICT program.

In Enclosure 9 of the LAR, as supplemented [6], the licensee provided a discussion of potential key assumptions and sources of uncertainty, along with treatment for the application of TSTF-505. The licensee discussed PRA modeling of FLEX strategies and associated uncertainties. The NRC staff concluded that the credit for FLEX equipment in the TSTF-505 application is appropriate because the licensee used consensus human reliability analysis methodologies and practices, acceptable failure rates, and performed sensitivity studies to assess the impact on the TSTF-505 application. The licensee discussed PRA modeling of the digital I&C process protection system (i.e., Eagle-21). The NRC staff concluded that modeling of the digital Eagle-21 system in the TSTF-505 application is appropriate because: (1) the licensee demonstrated that changes in the failure probabilities of the Eagle-21 surrogate events have an inconsequential impact on the RICT calculations for representative TS LCO conditions most impacted by the treatment, (2) modeling of the Eagle-21 system includes consideration of CCF events, and (3) the licensee justified that CCF failure across multiple channels and functions due to software failure associated with an overarching function is not credible.

The NRC staff reviewed the PRA models peer review history provided by the licensee in of the LAR, as supplemented. The licensee adequately applied the guidance for establishing PRA technical acceptability for the aforementioned models. The NRC staff further considered the key assumptions and key sources of uncertainty identified by the licensee, proposed use of surrogates in the PRA models for specific TS functions, and credit for FLEX.

Therefore, the NRC staff finds the Sequoyah IEPRA and FPRA models to be acceptable commensurate with the RICT application. As such, their use in the integrated decision-making process are consistent with RG 1.174.

Evaluation of Seismic PRA Model The seismic PRA (SPRA) model supporting the RICT program is discussed in Section 5 of to the LAR [1], as supplemented [6] [7] [8]. The licensee stated that the SPRA model had been peer reviewed against the requirements of Part 5 of ASME/ANS RA-Sb-2013 (Addendum B of the PRA Standard) [24], which is not endorsed by RG 1.200, Revision 2. The licensee concluded that all but six of Addendum B supporting requirements (SRs) have been shown to either be equal to the corresponding Addendum A SRs or envelop the corresponding Addendum A SRs. The licensee then provided the assessment of the remaining six SRs that Sequoyah conforms to Addendum A in a table of the same section [25]. Based on its review, the NRC staff finds that the licensees use of Part 5 of Addendum B adequately addresses the technical elements for the development of an SPRA. Therefore, the NRC staff concludes that the use of Part 5 of Addendum B is an acceptable alternative to the NRC-endorsed approach for the licensee's SPRA used to support this application.

The licensee stated that the Sequoyah SPRA model received a full-scope peer review in April 2018 using NEI guidelines NEI 12-13, with a total of 53 unique finding level F&Os generated. Subsequently, in February 2019, the licensee conducted an Independent Assessment and Focused-Scope Peer Review for closure of all 53 F&Os. The F&Os closure review was performed in accordance with Appendix X to NEI 05-04, 07-12, and 12-13. In its supplement dated April 28, 2022 [6], the licensee further explained that four of the seven seismic hazard analysis (SHA) findings were assessed to be upgrades, which required a focused-scope peer review. All four reviewed SRs were assessed to be met and three new F&Os (two findings and one suggestion) were generated. The three F&Os were ultimately closed in the April 1, 2019, F&O closure review. Based on its review, the NRC staff finds that the Sequoyah SPRA was appropriately peer reviewed consistent with RG 1.200, Revision 2, F&Os reviewed consistent with Appendix X guidance, as accepted, and all F&O findings have been closed. Therefore, the NRC staff concludes that the Sequoyah SPRA is acceptable for use in the RICT program.

In its supplement dated April 28, 2022 [6], the licensee explained that the difference of SCDF and SLERF values between the SPRA submittal [26] and this LAR is mainly due to SPRA model improvement. The updated Sequoyah SPRA model was incorporated into the one-top multi-hazard model (OTMHM), which calculates the SCDF and SLERF values used in this LAR. The OTMHM will be used in the Phoenix Real-Time Risk Model to calculate RICT. In its supplement dated July 1, 2022 [8], the licensee stated that it identified an error in preparing the computer-aided fault tree analysis (CAFTA) database for the UNCERT computer code calculations. This error led to the failure to sample the seismic fragility basic events and seismic bin (initiator) basic events. The licensee provided updated results showing that the mean seismic CDF and LERF are about 30 to 40% higher, respectively, than the corresponding point estimates. The licensee re-evaluated the impact of state-of-knowledge correlation (SOKC) on this application and concluded that the updated mean seismic CDF and mean seismic LERF values do not impact the RICT calculations. The NRC staff finds that the licensee identified and corrected its error resulting in the difference between the updated mean and point estimate becoming reasonable and consistent with a recent peer reviewed SPRA supporting a 10 CFR 50.69 application and that the SOKC does not impact this application.

In Enclosure 9 of the LAR, the licensee provided a discussion of potential key assumptions and sources of uncertainty, along with treatment for the application of TSTF-505. The licensee concluded that there are no key sources of uncertainty in the SPRA. The licensee discussed SPRA modeling of FLEX strategies, assessed risk significance based on sensitivity studies for the fragility of the FLEX diesel components, and concluded that the seismic risk is relatively insensitive to the fragility of FLEX diesel generators. The NRC staff finds that the credit for FLEX equipment in the TSTF-505 application is appropriate because the licensee used consensus human reliability analysis methodologies and practices, acceptable failure rates, and performed sensitivity studies to assess the impact on the TSTF-505 application.

In summary, the NRC staff reviewed the SPRA model peer review history provided by the licensee in Enclosure 2 of the LAR, as supplemented. The licensee adequately applied the guidance for establishing SPRA technical acceptability. The NRC staff further considered the key assumptions and sources of uncertainty identified by the licensee for its SPRA and credit for FLEX. Therefore, the NRC staff finds the Sequoyah SPRA model to be acceptable for use in the RICT application.

Evaluation of Other External Hazards Besides the seismic hazard discussed above, the licensee confirmed that other external hazards for Sequoyah have an insignificant contribution to risk and proposed these hazards be screened from the RICT program. The licensee provided its evaluation of external hazards for the RICT program and also evaluated configuration-specific impacts on the RICT program for these hazards.

The licensees high wind evaluation was based on the design of the SSCs and a site-specific tornado missile analysis. The licensee concluded that all non-missile extreme wind hazards and tornado missile hazards could be screened from consideration for the TSTF-505 application based on EXT-B2 of ASME/ANS RA-Sa-2009, which is screening criterion PS2 (i.e., design basis for the event meets the criteria in the NRC 1975 Standard Review Plan). The NRC staff reviewed the licensees evaluation of the extreme wind and tornado hazards and finds that the licensee appropriately considered the risk from extreme winds and tornadoes in the proposed RICTs and that the extreme winds and tornado hazards have an insignificant contribution to configuration risk and can be excluded from the calculation of the proposed RICTs.

The licensee provided its evaluation of the external flooding hazard based on the licensees time available to shut the plant down and implement emergency procedures. The licensee stated that Sequoyah warning time is sufficient to screen out external flooding hazard using the criterion C5 (i.e., event develops slowly, allowing adequate time to eliminate or mitigate the threat). The licensee concluded that the external flooding hazard could be screened from consideration for the TSTF-505 application based on EXT-B1 Criterion 5 of ASME/ANS RA-Sa-2009, which is screening criterion C5. In the second supplement [7], the licensee confirmed that the existing early warning time of 27 hours3.125e-4 days 0.0075 hours 4.464286e-5 weeks 1.02735e-5 months provides adequate time to prepare the plant for an external flood.

The NRC staff reviewed the licensees evaluation of the external flooding hazard and finds that the licensee appropriately considered the risk from external flooding in the proposed RICTs. The staff also finds that the external flooding hazard has an insignificant contribution to configuration risk and can be excluded from the calculation of the proposed RICTs. The NRC staff also finds that plant procedures exist to ensure that the flood protection features will be available during RICTs to manage the external flooding risk in the RICT program.

The licensee provided its evaluation of all other external hazards in Table E4-1 of Enclosure 4 to the LAR. The NRC staff notes that the list of hazards assessed is essentially the same list of hazards as presented in Table 4-1 of NUREG-1855, Revision 1 [12]. The licensee provided a screening disposition for each external hazard and concluded that no unique PRA model for these hazards is required in order to assess configuration risk for the RICT program. The NRC staff notes that the preliminary screening criteria and progressive screening criteria used is the same criteria presented in supporting requirements EXT-B1, EXT-B2, and EXT-C1 of the ASME/ANS PRA Standard.

Based on the NRC staffs review of the information provided by the licensee, the staff finds that the contributions from the other external hazards have an insignificant contribution to configuration risk and can be excluded from the calculation of the proposed RICTs because they either do not challenge the plant or they are bounded by the external hazards analyzed for the plant.

Application of PRA Models, Results and Insights in the RICT Program The Sequoyah base PRA models that have been determined to be acceptable in this SE will be modified as an application specific-PRA model (i.e., CRMP tool) that will be used to analyze the risk for an extended CT. The CRMP model produces results (i.e., risk metrics) that are consistent with the NEI 06-09-A guidance. The LAR, as supplemented [6], provided all information needed to support the requested LCO actions proposed for the Sequoyah RICT program consistent with the Limitations and Conditions prescribed in Section 4.0 of NRCs final safety evaluation incorporated in NEI 06-09-A.

The NRC staff did not identify any insufficiencies in the licensees information or the CRMP tool as described in Enclosure 8 of the LAR, as supplemented [6]. Furthermore, the Sequoyah design criteria of the applicable systems are maintained, and the changes requested in the LAR do not physically change the applicable systems. The NRC staff finds that the Sequoyah PRA models and CRMP tool used will continue to reflect the as--built, as--operated plant consistent with RG 1.200, Revision 2 for ensuring PRA acceptability is maintained. Therefore, the NRC staff concludes that the proposed application of the Sequoyah RICT program is appropriate for use in the adoption of TSTF-505 for performing RICT calculations.

The licensee provided in Enclosure 5 of the submittal the estimated total CDF and LERF of the base PRA models to demonstrate that Sequoyah meets the 1E-4/year CDF and 1E-5/year LERF criteria of RG 1.174 consistent with the guidance in NEI 06-09-A and that these guidelines will be satisfied for implementation of a RICT.

The licensee has incorporated NEI 06-09-A into TS 5.5.18. The estimated current total CDF and LERF for Sequoyah PRAs meet the RG 1.174 guidelines, therefore, the NRC staff concludes the PRA results and insights to be used by the licensee in the RICT program will continue to be consistent with NEI 06-09-A.

Tier 1 Conclusions Based on the above conclusions, the NRC staff finds that the licensee has satisfied the intent of Tier 1 in RG 1.177 for determining the acceptability of the PRA, including the scope of the PRA models (i.e., IEPRA, FPRA, SPRA) and the evaluation of other external hazards, and is appropriate for this application.

3.2.4.2 Tier 2: Avoidance of Risk-Significant Plant Configurations As prescribed in RG 1.177, the second tier evaluates the capability of the licensee to identify and avoid risk-significant plant configurations that could result if equipment, in addition to that associated with the proposed change, is taken out of service simultaneously or if other risk-significant operational factors, such as concurrent system or equipment testing, are also involved. In Section 2 of Enclosure 10 of the LAR, the licensee confirmed that the risk thresholds associated with 10 CFR 50.65(a)(4) will be coordinated with the RICT limits. 2 of the LAR identifies three kinds of RMAs (i.e., actions to provide increased risk awareness and control, actions to reduce the duration of maintenance activities, and actions to minimize the magnitude of the risk increase). The LAR, as supplemented [6], also explains that RMAs will be implemented in accordance with current plant procedures and no later than the time at which the 1E-06 incremental core damage probability (ICDP) or 1E-07 incremental large early release probability (ILERP) threshold is reached and under emergent conditions when the instantaneous CDF and LERF thresholds are exceeded.

The NRC staff concludes that the Tier 2 attributes of the proposed RICT program, including the limits established for entry into a RICT and implementation of RMAs, are consistent with NEI 06-09-A. Therefore, the proposed changes are consistent with the intent of Tier 2 in RG 1.177.

3.2.4.3 Tier 3: Risk-Informed Configuration Risk Management The third tier stipulates that the licensee should develop a program that ensures the risk impact of out-of-service equipment is appropriately evaluated prior to performing any maintenance activity. The proposed RICT program establishes a CRMP based on the underlying PRA models. The CRMP is then used to evaluate configuration-specific risk for planned activities associated with the RMTS extended CT, as well as emergent conditions which may arise during an extended CT. This required assessment of configuration risk, along with the implementation of compensatory measures and RMAs, is consistent with the principle of Tier 3 for assessing and managing the risk impact of out-of-service equipment.

Paragraph 50.36(c)(5) of 10 CFR identifies administrative controls as the provisions relating to organization and management, procedures, [thereby] assuring operation of the facility in a safe manner. In Enclosure 8 of the submittal, Attributes of the Real-Time Model, as supplemented [6], the licensee confirmed that future changes made to the baseline PRA models and changes made to the online model (i.e., CRMP) are controlled and documented by plant procedures. Enclosure 10 of the LAR provided the attributes that the licensees RICT program procedures will address, which are consistent with NEI 06-09-A. The NRC staff finds that the licensee has identified appropriate administrative controls consistent with NEI 06-09-A and 10 CFR 50.36(c)(5).

Based on the licensees incorporation of NEI 06-09-A in the TS (discussed in LAR ) and its use of RMAs (discussed in LAR Enclosure 12), and because the proposed changes are consistent with the Tier 3 guidance of RG 1.177, the NRC staff finds the licensees Tier 3 program is acceptable and supports the proposed implementation of the RICT program.

3.2.4.4 Key Principle 4: Conclusions The licensee has demonstrated the technical acceptability and scope of its PRA models and alternative methods, including consideration of the impact of seismic events, extreme winds and tornado hazards, and other external hazards, and that the models can support implementation of the RICT program for determining extensions to CTs. The licensee has made proper consideration of key assumptions and sources of uncertainty. The risk metrics are consistent with the approved methodology of NEI 06-09-A and the acceptance guidance in RG 1.177 and RG 1.174. The RICT program will be controlled administratively through plant procedures and training and follows the NRC-approved methodology in NEI 06-09-A. The NRC staff concludes that the RICT program satisfies the fourth key principle of RG 1.174 and RG 1.177, and therefore, is acceptable.

3.2.5 Key Principle 5: Performance Measurement Strategies - Implementation and Monitoring RG 1.174 and RG 1.177 establish the need for an implementation and monitoring program to ensure that extensions to TS CTs do not degrade operational safety over time and that no adverse degradation occurs due to unanticipated degradation or common cause mechanisms. 1 of the LAR, as supplemented [6], states, the SSCs in scope of the RICT program are also in the scope of 10 CFR 50.65 for the Maintenance Rule. The Maintenance Rule monitoring programs will provide for evaluation and disposition of unavailability impacts which may be incurred from implementation of the RICT program. Furthermore, in Enclosure 11 of the LAR, the licensee confirmed that the cumulative risk is calculated at least every refueling cycle, but the recalculation period does not exceed 24 months, which is consistent with NEI 06-09-A.

The NRC staff concludes that the RICT program satisfies the fifth key principle of RG 1.174 and RG 1.177 because: (1) the RICT program will monitor the average annual cumulative risk increase as described in NEI 06-09-A, thereby, ensuring the program, as implemented, continues to meet RG 1.174 guidance for small risk increases; and (2) all affected SSCs are within the Maintenance Rule program, which is used to monitor changes to the reliability and availability of these SSCs.

4.0 CHANGES TO OPERATING LICENSE In its letter dated August 5, 2021 [1], the licensee proposed amendments to the Renewed Facility Operation Licenses for Sequoyah, Units 1 and 2, as follows:

The proposed amendment would modify the Technical Specification (TS) requirements related to Completion Times (CTs) for Required Actions to provide the option to calculate a longer, risk-informed CT (RICT). A new program, the Risk Informed Completion Time Program, is added to TS Section 5, Administrative Controls.

The methodology for using the RICT Program is described in NEI 06-09-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, Revision 0, which was approved by the NRC on May 17, 2007. Adherence to NEI 06-09-A is required by the RICT Program.

The proposed amendment is consistent with TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b. However, only those Required Actions described in Attachment 5 and Enclosure 1, as reflected in the proposed TS markups provided in Attachments 2.1 and 2.2, are proposed to be changed, because some of the modified Required Actions in TSTF-505 are not applicable to the Sequoyah Nuclear Plant (SQN), and there are some plant-specific Required Actions not included in TSTF-505 that are included in this proposed amendment.

By letter dated May 13, 2022 [7], the regulatory commitment listed in LAR Attachment 6 regarding external flooding hazard was closed by the licensee.

5.0 TECHNICAL CONCLUSION The NRC staff has evaluated the proposed changes against each of the five key principles in RG 1.174 and RG 1.177, including the optional variations from the approved TSTF-505 discussed in Section 3.2.1 of this SE. The NRC staff concludes that the changes proposed by the licensee satisfy the key principles of risk-informed decision-making identified in RG 1.174 and RG 1.177, and therefore, the requested adoption of the proposed changes to the TSs is acceptable to assure that the Commissions regulations continue to be met.

Based on the considerations discussed above, the NRC staff concludes that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

6.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Tennessee State official was notified of the proposed issuance of the amendments on July 12, 2022. The State official had no comments.

7.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on October 4, 2021 (86 FR 55013). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

8.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

9.0 REFERENCES

[1] Polickoski, James T., Tennessee Valley Authority, letter to U.S. Nuclear Regulatory Commission, "Sequoyah Nuclear Plant, Units 1 and 2, License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, 'Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b' (SQN-TS-20-03)," dated August 5, 2021 (ADAMS Accession No. ML21217A174).

[2] U.S. Nuclear Regulatory Commission, "TSTF-505, Revision 2, TSTF Comments on Draft Safety Evaluation for Traveler TSTF-505, Provide Risk-Informed Extended Completion Times and Submittal of TSTF-505, Revision 2," dated July 2, 2018 (ADAMS Package Accession No. ML18183A493).

[3] U.S. Nuclear Regulatory Commission, "Final Revised Model Safety Evaluation of Traveler TSTF-505, Revision 2, Provide Risk Informed Extended Completion Times - RITSTF Initiative 4B," dated November 21, 2018 (ADAMS Package Accession No. ML18269A041).

[4] Buckberg, Perry, U.S. Nuclear Regulatory Commission, letter to Barstow, James, Tennessee Valley Authority, "Sequoyah Nuclear Plant, Units 1 and 2 - Regulatory Audit in Support of Review of the Application to Adopt Risk-Informed Extended Completion Times

- RITSTF Initiative 4b (EPID L-2021-LLA-0145)," dated September 15, 2021 (ADAMS Accession No. ML21246A053).

[5] Buckberg, Perry H., U.S. Nuclear Regulatory Commission, letter to Tennessee Valley Authority, "Sequoyah Nuclear Plant, Units 1 and 2 - Summary of Regulatory Audit Regarding the License Amendment Request to Revise Technical Specifications to Adopt TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b'," dated April 27, 2022 (ADAMS Accession No. ML22108A282).

[6] Barstow, James, Tennessee Valley Authority, letter to U.S. Nuclear Regulatory Commission, "Sequoyah Nuclear Plant, Units 1 and 2, Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, (SQN-TS-20-03) EPID L-2021-LLA-0145," dated April 28, 2022 (ADAMS Accession No. ML22118A496).

[7] Polickoski, James, Tennessee Valley Authority, letter to U.S. Nuclear Regulatory Commission, "Sequoyah Nuclear Plant, Units 1 and 2, Second Supplement to License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, (SQN-TS-20-03) EPID L-2021-LLA-0145," dated May 13, 2022 (ADAMS Accession No. ML22133A238).

[8] Barstow, James, Tennessee Valley Authority, letter to U.S. Nuclear Regulatory Commission, Sequoyah Nuclear Plant, Units 1 and 2, "Response to Request for Additional Information Regarding License Amendment Request to Revise Technical Specifications to Adopt Risk-Informed Completion Times TSTF-505, Revision 2, 'Provide Risk-Informed Completion Times - RITSTF Initiative 4b'," dated July 1, 2022 (ADAMS Accession No. ML22182A390), (SQN-TS-20-03) EPID L-2021-LLA-0145.

[9] U.S. Nuclear Regulatory Commission, Regulatory Guide 1.200, Revision 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," dated March 2009 (ADAMS Accession No. ML090410014).

[10] U.S. Nuclear Regulatory Commission, Regulatory Guide 1.174, Revision 3, "An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis," dated January 2018 (ADAMS Accession No. ML17317A256).

[11] U.S. Nuclear Regulatory Commission, Regulatory Guide 1.177, Revision 2, "Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications," dated January 2021 (ADAMS Accession No. ML20164A034).

[12] U.S. Nuclear Regulatory Commission, NUREG-1855, Revision 1, "Guidance on the Treatment of Uncertainties Associated with PRAs in Risk-Informed Decisionmaking, Final Report," March 2017 (ADAMS Accession No. ML17062A466).

[13] Nuclear Energy Institute (NEI) Topical Report NEI 06-09, Revision 0-A, "Risk-Informed Technical Specifications Initiative 4b: Risk Managed Technical Specifications (RMTS)

Guidelines," dated October 2012 (ADAMS Accession No. ML122860402).

[14] U.S. Nuclear Regulatory Commission, "Final Safety Evaluation For Nuclear Energy Institute (NEI) Topical Report (TR) NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," dated May 17, 2007 (ADAMS Accession No. ML071200238).

[15] U.S. Nuclear Regulatory Commission, Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities," dated December 2020 (ADAMS Accession No. ML20238B871).

[16] Tennessee Valley Authority, Updated Final Safety Analysis Report, "Sequoyah Nuclear Plant, Units 1 and 2, Renewed Facility Operating License Nos. DPR-77 and DPR-79, NRC Docket Nos. 50-327 and 50-328, Updated Final Safety Analysis Report Amendment 30,"

dated April 28, 2022 (ADAMS Package Accession No. ML22118A333).

[17] U.S. Nuclear Regulatory Commission, NUREG 0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Chapter 16.1, "Risk-Informed Decision Making: Technical Specifications," dated March 2007 (ADAMS Accession No. ML070380228).

[18] American Society of Mechanical Engineers, ASME/ANS RA-Sa-2009, "Addenda to ASME/ANS RA-S-2008, Standard for Level 1/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications," February 2009.

[19] Hon, Andrew, U.S. Nuclear Regulatory Commission, letter to Barstow, James, Tennessee Valley Authority, "Sequoyah Nuclear Plant, Units 1 and 2 - Issuance of Amendment Nos.

346 and 340, RE: Request to Adopt 10 CFR 50.69, 'Risk-Informed Categorization and Treatment of Structures, Systems, and Components for Nuclear Power Reactors' (EPID L-2018-LLA-0066)," dated September 18, 2019 (ADAMS Accession No. ML19179A135).

[20] Nuclear Energy Institute, NEI 05-04, Revision 2, "Process for Performing Internal Events PRA Peer Reviews Using the ASME/ANS PRA Standard," dated November 2008 (ADAMS Accession No. ML083430462).

[21] Andersen, Victoria, Nuclear Energy Institute, letter to Rosenberg, Stacey, U.S. Nuclear Regulatory Commission, "Final Revision of Appendix X to NEI 05-04/07-12/12-[13], Close-Out of Facts and Observations," dated February 21, 2017 (ADAMS Package Accession No. ML17086A431).

[22] U.S. Nuclear Regulatory Commission, letter to Greg Krueger, Nuclear Energy Institute, "U.S. Nuclear Regulatory Commission Acceptance on Nuclear Energy Institute Appendix X to Guidance 05-04, 07-12 and 12-13, Closeout of Facts and Observations (F&Os)," dated May 3, 2017 (ADAMS Accession No. ML17079A427).

[23] Nuclear Energy Institute, NEI 07-12, Revision 1, "Fire Probabilistic Risk Assessment (FPRA) Peer Review Process Guidelines," dated June 2010 (ADAMS Accession No. ML102230070).

[24] ASME/ANS RA-Sb-2013, "Standard for Level l/Large Early Release Frequency Probabilistic Risk Assessment for Nuclear Power Plant Applications, Addendum B to RA-S-2008," American Society of Mechanical Engineers, New York, NY, American Nuclear Society, La Grange Park, Illinois, July 2013.

[25] Orenak, Michhael, U.S. Nuclear Regulatory Commission, letter to Gayheart, Cheryl A.,

Southern Nuclear Operating Company, Inc., "Vogtle Electric Generation Plant, Units 1 and 2 - Issuance of Amendments Regarding Application of Seismic Probabilistic Risk Assessment into the Previously Approved 10 CFR 50.69 Categorization Process (EPID L-2017-LLA-0248)," dated August 10, 2018 (ADAMS Accession No. ML18180A062).

[26] Polickoski, James T., Tennessee Valley Authority, letter to U.S. Nuclear Regulatory Commission, Seismic Probabilistic Risk Assessment for Sequoyah Nuclear Plant, Unit 1 and 2, "Response to NRC Request for Information Pursuant to Title 10 of the Code of Federal Regulations 50.54(f) Regarding Recommendation 2.1 of the Near-Term Task Force Review of Insights from the Fukushima Dai-ichi Accident (CNL-19-061)," dated October 18, 2019 (ADAMS Accession No. ML19291A003).

[27] U.S. Nuclear Regulatory Commission, NUREG 0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants," Chapter 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance," dated June 2007 (ADAMS Accession No. ML071700658).

Principal Contributors: T. Hilsmeier, NRR J. Patel, NRR N. Iqbal, NRR T. Dinh, NRR D. Wu, NRR K. Tetter, NRR A. Foli, NRR E. Kleeh, NRR N. Carte, NRR B. Gurjendra, NRR H. Wagage, NRR S. Sun, NRR K. West, NRR Date: August 24, 2022

ML22210A118 OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2/LA NRR/DRA/APLA/BC NRR/DRA/APLB/BC NAME PBuckberg RButler RPascarelli JWhitman DATE 8/2/2022 08/02/2022 6/23/2022 7/27/2022 OFFICE NRR/DRA/APLC/BC NRR/DSS/STSB/BC NRR/DSS/SCPB/BC NRR/DEX/EICB/BC NAME SRosenberg (SVasavda for)

VCusumano BWittick MWaters DATE 7/29/2022 7/20/2022 7/7/2022 8/3/2022 OFFICE NRR/DEX/EEEB/BC NRR/DEX/EMIB/BC NRR/DNRL/NPHP OGC - NLO NAME WMorton SBailey MMitchell LShrum DATE 6/7/2022 7/19/2022 7/5/2022 8/10/2022 OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME DWrona PBuckberg DATE 8/19/2022 8/24/2022

v t e Letter Sequence Approval
EPID:L-2021-LLA-0145, Technical Specifications Task Force (Approved, Closed)
Initiation Request, Request, Request Acceptance Supplement, Supplement Administration Questions 26 May 2022 Answers 1 July 2022 Results Approval, Approval, Approval, Approval, Approval, Approval Other: ML22108A282, ML22196A073, ML22259A204
MONTHYEAR2022-03-22 [Table View]

ML22210A118

Text

SUBJECT:

Dear Mr. Barstow:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

6.0 STATE CONSULTATION

7.0 ENVIRONMENTAL CONSIDERATION

8.0 CONCLUSION

9.0 REFERENCES

Navigation menu

Search