Text

Issuance of Amendment Nos. 212 and 210 Regarding Shutdown Actions
	ML26008A021
Person / Time
Site:	Vogtle ; (NFP-091, NPF-092)
Issue date:	02/03/2026
From:	Geoffrey Miller; NRC/NRR/DORL/LPL2-1
To:	Coleman J; Southern Nuclear Operating Co
References
	EPID L-2025-LLA-0011
	Download: ML26008A021 (0)
	v • d • e

February 3, 2026 Jamie Coleman Regulatory Affairs Director Southern Nuclear Operating Company, Inc.

3535 Colonnade Parkway, Bin N-274-EC Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 ISSUANCE OF AMENDMENT NOS. 212 AND 210 REGARDING SHUTDOWN ACTIONS (EPID NO. L-2025-LLA-0011)

Dear Ms. Coleman:

In response to your application dated January 23, 2025, as supplemented by letters dated October 31 and December 18, 2025, the U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 212 and 210 to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, respectively. The amendments revise the technical specifications (TSs) related to required actions during shutdown modes.

A copy of the related Safety Evaluation, which includes the NRC staffs evaluation of the amendment, is enclosed. The notice of issuance of the amendment documents included in this letter will be published in the Federal Register.

In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS).

ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.

J. Coleman If you have questions, please contact me at 301-415-2481 or ed.miller@nrc.gov.

Sincerely,

/RA/

G. Edward Miller, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 52-025 and 52-026

Enclosures:

1.

Amendment No. 212 to Vogtle, Unit 3, COL 2.

Amendment No. 210 to Vogtle, Unit 4, COL 3.

Safety Evaluation cc: Listserv SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 DOCKET NO.52-025 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 212 License No. NPF-91 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Southern Nuclear Operating Company (SNC),

dated January 23, 2025, as supplemented by letters dated October 31 and December 18, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will be constructed and 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 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.

The License is also amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment.

Paragraph 2.D(8) of facility Combined License No. NPF-91 is hereby amendment to read as follows:

(8) Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 212, are hereby incorporated into this license.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance. Implementation of the amendment shall include updating the Updated Final Safety Analysis Report (UFSAR) in accordance with 10 CFR 50.71 (e). The UFSAR update shall include a statement that the licensee shall implement the changes to the outage risk assessment monitoring procedure and the shutdown defense-in-depth software tool as described in the responses to Requests for Additional Information in the letters dated October 31 (ML25304A235) and December 18, 2025 (ML25353A427).

FOR THE NUCLEAR REGULATORY COMMISSION:

Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: February 3, 2026

Attachment:

1. Page 4 of the facility Combined License and affected pages of Appendix A of the facility Combined License MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2026.02.03 10:30:38 -05'00' SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 4 DOCKET NO.52-026 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 210 License No. NPF-92 1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Southern Nuclear Operating Company (SNC),

dated January 23, 2025, as supplemented by letters dated October 31 and December 18, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will be constructed and 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 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.

The License is also amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment.

Paragraph 2.D(8) of facility Combined License No. NPF-92 is hereby amendment to read as follows:

(8) Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 210, are hereby incorporated into this license.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance. Implementation of the amendment shall include updating the Updated Final Safety Analysis Report (UFSAR) in accordance with 10 CFR 50.71 (e). The UFSAR update shall include a statement that the licensee shall implement the changes to the outage risk assessment monitoring procedure and the shutdown defense-in-depth software tool as described in the responses to Requests for Additional Information in the letters dated October 31(ML25304A235) and December 18, 2025 (ML25353A427).

FOR THE NUCLEAR REGULATORY COMMISSION:

Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Date of Issuance: February 3, 2026

Attachment:

Page 4 of the facility Combined License and affected pages of Appendix C of the facility Combined License MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2026.02.03 10:31:34 -05'00'

ATTACHMENT TO LICENSE AMENDMENT NOS. 212 AND 210 TO FACILITY COMBINED LICENSE NOS. NPF-91 AND NPF-92 DOCKET NOS.52-025 AND 52-026 Replace the following pages of the facility combined licenses and Technical Specifications with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License License No. NPF-91, page 4 License No. NPF-91, page 4 License No. NPF-92, page 4 License No. NPF-92, page 4 TSs TSs 3.3.8-4 3.3.8-4 3.3.8-5 3.3.8-5 3.3.8-8 3.3.8-8 3.3.9-2 3.3.9-2 3.3.9-3 3.3.9-3 3.3.9-4 3.3.9-4 3.3.9-5 3.3.9-5 3.3.9-6 3.3.9-6 3.3.10-2 3.3.10-2 3.3.10-3 3.3.10-3 3.3.16-2 3.3.16-2 3.4.12-2 3.4.12-2 3.4.13-2 3.4.13-2 3.4.13-3 3.4.13-3 3.5.3-1 3.5.3-1 3.5.3-2 3.5.3-2 3.5.3-3 3.5.5-1 3.5.5-1 3.5.5-2 3.5.5-2 3.5.7-2 3.5.7-2 3.5.8-2 3.5.8-2 3.6.4-1 3.6.4-1 3.6.5-1 3.6.5-1 3.6.6-2 3.6.6-2 3.6.6-3 3.6.6-3 3.6.7-2 3.6.7-2 3.6.9-3 3.6.9-3

D.

The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:

(1)

Changes during Construction - Removed by Amendment No. 202 (2)

Pre-operational Testing - Removed by Amendment Nos. 192 and 202 (3)

Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos. 192 and 202 (4)

Initial Criticality and Low-Power Testing - Removed by Amendment No. 202 (5)

Power Ascension Testing - Removed by Amendment No. 202 (6)

Maximum Power Level (7)

(8)

SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.

Reporting Requirements - Removed by Amendment No. 202 Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 212, are hereby incorporated into this license.

(9)

Technical Specifications - Removed by Amendment No. 202 (10)

Operational Program Implementation - Removed by Amendment No. 202 (11)

Operational Program Implementation Schedule - Removed by Amendment No.202 (12)

Site-and Unit-specific Conditions - Removed by Amendment No. 202

[Blank Pages 5 through 14 removed by Amendment No. 202.]

4 Amendment No. 212

D.

The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:

(1)

Changes during Construction - Removed by Amendment No. 199 (2)

Pre-operational Testing - Removed by Amendment Nos. 194 and 199 (3)

Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos. 194 and 199 (4)

Initial Criticality and Low-Power Testing - Removed by Amendment No. 199 (5)

Power Ascension Testing - Removed by Amendment No. 199 (6)

Maximum Power Level (7)

(8)

SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.

Reporting Requirements - Removed by Amendment No. 199 Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 210, are hereby incorporated into this license.

(9)

Technical Specifications - Removed by Amendment No. 199 (10)

Operational Program Implementation - Removed by Amendment No. 199 (11)

Operational Program Implementation Schedule - Removed by Amendment No. 199 (12)

Site-and Unit-specific Conditions - Removed by Amendment No. 199

[Blank Pages 5 through 14 removed by Amendment No. 199.]

4 Amendment No. 210

Technical Specifications ESFAS Instrumentation 3.3.8 VEGP Units 3 and 4 3.3.8 - 4 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME J.

As required by Required Action C.1 and referenced in Table 3.3.8-1.

J.1 Be in MODE 5.

37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months with three or more inoperable channels AND 180 hours0.00208 days 0.05 hours 2.97619e-4 weeks 6.849e-5 months AND J.2 Initiate action to restore channel(s) to OPERABLE status.

37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months with three or more inoperable channels AND 180 hours0.00208 days 0.05 hours 2.97619e-4 weeks 6.849e-5 months K.

As required by Required Action C.1 and referenced in Table 3.3.8-1.

K.1 Suspend positive reactivity additions.

Immediately AND K.2 Initiate action to restore channel(s) to OPERABLE status.

Immediately L.

Not Used.

M.

As required by Required Action C.1 and referenced in Table 3.3.8-1.

M.1 Suspend positive reactivity additions.

Immediately AND M.2 Be in MODE 5.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND M.3 Initiate action to restore channel(s) to OPERABLE status.

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

Technical Specifications ESFAS Instrumentation 3.3.8 VEGP Units 3 and 4 3.3.8 - 5 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME N.

Not Used.

O.

As required by Required Action C.1 and referenced in Table 3.3.8-1.

O.1 Declare affected isolation valve(s) inoperable.

Immediately AND O.2 Be in MODE 3.

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

As required by Required Action C.1 and referenced in Table 3.3.8-1.

P.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND P.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months AND P.3 Initiate action to restore channel(s) to OPERABLE status.

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

As required by Required Action C.1 and referenced in Table 3.3.8-1.

Q.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND Q.2 Be in MODE 4 with at least one cold leg temperature 275°F.

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

Technical Specifications ESFAS Instrumentation 3.3.8 VEGP Units 3 and 4 3.3.8 - 8 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

Table 3.3.8-1 (page 2 of 3)

Engineered Safeguards Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS

14. RCS Wide Range Pressure - Low 1,2,3,4 4

H 5

4 K

6(g) 4 K

15. Core Makeup Tank (CMT) Level - Low 3 1,2,3,4(b) 4 per tank F

4(d),5(h) 4 per OPERABLE tank J

16. CMT Level - Low 6 1,2,3,4(b) 4 per tank F

4(d),5(h) 4 per OPERABLE tank J

17. Source Range Neutron Flux Doubling 3(i),4(j) 4 I

5(j) 4 I

18. IRWST Lower Narrow Range Level - Low 3 1,2,3,4(b) 4 F

4(d),5 4

M 6(g) 4 K

19. Reactor Coolant Pump Bearing Water Temperature - High 2 1,2,3,4 4 per RCP O

20. SG Narrow Range Water Level - Low 2 1,2,3,4(b) 4 per SG F

21. SG Wide Range Water Level - Low 2 1,2,3,4(b) 4 per SG F

22. SG Narrow Range Water Level - High 1,2,3,4 4 per SG I

23. SG Narrow Range Water Level - High 3 1,2 4 per SG D

3,4 4 per SG I

(b) With the RCS not being cooled by the Normal Residual Heat Removal System (RNS).

(d) With the RCS being cooled by the RNS.

(g) With upper internals in place.

(h) With RCS not VENTED.

(i) With unborated water source flow paths not isolated except during intentional approach to criticality.

(j) With unborated water source flow paths not isolated.

Technical Specifications ESFAS Manual Initiation 3.3.9 VEGP Units 3 and 4 3.3.9 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

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

OR One or more Functions with two channels inoperable.

C.1 Enter the Condition referenced in Table 3.3.9-1 for the channel(s).

Immediately D.

As required by Required Action C.1 and referenced in Table 3.3.9-1.

D.1 AND D.2 Be in MODE 3.

Be in MODE 4 with the Reactor Coolant System (RCS) cooling provided by the Normal Residual Heat Removal System (RNS).

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 24 hours E.

As required by Required Action C.1 and referenced in Table 3.3.9-1.

E.1 AND E.2 Be in MODE 3.

Be in MODE 5.

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

As required by Required Action C.1 and referenced in Table 3.3.9-1.

F.1 Declare affected isolation valve(s) inoperable.

Immediately G.

As required by Required Action C.1 and referenced in Table 3.3.9-1.

G.1 AND G.2 Be in MODE 5.

Initiate action to restore channel(s) to OPERABLE status.

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

Technical Specifications ESFAS Manual Initiation 3.3.9 VEGP Units 3 and 4 3.3.9 - 3 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME H.

As required by Required Action C.1 and referenced in Table 3.3.9-1.

H.1 Suspend positive reactivity additions.

Immediately AND H.2 Initiate action to restore channel(s) to OPERABLE status.

Immediately I.

Not Used.

J.

As required by Required Action C.1 and referenced in Table 3.3.9-1.

J.1 Suspend positive reactivity additions.

Immediately AND J.2 Be in MODE 5.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND J.3 Initiate action to restore channel(s) to OPERABLE status.

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

Not Used.

L.

As required by Required Action C.1 and referenced in Table 3.3.9-1.

L.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND L.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months AND L.3 Initiate action to restore channel(s) to OPERABLE status.

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

Technical Specifications ESFAS Manual Initiation 3.3.9 VEGP Units 3 and 4 3.3.9 - 4 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.3.9.1

- NOTE -

Verification of setpoint not required.

Perform TRIP ACTUATING DEVICE OPERATIONAL TEST (TADOT).

24 months

Technical Specifications ESFAS Manual Initiation 3.3.9 VEGP Units 3 and 4 3.3.9 - 5 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

Table 3.3.9-1 (page 1 of 2)

Engineered Safeguards Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS

1.

Safeguards Actuation - Manual Initiation 1,2,3,4 2 switches E

5 2 switches J

2.

Core Makeup Tank (CMT) Actuation - Manual Initiation 1,2,3,4(a) 2 switches D

4(b), 5(d) 2 switches G

3.

Containment Isolation - Manual Initiation 1,2,3,4 2 switches E

4.

Steam Line Isolation - Manual Initiation 1,2,3,4 2 switches F

5.

Feedwater Isolation - Manual Initiation 1,2,3,4 2 switches F

6.

ADS Stages 1, 2 & 3 Actuation - Manual Initiation 1,2,3,4 2 switch sets E

5(d) 2 switch sets H

7.

ADS Stage 4 Actuation - Manual Initiation 1,2,3,4 2 switch sets E

5 2 switch sets H

6(e) 2 switch sets H

8.

Passive Containment Cooling Actuation -

Manual Initiation 1,2,3,4 2 switches E

5(f) 2 switches J

6(f) 2 switches H

9.

Passive Residual Heat Removal Heat Exchanger Actuation - Manual Initiation 1,2,3,4 2 Switches E

5(c) 2 switches G

10. Chemical and Volume Control System Makeup Isolation - Manual Initiation 1,2,3,4(h) 2 switches F

11. Normal Residual Heat Removal System Isolation - Manual Initiation 1,2,3 2 switch sets F

(a) With the RCS not being cooled by the Normal Residual Heat Removal System (RNS).

(b) With the RCS being cooled by the RNS.

(c) With the RCS pressure boundary intact.

(d) With RCS not VENTED.

(e) With upper internals in place.

(f) With decay heat > 7.0 MWt.

(h) With all four cold leg temperatures > 275°F.

Technical Specifications ESFAS Manual Initiation 3.3.9 VEGP Units 3 and 4 3.3.9 - 6 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

Table 3.3.9-1 (page 2 of 2)

Engineered Safeguards Actuation System Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS

12. In-Containment Refueling Water Storage Tank (IRWST) Injection Line Valve Actuation -

Manual Initiation 1,2,3,4(a) 2 switch sets D

4(b),5 2 switch sets J

6 2 switch sets H

13. IRWST Containment Recirculation Valve Actuation - Manual Initiation 1,2,3,4(a) 2 switch sets D

4(b),5 2 switch sets J

6 2 switch sets H

14. SG Power Operated Relief Valve and Block Valve Isolation - Manual Initiation 1,2,3,4(a) 2 switches D

15. Containment Vacuum Relief Valve Actuation -

Manual Initiation 1,2,3,4,5(g),6(g) 2 switches L

(a) With the RCS not being cooled by the Normal Residual Heat Removal System (RNS).

(b) With the RCS being cooled by the RNS.

(g) Without an open containment air flow path 6 inches in diameter.

Technical Specifications ESFAS RCS Hot Leg Level Instrumentation 3.3.10 VEGP Units 3 and 4 3.3.10 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

As required by Required Action B.1 and referenced in Table 3.3.10-1.

C.1 Suspend positive reactivity additions.

Immediately AND C.2 Initiate action to restore channel(s) to OPERABLE status.

Immediately D.

As required by Required Action B.1 and referenced in Table 3.3.10-1.

- NOTE -

Flow path(s) may be unisolated intermittently under administrative controls.

D.1.1 Isolate the affected flow path(s).

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND D.1.2.1 Isolate the affected flow path(s) by use of at least one closed and deactivated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured.

7 days OR D.1.2.2 Verify the affected flow path is isolated Once per 7 days OR D.2 Initiate action to restore channel(s) to OPERABLE status.

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

Technical Specifications ESFAS RCS Hot Leg Level Instrumentation 3.3.10 VEGP Units 3 and 4 3.3.10 - 3 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

As required by Required Action B.1 and referenced in Table 3.3.10-1.

E.1 Initiate action to restore channel(s) to OPERABLE status.

Immediately

Technical Specifications ESFAS Actuation Logic

- Shutdown 3.3.16 VEGP Units 3 and 4 3.3.16 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

Required Action and associated Completion Time of Condition A not met in MODE 5.

OR One or more Functions within two or more divisions inoperable in MODE 5.

B.1 Suspend positive reactivity additions.

Immediately AND B.2 Initiate action to restore Function(s) to OPERABLE status.

Immediately AND B.3 Initiate action to isolate the flow path from the demineralized water storage tank to the RCS by use of at least one closed and de-activated automatic valve or closed manual valve.

Immediately C.

Required Action and associated Completion Time of Condition A not met in MODE 6.

OR One or more Functions within two or more divisions inoperable in MODE 6.

C.1 Suspend positive reactivity additions.

Immediately AND C.2 Initiate action to restore Function(s) to OPERABLE status.

Immediately

Technical Specifications ADS - Shutdown, RCS Intact 3.4.12 VEGP Units 3 and 4 3.4.12 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One required flow path in ADS stage 1 inoperable and one required flow path in ADS stage 2 or 3 inoperable.

OR Two required flow paths in ADS stage 1 inoperable.

C.1 Restore one required flow path to OPERABLE status.

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

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

OR Condition A and Condition B entered concurrently.

OR Three or more required flow paths in ADS stage 1, 2, and 3 inoperable.

OR LCO not met for reasons other than Condition A, B, or C.

D.1 Initiate action to restore compliance with the LCO.

Immediately

Technical Specifications ADS - Shutdown, RCS Open 3.4.13 VEGP Units 3 and 4 3.4.13 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One required flow path in ADS stage 1, 2, and 3 not open.

A.1 Restore required flow path in ADS stage 1, 2, and 3 to open status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR A.2 Open alternative flow path(s) with an equivalent area.

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

One required flow path in ADS stage 4 inoperable.

B.1 Restore required flow path in ADS stage 4 to OPERABLE status.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR B.2 Open an alternative flow path with an equivalent area.

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

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

OR Condition A and Condition B entered concurrently.

OR LCO not met for reasons other than Condition A or B.

C.1 Initiate action to restore compliance with the LCO.

Immediately AND C.2 Suspend positive reactivity additions.

Immediately

Technical Specifications ADS - Shutdown, RCS Open 3.4.13 VEGP Units 3 and 4 3.4.13 - 3 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.13.1 Verify each required ADS stage 1, 2, and 3 valve is in the open position.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.13.2 For each required flow path in ADS stage 4, the following SRs are applicable:

SR 3.4.11.1 SR 3.4.11.3 SR 3.4.11.5 In accordance with applicable SRs

Technical Specifications CMTs - Shutdown, RCS Intact 3.5.3 VEGP Units 3 and 4 3.5.3 - 1 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4) 3.5 PASSIVE CORE COOLING SYSTEM (PXS) 3.5.3 Core Makeup Tanks (CMTs) - Shutdown, Reactor Coolant System (RCS) Intact LCO 3.5.3 One CMT shall be OPERABLE.

APPLICABILITY:

MODE 4 with the RCS cooling provided by the Normal Residual Heat Removal System (RNS).

MODE 5 with the RCS not VENTED.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Required CMT inoperable due to one outlet isolation valve inoperable.

A.1 Restore required isolation valve to OPERABLE status.

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

Required CMT inoperable due to water temperature or boron concentration not within limits.

B.1 Restore required CMT water temperature and boron concentration to within limits.

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

Required CMT inlet line noncondensible gas volume not within limit in MODE 4.

C.1 OR C.2 Restore required CMT inlet line noncondensible gas volume to within limit.

Be in MODE 5.

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

Required CMT inoperable for reasons other than Condition A, B, or C.

D.1 Restore required CMT to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

Technical Specifications CMTs - Shutdown, RCS Intact 3.5.3 VEGP Units 3 and 4 3.5.3 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

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

E.1 Initiate action to be in MODE 5.

Immediately AND E.2 Initiate action to restore required CMT to OPERABLE status.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.3.1 The following SRs are applicable:

SR 3.5.2.1 SR 3.5.2.2 SR 3.5.2.4 SR 3.5.2.5 SR 3.5.2.6 SR 3.5.2.7 In accordance with applicable SRs SR 3.5.3.2

- NOTE -

Only required to be met in MODE 4 with RCS cooling provided by the RNS.

The following SR is applicable:

SR 3.5.2.3 In accordance with applicable SR

Technical Specifications CMTs - Shutdown, RCS Intact 3.5.3 VEGP Units 3 and 4 3.5.3 - 3 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.3.3

- NOTE -

Only required to be met in MODE 5 with RCS not VENTED.

Verify the borated water volume is 2450 cu. ft.

7 days

Technical Specifications PRHR HX - Shutdown, RCS Intact 3.5.5 VEGP Units 3 and 4 3.5.5 - 1 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4) 3.5 PASSIVE CORE COOLING SYSTEM (PXS) 3.5.5 Passive Residual Heat Removal Heat Exchanger (PRHR HX) - Shutdown, Reactor Coolant System (RCS) Intact LCO 3.5.5 The PRHR HX shall be OPERABLE.

APPLICABILITY:

MODE 4 with the RCS cooling provided by the Normal Residual Heat Removal System (RNS).

MODE 5 with the RCS pressure boundary intact and pressurizer level 20%.

- NOTE -

PRHR HX is not required to be OPERABLE in MODE 5 during RCS vacuum fill operations.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One air operated PRHR HX outlet isolation valve inoperable.

A.1 Restore air operated PRHR HX outlet valve to OPERABLE status.

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

One air operated In-Containment Refueling Water Storage Tank (IRWST) gutter isolation valve inoperable.

B.1 Restore air operated IRWST gutter isolation valve to OPERABLE status.

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

PRHR HX inlet line noncondensible gas volume not within limit.

C.1 Restore PRHR HX inlet line noncondensible gas volume to within limit.

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

PRHR HX inoperable for reasons other than Condition A, B, or C.

D.1 Restore PRHR HX to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

Technical Specifications PRHR HX - Shutdown, RCS Intact 3.5.5 VEGP Units 3 and 4 3.5.5 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and associated Completion Time not met.

E.1 Initiate action to be in MODE 5.

Immediately AND E.2 Initiate action to restore PRHR HX to OPERABLE status.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.5.1 The SRs of Specification 3.5.4, Passive Residual Heat Removal Heat Exchanger (PRHR HX) -

Operating are applicable.

In accordance with applicable SRs

Technical Specifications IRWST - Shutdown, MODE 5 3.5.7 VEGP Units 3 and 4 3.5.7 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

IRWST boron concentration not within limits.

OR IRWST borated water temperature not within limits.

OR IRWST borated water volume < 73,100 cu. ft.

and 70,907 cu ft.

D.1 Restore IRWST to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months E.

Required motor operated IRWST isolation valve not fully open.

OR Power is not removed from required motor operated IRWST isolation valve.

E.1 Restore required motor operated IRWST isolation valve to fully open condition with power removed.

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

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

OR LCO not met for reasons other than Condition A, B, C, D, or E.

F.1 Initiate action to restore IRWST to OPERABLE status.

Immediately AND F.2 Suspend positive reactivity additions.

Immediately

Technical Specifications IRWST - Shutdown, MODE 6 3.5.8 VEGP Units 3 and 4 3.5.8 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D.

IRWST and refueling cavity boron concentra-tion not within limits.

OR IRWST and refueling cavity borated water temperature not within limits.

OR IRWST and refueling cavity borated water volume < 73,100 cu. ft and 70,907 cu. ft.

D.1 Restore IRWST to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months E.

Required motor operated IRWST isolation valve not fully open.

OR Power is not removed from required motor operated IRWST isolation valve.

E.1 Restore required motor operated IRWST isolation valve to fully open condition with power removed.

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

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

F.1 Initiate action to restore IRWST to OPERABLE status.

Immediately OR AND LCO not met for reasons other than Condition A, B, C, D, or E.

F.2 Suspend positive reactivity additions.

Immediately

Technical Specifications Containment Pressure 3.6.4 VEGP Units 3 and 4 3.6.4 - 1 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4) 3.6 CONTAINMENT SYSTEMS 3.6.4 Containment Pressure LCO 3.6.4 Containment pressure shall be -0.2 psig and +1.0 psig.

APPLICABILITY:

MODES 1, 2, 3, and 4.

MODES 5 and 6 without an open containment air flow path 6 inches in diameter.

- NOTE -

The high pressure LCO limit is not applicable in MODES 5 or 6.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Containment pressure not within limits.

A.1 Restore containment pressure to within limits.

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

Required Action and associated Completion Time of Condition A not met in MODE 1, 2, 3, or 4.

B.1 AND B.2 Be in MODE 3.

Be in MODE 5.

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

Required Action and associated Completion Time of Condtion A not met in MODE 5 or 6.

C.1 Initiate action to restore containment pressure to within limits.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.4.1 Verify containment pressure is within limits.

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

Technical Specifications Containment Air Temperature 3.6.5 VEGP Units 3 and 4 3.6.5 - 1 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4) 3.6 CONTAINMENT SYSTEMS 3.6.5 Containment Air Temperature LCO 3.6.5 Containment average air temperature shall be 120°F.

APPLICABILITY:

MODES 1, 2, 3, and 4, MODES 5 and 6 with both containment equipment hatches and both containment airlocks closed.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

Containment average air temperature not within limit.

A.1 Restore containment average air temperature to within limit.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months B.

Required Action and associated Completion Time of Condition A not met in MODE 1, 2, 3, or 4.

B.1 AND B.2 Be in MODE 3.

Be in MODE 5.

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

Required Action and associated Completion Time of Condition A not met in MODE 5 or 6.

C.1 Initiate action to restore containment average air temperature to within limit.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.5.1 Verify containment average air temperature is within limit.

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

Technical Specifications PCS 3.6.6 VEGP Units 3 and 4 3.6.6 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E.

Required Action and associated Completion time of Condition A, B, or C not met in MODE 5 or 6.

OR LCO not met for reasons other than Condition A, B, or C in MODE 5 or 6.

E.1 Initiate action to restore passive containment cooling to OPERABLE status.

Immediately AND E.2 Suspend positive reactivity additions.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.6.1 Verify the water storage tank temperature 40°F and 120°F.

24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months SR 3.6.6.2 Verify the water storage tank volume 756,700 gallons.

7 days SR 3.6.6.3 Verify each passive containment cooling system manual, power operated, and automatic valve in each flow path that is not locked, sealed, or otherwise secured in position, is in the correct position.

31 days SR 3.6.6.4 Verify each passive containment cooling system automatic valve in each flow path that is not locked, sealed, or otherwise secured in position, actuates to the correct position on an actual or simulated actuation signal.

24 months

Technical Specifications PCS 3.6.6 VEGP Units 3 and 4 3.6.6 - 3 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.6.6.5 Verify the air flow path from the shield building annulus inlet to the exit is unobstructed and, that all air baffle sections are in place.

24 months SR 3.6.6.6 Verify passive containment cooling system flow and water coverage performance in accordance with the System Level OPERABILITY Testing Program.

At first refueling AND 10 years

Technical Specifications Containment Penetrations 3.6.7 VEGP Units 3 and 4 3.6.7 - 2 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B.

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

OR LCO not met for reasons other than Condition A.

B.1 Initiate action to restore compliance with the LCO.

Immediately AND B.2 Suspend positive reactivity additions.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.6.7.1 Verify each required containment penetration is in the required status.

7 days SR 3.6.7.2

- NOTE -

Only required to be met for an open equipment hatch.

Verify the hardware, tools, equipment and power source necessary to close the equipment hatch are available.

Prior to hatch removal AND 7 days

Technical Specifications Vacuum Relief Valves 3.6.9 VEGP Units 3 and 4 3.6.9 - 3 Amendment No. 212 (Unit 3)

Amendment No. 210 (Unit 4)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time of Condition A, B, C, D, or E not met in MODE 1, 2, 3, or 4.

F.1 Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months AND F.2 Be in MODE 5.

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months OR Two vacuum relief check valves inoperable for opening in MODE 1, 2, 3, or 4.

OR Two vacuum relief isolation valves inoperable for opening in MODE 1, 2, 3, or 4.

G.

Required Action and associated Completion Time of Condition A, B, or E not met in MODE 5 or 6.

G.1 Initiate action to restore compliance with the LCO.

Immediately OR Two vacuum relief check valves inoperable for opening in MODE 5 or 6.

OR Two vacuum relief isolation valves inoperable for opening in MODE 5 or 6.

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 212 AND 210 TO THE COMBINED LICENSE NOS. NPF-91 AND NPF-92 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026

1.0 INTRODUCTION

By letter dated January 23, 2025 (Agencywide Documents Access and Management System Accession No. ML25023A275), as supplemented by letters dated October 31, 2025 and December 18, 2025 (ADAMS Accession Nos. ML25304A235 and ML25353A427, respectively), Southern Nuclear Operating Company (SNC, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) amend Vogtle Electric Generating Plant (Vogtle), Units 3 and 4 Combined License (COL)

Numbers NPF-91 and NPF-92, respectively.

The proposed amendment would modify the licenses and selected technical specification (TS) required actions applicable during shutdown modes of operation.

The supplements dated October 31, 2025, and December 18, 2025, 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 the Federal Register on March 18, 2025 (90 FR 12573).

2.0 REGULATORY EVALUATION

The regulation at Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36(c)(2) requires that TSs include limiting conditions for operation (LCO). Per 10 CFR 50.36(c)(2)(i), LCO are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that 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 TSs until the condition can be met.

Section (a)(4) of 10 CFR50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, (the Maintenance Rule), requires, in part, that [b]efore performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.

Nuclear Utility Management and Resources Council (NUMARC) 93-01, Revision 4F, Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, (ML18120A069),

Section 11.0, Assessment of Risk Resulting from Performance of Maintenance Activities, provides a methodology (endorsed by the NRC in Regulatory Guided (RG) 1.160, Revision 4, Monitoring the Effectiveness of Maintenance at Nuclear Power Plants, (ML18220B281) that is an acceptable approach to assess and manage the risk associated with maintenance activities.

Regarding shutdown operations, RG. 1.160 states, NUMARC 93-01 provides guidance to licensees on the scope of hazard groups to be considered for the 10 CFR 50.65(a)(4) assessment provision during shutdown conditions. Section 11.3.6 Assessment of Methods for Shutdown Conditions of NUMARC 93-01 states to licensees that they should consider section 4.0 of NUMARC 91-06 Guidelines for Industry Actions to Assess Shutdown Management when developing an assessment process that meets 10 CFR 50.65(a)(4). As stated in RG 1.160, the NRC staff considers NUMARC 91-06 acceptable for use with the following clarification. In Section 1.8 of RG 1.160, the NRC clarifies that the acceptable application of NUMARC 91-06 is limited in applicability to where it is applied in NUMARC 93-01 only.

The U.S Nuclear Regulatory Commission (NRC, the Commission) staff reviews the human performance aspects of licensing action requests utilizing guidance in NUREG-1764, Revision 1, Guidance for the Review of Changes to Human Actions (ML072640413).

NRC Generic Letter (GL) 88-17, Loss of Decay Heat Removal, ( NUDOCS Accession Number 8810180350) and NUMARC 91-06 contain key shutdown voluntary initiatives credited in SECY-97-168, Issuance for Public Comment of Proposed Rulemaking Package for Shutdown and Fuel Storage Pool Operation, that are necessary to reduce shutdown risk beyond what is provided by adherence to TSs.

In Staff Requirements Memorandum (SRM) to SECY 97-168, the Commission expects the NRC staff to continue to monitor licensee performance, through inspections and other means, in the area of shutdown operations to ensure that the current level of safety is maintained. Vogtle 3 and 4 UFSAR, Sections 1.9.5.1.4 and 5.4.7.2.1 discuss design features and approaches that address GL 88-17.

Consistent with the expectation of the SRM, and in the context of the GL incorporation in the Vogtle 3 and 4 UFSAR, the NRC staff reviewed the licensees mitigation capability to a postulated loss of decay heat removal during reduced inventory conditions in context of the proposed TS action statement changes.

3.0 TECHNICAL EVALUATION

The NRC staff evaluated the licensees application to determine whether the proposed changes are consistent with the guidance, regulations, and plant-specific design and licensing basis discussed in Section 2.0 of this safety evaluation. The NRC staff reviewed the licensees statements in the LAR, attachments to the LAR, and the relevant sections of the Vogtle Units 3 and 4 UFSAR, TS and TS Bases.

The NRC staffs technical evaluation is organized into the following sections as follows. Each proposed TS change is discussed in Section 3.1, the safety analysis is discussed in Section 3.2, TS change consistency is discussed in Section 3.3, maintenance rule and Generic Letter 88-17 are discussed in Section 3.4, and human factors is discussed in Section 3.5.

3.1 Review of proposed changes to TS 3.1.1 Proposed Changes to TS 3.3.8, Engineered Safety Feature Actuation System (ESFAS)

Instrumentation TS 3.3.8, Function 7, Pressurizer Water Level - Low 2, Action J TS 3.3.8, Function 15, Core Makeup Tank (CMT) Level - Low 3, Action J TS 3.3.8, Function 16, CMT Level - Low 6, Action J The Pressurizer Water Level - Low 2 function initiates Core Makeup Tank (CMT) actuation and tripping of the Reactor Coolant Pumps (RCPs) from the coincidence of pressurizer level below the Low 2 setpoint in any two of the four divisions. For Action J, this function is applicable in MODE 4 with the Reactor Coolant System (RCS) being cooled by the Normal Residual Heat Removal System (RNS) and MODE 5 with RCS not vented and CMT actuation on Pressurizer Water Level - Low 2 not blocked.

The CMT Level - Low 3 function ensures continued passive injection or borated water to the RCS following a small break Loss of Coolant Accident (LOCA). Automatic Depressurization System (ADS)

Stages 1, 2 and 3 actuation is initiated when the CMT level reaches its Low 3 setpoint coincident with any CMT actuation signal. The ADS Stage 4 actuation ESFAS protective function is actuated by the CMT level - Low 6 function coincident with RCS Wide Range Pressure - Low. For Condition J, Functions 15 and 16 are applicable in MODE 4 with the RCS being cooled by the RNS and MODE 5 with the RCS not vented.

The existing Required Action J.1 requires that the plant shall be placed in a condition in which the likelihood and consequences of an event are minimized and is accomplished by placing the plant in MODE 5. The licensee has not proposed any changes to Required Action J.1.

The existing Required Action J.2 is to initiate action to establish RCS vented with a completion time of 180 hours0.00208 days 0.05 hours 2.97619e-4 weeks 6.849e-5 months . Establishing RCS vented assures that the required ADS 1, 2, and 3 flow paths, or equivalent prescribed by LCO 3.4.13, Automatic Depressurization System (ADS) - Shutdown, RCS Open, are open providing sufficient steam venting such that, in combination with required ADS 4 actuation, lowers RCS pressure to allow In-containment Refueling Water Storage Tank (IRWST) injection. In its submittal, the licensee stated license amendment request (LAR), Required Action J.2 represents a potential conflict with any Required Action that includes with the RCS pressure boundary intact, including Function 18 of TS 3.3.8, Functions 6, 7 and 8 of TS 3.3.9, TS 3.5.7, and TS 3.6.6. To eliminate the potential conflict, the licensee proposed changes to Required Action J.2 to initiate action to restore channel(s) to operable status with a completion time of 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months with three or more inoperable channels and 180 hours0.00208 days 0.05 hours 2.97619e-4 weeks 6.849e-5 months otherwise.

In the enclosure to its LAR, the licensee stated that Condition J could be reached with the Function 7 actuation signal still capable of providing two channels to automatically actuate ADS Stage 1, 2 and 3, or Action J could be entered as a result of three or more channels being inoperable. The licensee stated that given the potential for ADS Stages 1, 2, and 3 still being capable of automatic initiation (Function 7), ADS Stage 4 still being capable of automatic initiation (Functions 15 and 16), and the requirements in TS 3.3.9 (Functions 6 and 7) for manual actuation of ADS, requiring opening the RCS could be an unnecessary compensatory measure. In addition, operability of one CMT (TS 3.5.3) and the Passive Residual Heat Removal Heat Exchanger (PRHR HX) (TS 3.5.5) is removed once the RCS is vented, thereby reducing the complement of safety systems available to respond to an event. The licensee stated that replacing the action to exit the Applicability with an action to restore channels to operable status allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to establish the RCS vented or not, thereby maintaining an appropriate focus on safe plant operation.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.8, Function 7, Pressurizer Water Level - Low 2, Condition J, are acceptable.

TS 3.3.8, Function 14, RCS Wide Range Pressure - Low, Actions K and L The RCS Wide Range Pressure - Low function actuates the ADS Stage 4 ESFAS protective function.

For Action K, this function is applicable in MODE 5. For Action L, this function is applicable in MODE 6 with the upper internals in place.

The existing Required Actions K.1 and K.2 require that the plant shall be placed in a condition in which the likelihood and consequences of an event are minimized and is accomplished by immediately initiating action to open the RCS pressure boundary and establish 20% pressurizer level. Additionally, action is required to immediately suspend positive reactivity additions. These requirements minimize the consequences of the loss of decay heat removal by maximizing RCS inventory and maintaining RCS temperature as low as practical. The potential for a criticality event is minimized by suspension of positive reactivity additions.

The existing Required Actions L.1 and L.2 require that the plant shall be placed in a condition in which the likelihood and consequences of an event are minimized and are accomplished by immediately initiating action to suspend positive reactivity additions and actions immediately initiated to remove the upper internals. The potential for a criticality event is minimized by suspension of positive reactivity additions. The licensee did not propose any changes to Required Actions K.1 and L.1 to immediately suspend positive reactivity additions.

The licensee stated that for Required Action K.2 the action to open the RCS pressure boundary requires entry into and compliance with TS 3.4.13, while exiting the Applicability for TS 3.4.12. This results in the opening of the required number of ADS Stage 1, 2 and 3 flow paths. Condition K can be reached with the Function 14 interlock signals still capable of supporting two channels to automatically actuate ADS Stage 1, 2, and 3. The licensee stated that with the potential for ADS Stage 1, 2, and 3 still being capable of automatic and manual actuation, requiring opening the RCS could be an unnecessary compensatory measure. In addition, required operability of one CMT (TS 3.5.3) and the PRHR HX (TS 3.5.5) is removed once the RCS is vented, thus reducing the required complement of safety system available to respond to an event.

The second portion of Required Action K.2 is to establish pressurizer water level 20%. The licensee stated that events requiring actuation of ADS Stage 1, 2, and 3 do not assume a minimum RCS water level and that establishing 20% pressurizer level is not necessary to put the plant within the assumptions of the safety analysis.

The licensee stated that replacing the action to open RCS and increase pressurizer level with an action to restore channel(s) to operable status allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to establish the RCS vented and whether to increase level (and if so by how much), thereby maintaining an appropriate focus on safe plant operation.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.8, Function 14, RCS Wide Range Pressure - Low, Condition K, is acceptable.

Required Action L.2 requires immediate initiation of action to remove the upper internals, which would exit the Applicability for Function 14. The licensee stated that this will preclude normal outage progression to proceed to MODE 5 with the reactor vessel head on, which would establish an additional fission product boundary. As such, replacing the action to exit the Applicability with an action to restore channel(s) to operable status allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to remove the reactor vessel internals, thereby maintaining an appropriate focus on safe plant operation.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.8, Function 14, RCS Wide Range Pressure - Low, Condition L, is acceptable.

With the proposed change to restore channel(s) to OPERABLE status the Required Actions for Conditions K and L become identical. Therefore, the licensee has proposed consolidating Required Actions K and L into Condition K, noting that Action L is Not Used and updating Table 3.3.8-1, Function 14, MODE 6 Conditions to reference Condition K. The NRC staff finds this acceptable.

TS 3.3.8, Function 18, IRWST Lower Narrow Range Level - Low 3, Actions M and N The IRWST Lower Narrow Range Level - Low 3 function coincident with an ADS Stage 4 actuation signal will open the containment recirculation valves. For Condition M, this function is applicable in MODE 4 with the RCS being cooled by the RNS, MODE 5, and MODE 6 with upper internals in place.

If Condition M is reached, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized and is accomplished by placing the plant in MODE 5 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The existing Required Action M.1 minimizes the potential for a criticality event by suspension of positive reactivity additions. The licensee did not propose any changes to Required Action M.1.

The existing Required Action M.3 requires initiation of action within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to close the RCS pressure boundary and establish 20% pressurizer level. The 12-hour Completion Time allows transition to MODE 5 in accordance with M.2, if needed, while maintaining the RCS pressure boundary intact. The existing Required Actions M.2 and M.3 minimize the consequences of a loss of decay heat removal event by optimizing conditions for RCS cooling in MODE 5 using the PRHR HX. Additionally, maximizing RCS inventory and maintaining RCS temperature as low as practical further minimize the consequences of a loss of decay heat removal event. Maintaining the RCS pressure boundary intact in MODE 5 assures that PRHR HX cooling is available. The licensee did not propose any changes to Required Action M.2.

For the existing Condition N, the plant must be placed in a condition in which the likelihood and consequences of an event are minimized. This is accomplished by immediately initiating action to establish the reactor cavity water level 23 feet above the top of the reactor vessel flange and immediately suspending positive reactivity additions. The existing Required Action N.2 minimizes the consequences of a loss of decay heat removal event by maximizing RCS inventory and maintaining RCS temperature as low as practical. Additionally, the potential for a criticality event is minimized by suspension of positive reactivity additions in accordance with Required Action N.1. The licensee did not propose any changes to Required Action N.1.

Existing Required Action M.3 that requires Initiate action to establish a pressurizer level 20% with the RCS pressure boundary intact. Establishing the RCS pressure boundary intact requires entering the Applicability for TS 3.4.12 (requiring ADS Stage 1, 2, and 3 flow paths to be OPERABLE), TS 3.5.3 (requiring CMT to be OPERABLE), and TS 3.5.5 (requiring PRHR HX to be OPERABLE). In the event these structure, system, and components (SSCs) cannot be made OPERABLE, their current Required Actions would require actions to open the RCS, representing a conflict with the action to establish RCS intact. Given the differing requirements when the RCS is intact versus when it is open, and the potential range of plant conditions during an outage when these actions might arise, the licensee proposes replacing the action to establish the RCS intact and increase pressurizer level with an action to restore channel(s) to operable status. This would allow the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to establish or maintain the RCS open or intact, thereby maintaining an appropriate focus on safe plant operation.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.8, Function 18, IRWST Lower Narrow Range Level - Low 3, Condition M are acceptable.

The existing Required Action N.2, which is entered from MODE 6, requires Initiate action to establish water level 23 feet above the top of the reactor vessel flange. The licensee stated that this precludes activities necessary to install the reactor vessel head and proceed to MODE 5 and that safe operation of the plant can be maintained without the requirement to establish a specific water level. Therefore, the licensee proposed to replace the action to increase level with an action to restore channel(s) to operable status as this allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level, thereby maintaining an appropriate focus on safe plant operation.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.8, Function 18, IRWST Lower Narrow Range Level - Low 3, Condition N are acceptable.

With the proposed change to Required Actions M.3 and N.2, the licensee states that the Required Actions for Conditions K and N become identical. Therefore, the licensee has proposed consolidating Required Actions K and N. The licensee proposed changing Action N to Not Used and Table 3.3.8-1, Function 14, MODE 6, Conditions, is revised to specify Condition K. The NRC staff finds this acceptable.

TS 3.3.8, Function 1, Containment Pressure, Action P The Containment Pressure - Low (Function 1.a) provides an interlock to block opening of the Containment Vacuum Relief Valves above the Low setpoint to prevent inadvertent opening of these valves. The Containment Pressure - Low 2 (Function 1.b) provides protection against a negative pressure in containment due to loss of ac power or inadvertent actuation of containment cooling and a low outside ambient air temperature in combination with limited containment heating that reduces the atmospheric temperature (and hence pressure) inside containment. For Condition P, this function is applicable in MODES 1 - 4, and both MODES 5 and 6 without an open containment air flow path 6 inches in diameter.

If the existing Condition P is entered, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In addition, a containment air flow path 6 inches in diameter shall be opened within 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months from Condition entry. Opening any flow path (or paths) with an area equivalent to 6 inches in diameter provides the required vacuum relief path in the event of a low-pressure event. In addition, Containment air flow paths opened must comply with LCO 3.6.7, Containment Penetrations.

The licensee stated that for MODES 5 and 6, LCO 3.6.7, Containment Penetrations, requires the capability of closing the containment prior to steaming (e.g., loss of decay heat removal that would lead to steaming in the containment). As such, Required Action P.3 represents a potential conflict with a necessary post-event action. The licensee proposed to replace the action to open a containment air flow path with an action to restore channel(s) to operable status. Consistent with Generic Letter 88-17, NUMARC 91-06, and low power and shutdown risk assessments, priority is given to be able to close the containment prior to steaming. The outage assessment risk monitoring defense-in-depth (DID) tool, B-ADM-OPS-11 does not evaluate the need to open a containment vent path. As stated in the request for additional information (RAI) responses to question 11, B-ADM-OPS-011, Key Safety Function 6, Containment Closure will be revised to include actions for the operators to increase RCS inventory therefore raising the ratio of closure time to RCS boil in the event of an ORANGE or RED path is identified. In addition, the licensee proposed to reduce the Completion Time of Required Action P.3 from 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months to be consistent with Required Action P.2.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.8, Function 1, Containment Pressure, Condition P, are acceptable.

3.1.2 Proposed Changes to TS 3.3.9, Engineered Safety Feature Actuation System (ESFAS) Manual Initiation TS 3.3.9, Function 2, Core Makeup Tank (CMT) Actuation - Manual Initiation, Action G TS 3.3.9, Function 9, Passive Residual Heat Removal Heat Exchanger Actuation - Manual Initiation, Action G CMT Actuation (Function 2) provides the passive injection of borated water into the RCS. Injection provides RCS makeup water and boration during transients or accidents when the normal makeup supply from the Chemical and Volume Control System (CVS) is lost or insufficient. The PRHR HX Actuation (Function 9) provides emergency core decay heat removal when the startup feedwater system is not available to provide a heat sink. For Condition G, Function 2 is applicable in MODE 4 with the RCS being cooled by the RNS and MODE 5 with the RCS not vented. For Condition G, Function 9 is applicable in MODE 5 with the RCS pressure boundary intact.

If the current Condition G is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized. This is accomplished by placing the plant in MODE 5 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . Once in MODE 5, action shall be immediately initiated to establish RCS vented. Establishing RCS vented assures that the required ADS 1, 2 and 3 flow paths, or equivalent prescribed by LCO 3.4.13, are open providing sufficient steam venting such that, in combination with required ADS 4 actuation, lowers RCS pressure to allow IRWST injection. Required Action G.2 requires Initiate action to establish RCS VENTED, which would exit the Applicability for Functions 2 and 9.

The licensee stated that the action to establish RCS vented requires entry into and compliance with TS 3.4.13, while exiting the Applicability for TS 3.4.12 and that there is no effect on ADS Stage 4 OPERABILITY between these two TSs, while ADS Stage 1, 2, and 3 requirements change from being OPERABLE for opening to being required to be open.

The licensee stated that Condition G could be reached with either Function 2 or 9 manual actuation still capable of providing one switch to actuate the CMT or the PRHR heat exchanger. Additionally, TS 3.3.8 still requires operability of automatic CMT actuation capability and associated PRHR heat exchanger actuation capability. With the potential for CMT and PRHR HX still being capable of automatic and manual actuation, requiring establishing the RCS vented could be an unnecessary compensatory measure. Additionally, the licensee stated that operability of one CMT (TS 3.5.3) and the PRHR HX (TS 3.5.5) is also removed once the RCS is vented, thus reducing the complement of safety systems available to respond to an event. The licensee proposed changing Required Action G.2 to an action to restore channel(s) to operable status with a completion time of 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . The licensee stated that this change allows the operators to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether or not to open the RCS.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.9, Function 2, Core Makeup Tank (CMT) Actuation - Manual Initiation, Action G and Function 9, Passive Residual Heat Removal Heat Exchanger Actuation - Manual Initiation, Condition G are acceptable.

TS 3.3.9, Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation, Action H The ADS Stages 1, 2 and 3 manual actuation (Function 6) provides a sequenced depressurization of the reactor coolant system to allow passive injection from the CMTs, accumulators, and the IRWST to mitigate the effects of a LOCA. This Function is applicable in MODE 5 with the RCS not vented.

If the current Condition H is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized and is accomplished by immediately initiating action to establish RCS vented (lowers RCS pressure to allow IRWST injection), establish 20% pressurizer level (maximizes RCS inventory), and suspending positive reactivity additions (criticality events minimized).

The licensee stated that Condition H could be reached with the Function 6 manual actuation still capable of providing one switch set to actuate ADS Stages 1, 2 & 3. Additionally, TS 3.3.8 requires operability of automatic ADS Stages 1, 2 & 3 actuation capability. With the potential for ADS Stages 1, 2 & 3 still being capable of automatic and manual actuation requiring establishing the RCS vented could be an unnecessary compensatory measure. In addition, operability of one CMT (TS 3.5.3) and the PRHR HX (TS 3.5.5) is also removed once the RCS is vented, reducing the complement of safety systems available to respond to an event. The existing Condition H also requires establishment of 20% pressurizer level. The licensee stated that events requiring actuation of ADS valves do not assume a minimum RCS water level, the MODE 5 Required Action H.2 requirement to establish 20%

pressurizer level would not be necessary to put the plant within the assumptions of the safety analysis and that safe plant operation can be maintained without the requirement to establish a specific water level.

The licensee has proposed replacing the action to establish RCS vented and establish 20% pressurizer level with an action to restore channel(s) to operable status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to open the RCS or not, and determine an appropriate water level.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.9, Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation, Condition H are acceptable.

TS 3.3.9, Function 7, ADS Stage 4 Actuation - Manual Initiation, Actions H & I The ADS provides a sequenced depressurization of the reactor coolant system to allow passive injection from the CMTs, accumulators, and the IRWST to mitigate the effects of a LOCA. This function is appliable in MODE 5 and MODE 6 with the upper internals in place.

If the current Condition H is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized and is accomplished by immediately initiating action to establish RCS vented (lowers RCS pressure to allow IRWST injection), establish 20% pressurizer level (maximizes RCS inventory), and suspending positive reactivity additions (criticality events minimized).

If the current Condition I is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized and is accomplished by immediately initiating action to remove the upper internals and suspend positive reactivity additions. The requirement to initiate action to remove the upper internals minimizes the consequences of the loss of decay heat removal by maximizing RCS inventory and maintaining RCS temperature as low as practical. The potential for a criticality event is minimized by the immediate suspension of positive reactivity additions.

The licensee stated that Condition H could be reached with the Function 7 manual actuation still capable of providing one switch set to actuate ADS Stage 4. TS 3.3.8 requires operability of automatic ADS Stage 4 actuation capability. With the potential for ADS Stages 1, 2 and 3 still being capable of automatic and manual actuation, requiring establishing the RCS vented could be an unnecessary compensatory measure. In addition, operability of one CMT (TS 3.5.3) and the PRHR HX (TS 3.5.5) is also removed once the RCS is vented, reducing the complement of safety systems available to respond to an event. The existing Required Action H.2 also includes an action to establish 20% pressurizer water level. The licensee stated that events requiring actuation of ADS valves do not assume a minimum RCS water level, the MODE 5 Required Action H.2 requirement to establish 20% pressurizer level would not be necessary to put the plant within the assumptions of the safety analysis and that safe plant operation can be maintained without the requirement to establish a specific water level.

For Required Action H.2, the licensee has proposed replacing the action to establish RCS vented and establish 20% pressurizer water level with an action to restore channel(s) to operable status where this allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to open the RCS or not, and determine an appropriate water level.

The current Required Action I.2 has an action to initiate action to remove the upper internals, which would exit the applicability for Function 7 in MODE 6. However, this would preclude normal outage progression to proceed to MODE 5. The licensee has proposed replacing this action with an action to restore channel(s) to operable status and allow the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to remove the reactor vessel internals. Given this proposed change, Required Actions H and I would become identical. The licensee has proposed consolidating these two actions where Condition H would be used and Condition I would be shown as Not Used and Table 3.3.9-1, Function 7 MODE 6 Conditions changed to specify Condition H.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.9, Function 7, ADS Stage 4 Actuation - Manual Initiation, Conditions H & I are acceptable.

TS 3.3.9, Function 8, Passive Containment Cooling System (PCS) Actuation - Manual Initiation, Actions J & K The Passive Containment Cooling System (PCS) transfers heat from the reactor containment to the environment. This Function is necessary to prevent the containment design pressure and temperature from being exceeded following any postulated design basis accident (such as LOCA or steam line break). For Conditions J and K, Function 8 is applicable in MODES 5 and 6 with decay heat > 7.0 MWt.

If the existing Condition J is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized. This is accomplished by placing the plant in MODE 5 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months (Required Action J.2). Required Action J.1 minimizes the potential for a criticality event by suspension of positive reactivity additions and current Required Action J.3 requires initiation of action within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to close the RCS pressure boundary and establish 20% pressurizer level. Existing Required Actions J.2 and J.3 minimize the consequences of a loss of decay heat removal event by optimizing conditions for RCS cooling in MODE 5 using the PRHR HX. Maximizing RCS inventory and maintaining RCS temperature as low as practical further minimize the consequences of a loss of decay heat removal event. Maintaining the RCS pressure boundary intact in MODE 5 assures that PRHR HX cooling is available.

The licensee states that Required Action J.3 requires action to establish the RCS pressure boundary intact. This potentially conflicts with other actions to establish RCS vented. Given the differing requirements when the RCS is intact versus when it is open, and the potential range of plant conditions during an outage when these actions might arise, the licensee is proposing to replace the action to establish the RCS intact and increase pressurizer level with an action to restore channel(s) to operable status. This would allow the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to establish or maintain the RCS open or intact and determine an appropriate water level.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.9, Function 8, Passive Containment Cooling System (PCS) Actuation - Manual Initiation, Condition J are acceptable.

If the existing Action K is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized. This is accomplished by immediately initiating action to establish the reactor cavity water level 23 feet above the top of the reactor vessel flange (Required Action K.2) and to suspend positive reactivity additions (Required Action K.1). Required Action K.2 minimizes the consequences of a loss of decay heat removal event by optimizing conditions for RCS cooling in MODE 6 using IRWST injection. Required Action K.1 reduces the potential for a criticality event by suspension of positive reactivity additions.

The licensee stated that for current Required Action K.2, the requirement to establish water level 23 feet above the top of the reactor vessel flange precludes activities necessary to install the reactor vessel head and proceed to MODE 5. The licensee stated that events requiring actuation of PCS valves do not assume a minimum RCS water level, neither the MODE 5 Required Action J.3 requirement to establish 20% pressurizer level, nor the MODE 6 Required Action K.2 requirement to establish water level 23 feet above the top of the reactor vessel flange, is necessary to put the plant within the assumptions of the safety analysis.

The licensee proposed replacing Required Action K.2 to increase level with an action to restore channel(s) to operable status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much). With the above identified changes to Required Actions, Conditions H and K would become identical. The licensee has proposed consolidating these two actions where Condition J would be used and Condition K would be shown as Not Used and Table 3.3.9-1, Function 8 MODE 6 Conditions changed to specify H.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.9, Function 8, Passive Containment Cooling System (PCS) Actuation - Manual Initiation, Condition K are acceptable.

TS 3.3.9, Function 15, Containment Vacuum Relief Valve Actuation - Manual Initiation, Action L The purpose of the vacuum relief lines is to protect the containment vessel against damage due to a negative pressure (i.e., a lower pressure inside than outside). For Condition L, Function 15 is appliable in MODES 5 and 6 without an open containment air flow path 6 inches in diameter.

If the current Condition L is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . In addition, a containment air flow path 6 inches in diameter shall be opened within 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months from Condition entry.

The licensee stated that Required Action L.3 requires Open a containment air flow path 6 inches in diameter, and that MODES 5 and 6, LCO 3.6.7, Containment Penetrations, requires the capability of closing the containment prior to steaming (e.g., loss of decay heat removal that would lead to steaming in the containment). This represents a potential conflict where containment is required to be both closed and open. The licensee proposed replacing the action to open a containment air flow path 6 inches in diameter with an action to restore channel(s) to operable status. The licensee also proposed a more restrictive Completion Time (from 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months to 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months ).

Consistent with Generic Letter 88-17, NUMARC 91-06, and low power and shutdown risk assessments, priority is given to be able to close the containment prior to steaming. The outage assessment risk monitoring DID tool, B-ADM-OPS-11, does not evaluate the need to open a containment vent path. As stated in the RAI responses to question 11, B-ADM-OPS-011, Key Safety Function 6, Containment Closure will be revised to include actions for the operators to increase RCS inventory, therefore, raising the ratio of closure time to RCS boil in the event of an ORANGE or RED path is identified.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.9, Function 15, Containment Vacuum Relief Valve Actuation - Manual Initiation, Condition L are acceptable.

3.1.3 Proposed Changes to TS 3.3.10, Function 1, Hot Leg Level - Low 4, Action C The Hot Leg Level - Low 4 (Function 1) is a signal to initiate the opening sequence of the fourth stage of ADS upon coincident loop 1 and loop 2 hot leg levels below an established setpoint. For Condition C, Function 1 is applicable in MODE 5 with CMT actuation on Pressurizer Water Level - Low 2 blocked and MODE 6 With upper internals in place and with CMT actuation on Pressurizer Water Level - Low 2 blocked.

If the current Condition C is entered, the plant must be placed in a MODE in which the likelihood and consequences of an event are minimized which is accomplished by immediately initiating action to suspend positive reactivity additions (Required Action C.1 ) and immediate initiation of action to establish pressurizer level above the P-12 (Pressurizer Level) interlock (Required Action C.2). These actions minimize the consequences of a loss of decay heat removal event by optimizing conditions for RCS cooling.

The licensee states that events requiring actuation of ADS Stage 4 do not assume a minimum RCS water level and the Required Action C.2 requirement to establish a pressurizer level above the P-12 interlock is not necessary to put the plant within the assumptions of the safety analysis and that safe plant operation can be maintained without the requirement to establish a specific water level. The licensee has proposed replacing the action to increase level with an action to restore channel(s) to operable status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much).

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.10, Function 1, Hot Leg Level - Low 4, Condition C are acceptable.

3.1.4 Proposed Changes to TS 3.3.10, Function 2, Hot Leg Level - Low 2, Actions D & E The Hot Leg Level - Low 2 (Function 2) is a signal to isolate the CVS letdown valves and is generated upon the occurrence of a Low 2 hot leg level in either of the two RCS hot leg loops. This helps to maintain reactor system inventory in the event of a LOCA. For Condition D, Function 2 is applicable in MODE 5 below the P-12 (Pressurizer Level) interlock. For Condition E, Function 2 is applicable in MODE 6 with the water level < 23 feet above the top of the reactor vessel flange.

If Condition D is entered, the plant must be placed in a condition where the instrumentation Function for valve isolation is no longer needed. This is accomplished by isolating the affected flow path within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . By isolating the CVS letdown flow path from the RCS, the need for automatic isolation is eliminated. In addition, Required Action D.2 requires initiation of action, within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , to establish a pressurizer level above the P-12 (Pressurizer Level) interlock which helps maintain RCS inventory in the event of a LOCA.

If Condition E is entered, the plant must be placed in a condition where the instrumentation Function for valve isolation is no longer needed which is accomplished by immediately initiating action to establish the reactor cavity water level 23 feet above the top of the reactor vessel flange. This minimizes the consequences of an event by providing additional inventory.

Since events requiring actuation of CVS letdown isolation valves do not assume a minimum RCS water level, neither the MODE 5 Required Action D.2 requirement to establish pressurizer level above P-12 interlock, nor the MODE 6 Required Action E.1 requirement to establish water level 23 feet above the top of the reactor vessel flange, is necessary to put the plant within the assumptions of the safety analysis. The licensee stated that safe plant operation can be maintained without the requirement to establish a specific water level.

The licensee proposed to replace the actions to increase level with actions to restore channel(s) to operable status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much).

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.10, Function 2, Hot Leg Level

- Low 2, Conditions D & E are acceptable.

3.1.5 Proposed Changes to TS 3.3.16, Engineered Safety Feature Actuation System (ESFAS)

Actuation Logic - Shutdown, Actions B & C The required divisions of ESFAS actuation logic provide plant protection in the event of any of the analyzed accidents. This includes both Engineered Safety Features (ESF) Coincidence Logic and ESF Actuation. This is applicable in MODES 5 and 6 during movement of irradiated fuel assemblies.

If Condition B is entered, the plant must be placed in a condition in which the likelihood and consequences of an event are minimized which is accomplished by immediately suspending positive reactivity additions, initiating action to open the RCS pressure boundary, and establishing 20% pressurizer level.

If Condition C is entered, the plant must be placed in a condition in which the likelihood and consequences of an event are minimized. This is accomplished by immediately initiating action to establish reactor cavity water level 23 feet above the top of the reactor vessel flange and suspending positive reactivity additions. This minimizes the consequences of a loss of decay heat removal event by optimizing conditions for RCS cooling in MODE 6 using IRWST injection.

The following required ESFAS actuations are potentially affected by inoperable ESFAS Actuation Logic in MODE 5:

ADS Stages 1, 2, and 3 ADS Stage 4 CVS Demineralized Water and Makeup Line Isolation Valves CVS Letdown Isolation Valves below P-12 (Pressurizer Level) interlock Main Control Room Electrical Load De-energization (also required during movement of irradiated fuel)

PRHR HX if RCS pressure boundary intact and 20% pressurizer level CMT IRWST PCS with the reactor decay heat > 7.0 MWt Containment Vacuum Relief Isolation Valves without an open containment air flow path 6 inches in diameter The following required ESFAS actuations are potentially affected by inoperable ESFAS Actuation Logic in MODE 6:

ADS Stage 4 with the reactor internals in place CVS Letdown Isolation Valves when water level < 23 feet above the top of the reactor vessel flange Main Control Room Electrical Load De-energization IRWST PCS with the reactor decay heat > 7.0 MWt Containment Vacuum Relief Isolation Valves without an open containment air flow path 6 inches in diameter SFS Containment Isolation Valves with refueling cavity and spent fuel pool volumes in communication The licensee states that Condition B could be reached with the sufficient ESFAS Actuation Logic Functions still capable of supporting necessary divisions to automatically and/or manually actuate each of these required ESF functions. Required operability of one required CMT (TS 3.5.3) and the PRHR HX (TS 3.5.5) is removed once the RCS is vented (i.e., the result of complying with current Required Action B.2), reducing the complement of required safety system available to respond to an event. With the potential for sufficient ESF functions still being capable of automatic and manual actuation to respond to events, requiring opening the RCS could be an unnecessary compensatory measure.

The second portion of the Required Action requires establishing pressurizer water level 20%. The licensee stated that events requiring the listed ESF actuation in MODE 5 do not assume a minimum RCS water level, establishing 20% pressurizer level is not necessary to put the plant within the assumptions of the safety analysis. The licensee stated that compensatory measures appropriate to the specific plant conditions can be implemented in accordance with existing procedures to assess and manage plant risk in accordance with 10 CFR 50.65(a)(4) without the explicit requirement to establish 20% pressurizer level. The licensee has proposed replacing the Required Action to open RCS and increase pressurizer level with an action to restore channel(s) to operable status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to establish the RCS vented and whether to increase level (and if so by how much).

Current Required Action C.2 requires Initiate action to establish water level 23 feet above the top of the reactor vessel flange, which precludes activities necessary to install the reactor vessel head and proceed to MODE 5. The licensee states that Condition C could be reached with sufficient ESFAS Actuation Logic Functions still capable of supporting necessary divisions to automatically and/or manually actuate each of the required ESF functions. With the potential for sufficient ESF functions still being capable of automatic and manual actuation to respond to events, requiring water level 23 feet above the top of the reactor vessel flange precludes activities necessary to install the reactor vessel head and proceed to MODE 5. The licensee stated that since events requiring ESF actuation in MODE 6 do not assume a minimum RCS water level, establishing water level 23 ft above the top of the reactor vessel flange is not necessary to put the plant within the assumptions of the safety analysis.

The licensee stated that compensatory measures appropriate to the specific plant conditions can be implemented in accordance with existing procedures to assess and manage plant risk in accordance with 10 CFR 50.65(a)(4) without the explicit requirement to establish water level 23 feet above the top of the reactor vessel flange. The licensee has proposed replacing the action in C.2 to establish water level with an action to restore channel(s) to operable status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much).

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.3.16, Engineered Safety Feature Actuation System (ESFAS) Actuation Logic - Shutdown, Conditions B & C are acceptable.

3.1.6 Proposed Changes to TS 3.4.12, Automatic Depressurization System (ADS) - Shutdown, RCS Intact, Action D In MODE 5, the ADS, in conjunction with the IRWST injection, provides the primary protection for mitigation of events requiring RCS makeup, boration, or core cooling. To ensure sufficient steam venting area is provided to adequately depressurize the RCS, thus enabling IRWST injection and containment recirculation, the number of ADS flow paths required to be OPERABLE depends on the level of reactor decay heat. TS 3.4.12 is applicable in MODE 5 with RCS pressure boundary intact and pressurizer level 20%.

If current Condition D is entered, the plant must be placed in a MODE in which this LCO does not apply and action must be initiated, immediately, to open the RCS pressure boundary.

The current Required Action D.1 requirement to open the RCS pressure boundary requires entry into and compliance with TS 3.4.13, while exiting the Applicability for TS 3.4.12. The effect is to require opening the required number of ADS Stage 1, 2, and 3 flow paths. The licensee stated that Condition D could be reached without OPERABILITY of ADS Stage 1, 2, and 3 being impacted. With ADS Stage 1, 2, and 3 still being OPERABLE, requiring opening the RCS could be an unnecessary compensatory measure. In addition, operability of one CMT and the PRHR HX is removed once the RCS is vented (i.e., the result of complying with TS 3.4.13), thus reducing the complement of safety system available to respond to an event.

The licensee stated that Required Action D.1 also represents a potential conflict with any Required Actions that require the RCS pressure boundary intact including Function 18 of TS 3.3.8, Functions 6, 7 and 8 of TS 3.3.9, TS 3.5.7, and TS 3.6.6. The licensee proposed replacing Required Action D.1 to open the RCS pressure boundary with an action to restore compliance with the LCO which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to open the RCS pressure boundary or not.

The licensee stated that the MODE 5 concern addressed by TS 3.4.12 is a postulated loss of normal decay heat removal event. This event is discussed in UFSAR Subsection 19E.4.8.2, Loss of Normal Residual Heat Removal System Cooling in MODE 4 and MODE 5 with Reactor Coolant System Intact.

Therefore, the evaluation of risk significance would focus on the decay heat, the availability of decay heat removal capability, and the availability of vent paths.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.4.12, Automatic Depressurization System (ADS) - Shutdown, RCS Intact, Condition D are acceptable.

3.1.7 Proposed Changes to TS 3.4.13, Automatic Depressurization System (ADS) - Shutdown, RCS Open, Actions C & D When all required flow paths in ADS stage 1, 2, and 3 are open, the RCS is considered vented. In this condition, the open flow paths in ADS stage 1, 2, and 3 provide sufficient vent area that, when combined with the required ADS stage 4 actuation, lower the RCS pressure to enable injection from the IRWST and containment recirculation. This TS specified the number of ADS flow paths required (depending on how long the reactor has been subcritical) and is applicable in MODE 5 with pressurizer level < 20%, MODE 5 with RCS pressure boundary open, and MODE 6 with the upper internals in place.

If current Condition C is entered, the plant must be placed in a condition which minimizes the potential for requiring ADS venting and IRWST injection. The time to RCS boiling is maximized by increasing RCS inventory to 20% pressurizer level and maintaining RCS temperature as low as practical. If the RCS pressure boundary is intact with pressurizer level < 20%, action must be taken immediately to establish an RCS vented condition. Note that, if entered with the reactor subcritical < 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months , it is possible for Condition C to be exited once the reactor has been subcritical 28 hours3.240741e-4 days 0.00778 hours 4.62963e-5 weeks 1.0654e-5 months , provided the applicable LCO requirements are met.

If current Condition D is entered, the plant must be placed in a condition which precludes the need for the ADS vent paths. Action must be initiated, immediately, to remove the upper internals, providing the required vent path. The time to RCS boiling is maximized by increasing RCS inventory and maintaining RCS temperature as low as practical.

The licensee stated that events requiring actuation of ADS valves do not assume a minimum RCS water level, the MODE 5 Required Action C.1 requirement to establish 20% pressurizer level would not be necessary to put the plant within the assumptions of the safety analysis. The licensee proposed replacing the Required Action C.1 to establish pressurizer level with an action to restore compliance with the LCO which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much). The licensee also proposed removing Required Action C.3 which is to Initiate action to establish RCS VENTED condition. The licensee stated that this imposes the same requirement for ADS Stage 1, 2, and 3 flow paths as the LCO itself (i.e., the TS definition of VENTED requires compliance with LCO 3.4.13 for the ADS Stage 1, 2, and 3 flow paths).

Required Action D.1 requires Initiate action to remove the upper internals, which would exit the MODE 6 Applicability. The licensee stated that this will preclude normal outage progression to proceed to MODE 5 with the reactor vessel head on, which would establish an additional fission product boundary. The licensee proposed replacing the Required Action to remove upper internals with an action to restore compliance with the LCO which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to remove the reactor vessel internals. With this proposed change, Required Actions for Conditions C and D become identical. The licensee proposed consolidating Conditions C and D into Action C and deleting Action D.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.4.13, Automatic Depressurization System (ADS) - Shutdown, RCS Open, Conditions C & D are acceptable.

3.1.8 Proposed Changes to TS 3.5.3, Core Makeup Tanks (CMTs) - Shutdown, Reactor Coolant System (RCS) Intact, Action E When the plant is shutdown with the RCS pressure boundary intact, the CMT and PRHR are the preferred methods for mitigation of postulated events such as loss of normal decay heat removal capability (either loss of Startup Feedwater or loss of normal residual heat removal system). The CMT and PRHR are preferred because the RCS pressure boundary can remain intact, thus preserving one of the barriers to fission product release. For these events, the PRHR provides the safety related heat removal path and the CMT maintains RCS inventory control. This TS is applicable in MODE 4 with the RCS cooling provided by the RNS, and MODE 5 with the RCS not vented.

If current Condition E is entered, action must be initiated, immediately, to place the plant in MODE 5 with RCS vented. In this condition, core cooling and RCS makeup are provided by IRWST injection and sump recirculation. With the RCS vented, actuation of ADS stage 4 sufficiently depressurizes the RCS to enable IRWST injection.

The Required Action to establish RCS vented requires entry into and compliance with TS 3.4.13, while exiting the Applicability for TS 3.4.12. The licensee stated that TS 3.5.3 Condition E could be reached without OPERABILITY of ADS Stage 1, 2, and 3 being impacted and that with ADS Stage 1, 2, and 3 still being OPERABLE, requiring the RCS to be vented could be an unnecessary compensatory measure. In addition, operability of the PRHR HX is removed once the RCS is vented, thus reducing the complement of safety system availability to respond to an event. The licensee is proposing to change Required Action E.1 to remove the RCS venting requirement and add new Required Action E.2 to immediately initiate action to restore required CMT to OPERABLE status. The licensee stated that removing the portion of the action to vent the RCS and adding an action to restore one CMT to operable status allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to establish the RCS vented or not.

The licensee stated that the MODE 5 concern addressed by TS 3.5.3 is a postulated loss of normal decay heat removal event. This event is discussed in UFSAR Subsection 19E.4.8.2, Loss of Normal Residual Heat Removal System Cooling in MODE 4 and MODE 5 with Reactor Coolant System Intact.

Therefore, the evaluation of risk significance would focus on the decay heat, the availability of decay heat removal capability, and the availability of vent paths.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.5.3, Core Makeup Tanks (CMTs) - Shutdown, Reactor Coolant System (RCS) Intact, Condition E are acceptable.

3.1.9 Proposed Changes to TS 3.5.5, Passive Residual Heat Removal Heat Exchanger (PRHR HX) -

Shutdown, Reactor Coolant System (RCS) Intact, Action E In the event of a loss of normal decay heat removal capability during shutdown with the RCS pressure boundary intact, the PRHR HX provides the preferred safety related heat removal path. When required, the PRHR HX is manually actuated and can maintain the RCS < 420°F. While there are alternative heat removal systems (i.e., ADS and IRWST), the PRHR HX is preferred because the RCS pressure boundary remains intact, thus preserving a barrier to fission product release. TS 3.5.5 is applicable in MODE 4 with the RCS cooling provided by the RNS, and MODE 5 with the RCS pressure boundary intact and pressurizer level 20%.

If the existing Action E is entered, action must be immediately initiated to be in MODE 5 with the RCS pressure boundary open. In this MODE with the RCS opened, safety related decay heat removal can be immediately initiated by actuation of the IRWST injection valve(s).

The action to establish RCS open requires entry into and compliance with TS 3.4.13 (and thus establish the RCS vented), while exiting the Applicability for TS 3.4.12. The licensee stated that TS 3.5.5 Action E could be reached without OPERABILITY of ADS Stage 1, 2, and 3 being impacted. With ADS Stage 1, 2, and 3 still being OPERABLE, requiring the RCS to be open could be an unnecessary compensatory measure. In addition, operability of the CMT is removed once the RCS is open (i.e., compliance with TS 3.4.13 establishes the vented condition; thereby exiting Applicability for TS 3.5.3, CMT), reducing the complement of safety system available to respond to an event.

The licensee proposed removing part of Required Action E.1 with the RCS pressure boundary open.

In addition, the licensee proposed adding a new Required Action E.2 with a Completion Time to immediately initiate action to restore the PRHR HX to OPERABLE status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to establish the RCS open or not.

The licensee stated that the MODE 5 concern addressed by TS 3.5.5 is a postulated loss of normal decay heat removal event. This event is discussed in UFSAR Subsection 19E.4.8.2, Loss of Normal Residual Heat Removal System Cooling in MODE 4 and MODE 5 with Reactor Coolant System Intact.

Therefore, the evaluation of risk significance would focus on the decay heat, the availability of decay heat removal capability, and the availability of vent paths.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.5.5, Passive Residual Heat Removal Heat Exchanger (PRHR HX) - Shutdown, Reactor Coolant System (RCS) Intact, Condition E are acceptable.

3.1.10 Proposed Changes to TS 3.5.7, In-containment Refueling Water Storage Tank (IRWST) -

Shutdown, MODE 5, Action F For postulated shutdown events in MODE 5 with the RCS pressure boundary intact, the primary protection is the PRHR, where the IRWST serves as the initial heat sink for the PRHR HX. For events in MODE 5 with the RCS pressure boundary open, PRHR is not available and RCS heat removal is provided by IRWST injection and containment sump recirculation.

If current ConditionAction F is entered, the plant must be placed in a condition in which the probability and consequences of an event are minimized to the extent possible which is done by immediately initiating action to place the plant in MODE 5 with the RCS intact with 20% pressurizer level. The time to RCS boiling is maximized by maintaining RCS inventory at 20% pressurizer level and maintaining RCS temperature as low as practical. With the RCS intact, the availability of the PRHR HX is maintained.

The licensee stated that the requirement to establish 20% pressurizer level would not be necessary to put the plant within the assumptions of the safety analysis. The licensee proposed replacing Required Action F.1 to establish water level with an action to restore the IRWST to OPERABLE status. This would allow the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much).

The licensee stated that the MODE 5 concern addressed by TS 3.5.7 is a postulated loss of normal decay heat removal event. This event is discussed in UFSAR Subsection 19E.4.8.2, Loss of Normal Residual Heat Removal System Cooling in MODE 4 and MODE 5 with Reactor Coolant System Intact, and in UFSAR Subsection 19E.4.8.3, Loss of Normal Residual Heat Removal System Cooling in MODE 5 with Reactor Coolant System Open. Therefore, the evaluation of risk significance would focus on the time to boil (i.e., current decay heat, available water inventory, and availability of remaining decay heat removal capability).

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.5.7, In-containment Refueling Water Storage Tank (IRWST) - Shutdown, MODE 5, Condition F are acceptable.

3.1.11 Proposed Changes to TS 3.5.8, In-containment Refueling Water Storage Tank (IRWST) -

Shutdown, MODE 6, Action F For MODE 6, heat removal is provided by IRWST injection and containment sump recirculation. IRWST injection could be required to mitigate some events by providing RCS inventory makeup. TS 3.5.8 is applicable in MODE 6.

If current Condition F is entered, the plant must be placed in a Condition in which the probability and consequences of an event are minimized to the extent possible. In MODE 6, action must be immediately initiated to have the cavity water level 23 feet above the top of the reactor vessel flange.

The time to RCS boiling is maximized by maximizing the RCS inventory and maintaining RCS temperature as low as practical. With the RCS intact, another means of removing decay heat is available (i.e., PRHR HX).

The licensee stated that establishing water level 23 feet above the top of the reactor vessel flange precludes activities necessary to install the reactor vessel head and proceed to MODE 5. Additionally, the licensee stated that the requirement to establish 23 feet above the top of the reactor vessel flange would not be necessary to put the plant within the assumptions of the safety analysis. The licensee proposed to replace Required Action F.1 from establishing water level to initiate action to restore IRWST to OPERABLE status which would allow the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much).

The licensee stated that the MODE 6 concerns addressed by TS 3.5.8 are heat removal and RCS inventory makeup. UFSAR Subsection 19E.2.3.2.3, In-containment Refueling Water Storage Tank, indicates that IRWST is not required due to the large heat capacity of the water in the refueling cavity.

Therefore, the evaluation of risk significance would focus on the decay heat and the availability of water sources for filling the refueling cavity.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.5.8, In-containment Refueling Water Storage Tank (IRWST) - Shutdown, MODE 6, Condition F are acceptable.

3.1.12 Proposed Changes to TS 3.6.4, Containment Pressure, Action C The containment pressure is limited during normal operation to preserve the initial conditions assumed in the accident analyses for a LOCA or SLB. These limits also prevent the containment pressure from exceeding the containment design negative pressure differential with respect to the outside atmosphere in the event of transients which result in a negative pressure. TS 3.6.4 is applicable in MODES 1-4, and MODES 5 and 6 without an open containment air flow path 6 inches in diameter.

The plant must be placed in a condition in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months .

If current Condition C is entered, Required Action C.1 requires that a containment air flow path 6 inches in diameter shall be opened within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months from Condition entry.

For MODES 5 and 6, LCO 3.6.7, Containment Penetrations, requires the capability of closing the containment prior to steaming (e.g., loss of decay heat removal that would lead to steaming in the containment). Therefore, Required Action C.1 represents a potential conflict with a necessary post-event action. The licensee stated that priority of closing the containment during such an event should not be constrained by a conflicting TS Required Action that would apply once the Applicability was reentered when there was no longer an open containment air flow path 6 inches in diameter.

The licensee stated that the MODE 5 and MODE 6 concerns addressed by TS 3.6.4 are excessive cooling resulting in a negative containment pressure below the design limit. UFSAR Section 6.2.1.1.4, External Pressure Analysis, identifies the conservative and bounding evaluation assumptions which are highly unlikely in MODE 5 and MODE 6.

Based on the industry guidance and NRC guidance in NUMARC 91-06 and GL 88-17, the NRC staff agrees that closing the containment is a priority which should not be constrained by a conflicting TS required action to limit the containment pressure from exceeding the containment design negative pressure differential. The licensee has proposed changing Required Action C.1 to open a containment air flow path with the requirement to initiate action to restore containment pressure to within limits. The licensee also proposed changing the required Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to a more restrictive time of Immediately.

The outage risk monitoring DID assessment tool proceduralized in B-ADM-OPS-11 does not evaluate the need to open a containment vent path. As stated in the RAI response to question 11, B-ADM-OPS-011, Key Safety Function 6, Containment Closure will be revised to include actions for the operators to increase RCS inventory thereby raising the ratio of closure time to RCS boil in the event of an ORANGE or RED path is identified.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.6.4, Containment Pressure, Condition C are acceptable.

3.1.13 Proposed Changes to TS 3.6.5, Containment Air Temperature, Action C The containment structure serves to contain radioactive material that may be released from the reactor core following a DBA. The containment average air temperature is limited during normal operation to preserve the initial conditions assumed in the accident analyses for a LOCA or SLB. TS 3.6.5 is applicable in MODES 1, 2, 3, and 4, and MODES 5 and 6 with both containment equipment hatches and both containment airlocks closed.

If current Action C is entered, the plant must be placed in a condition in which the LCO does not apply which is achieved by bringing the plant to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . Once in MODE 5 or 6, Required Action C.1 requires that a containment equipment hatch or a containment airlock shall be opened within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . The opening of a hatch or an airlock is necessary to provide the required vacuum relief path in the event of a low-pressure event if the average air temperature initial condition is not met.

For MODES 5 and 6, LCO 3.6.7, Containment Penetrations, requires the capability of closing the containment prior to steaming (e.g., a loss of decay heat removal that would lead to steaming in the containment). Therefore, Required Action C.1 represents a potential conflict with a necessary post-event action. The licensee stated that the priority of closing the containment during such an event should not be constrained by a conflicting TS required action that would apply once the Applicability was reentered when there was no longer an open containment equipment hatch or containment airlock.

The licensee has proposed replacing the action to open a containment equipment hatch or airlock in Required Action C.1 with an action to restore containment average air temperature to within limits. In addition, the licensee proposed changing the Completion Time of 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to a more restrictive time of Immediately.

Consistent with the industry guidance in NUMARC 91-06 and the staff guidance in Generic Letter 88-17, priority is given to closing containment which should not be constrained by a conflicting TS required action to maintain containment average air temperature by opening a containment equipment hatch or a containment airlock. The outage assessment risk monitoring DID tool proceduralized in B-ADM-OPS-11 does not evaluate the need to open a containment vent path. As stated in the RAI response to question 11, B-ADM-OPS-011, Key Safety Function 6, Containment Closure will be revised to include actions for the operators to increase RCS inventory thereby raising the ratio of closure time to RCS boil in the event of an ORANGE or RED path is identified.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.6.5, Containment Air Temperature, Condition C are acceptable.

3.1.14 Proposed Changes to TS 3.6.6, Passive Containment Cooling System (PCS), Actions E & F The PCS provides containment cooling to limit post-accident pressure and temperature in containment to less than the design values. Reduction of containment pressure reduces the release of fission product radioactivity from containment to the environment, in the event of a DBA. TS 3.6.6 is applicable in MODES 1, 2, 3, and 4, and MODES 5 and 6 with the reactor decay heat > 7.0 MWt.

If current Condition E is entered (in MODE 5), action must be immediately initiated to increase the RCS level to a pressurizer level 20% and to close the RCS so that the PRHR HX operation is available. In this case, the time to RCS boiling is maximized by maximizing the RCS inventory and maintaining RCS temperature as low as practical.

If current Condition F is entered (in MODE 6), action must be immediately initiated to increase the refueling cavity water level 23 feet above the top of the reactor vessel flange. In this case, the time to RCS boiling is maximized by maximizing the RCS inventory and maintaining RCS temperature as low as practical.

The licensee stated that the requirement to establish 20% pressurizer level or 23 ft above the top of the reactor vessel flange would not be necessary to put the plant within the assumptions of the safety analysis.

For Required Actions E.1 and F.1, the licensee proposed replacing the actions to increase water level with an action to restore the PCS to OPERABLE status which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much). Given these proposed changes, Conditions E and F become identical and the licensee proposed consolidating them into Condition E and deleting Condition F.

The licensee stated that the MODE 5 and MODE 6 concern addressed by TS 3.6.6 is a postulated loss of normal decay heat removal event. This event is discussed in UFSAR Subsection 19E.4.8.2, Loss of Normal Residual Heat Removal System Cooling, in MODE 4 and MODE 5 with Reactor Coolant System Intact, and in UFSAR Subsection 19E.4.8.3, Loss of Normal Residual Heat Removal System Cooling, in MODE 5 with Reactor Coolant System Open. While this event during MODE 6 is not discussed in the UFSAR, the concerns are similar while the upper internals remain in place and decay heat is greater than 7 MWt. As such, the evaluation of risk significance would focus on the time to boil (i.e., current decay heat, available water inventory, and availability of remaining decay heat removal capability).

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.6.6, Passive Containment Cooling System (PCS), Conditions E and F are acceptable.

3.1.15 Proposed Changes to TS 3.6.7, Containment Penetrations, Action B Containment closure capability is required during shutdown operations when there is fuel inside containment. Containment closure is required to maintain the cooling water inventory within containment. TS 3.6.7 is applicable in MODES 5 and 6.

If current Conditions B is entered, action must be taken to minimize the probability and consequences of an accident. In MODE 5, action must be immediately initiated to establish a pressurizer level 20%

with the RCS intact so that the PRHR HX operation is available. In MODE 6, action must be immediately initiated to increase the reactor cavity water level 23 feet above the top of the reactor vessel flange. The time to RCS steaming to containment is maximized by maximizing RCS inventory and allowing PRHR HX operation.

The licensee stated that the requirement to establish 20% pressurizer level or 23 ft above the top of the reactor vessel flange would not be necessary to put the plant within the assumptions of the safety analysis.

The licensee proposed replacing the actions to increase water level with an action to restore compliance with the LCO which allows the operations staff to evaluate the risk significance of the condition against the current plant status and make an appropriate informed decision on whether to increase level (and if so by how much).

The licensee stated that the MODE 5 and MODE 6 concern addressed by TS 3.6.7 is a postulated loss of cooling water inventory for RCS heat removal event. This event is discussed in UFSAR Subsection 19E.2.6.2, Design Features to Address Shutdown Safety, identifying that steam release would not be immediate following an accident. As such, the evaluation of risk significance would focus on the time to boil (i.e., current decay heat, available water inventory, availability of remaining decay heat removal capability) and capability for closure of containment.

As stated in the RAI response to question 11, B-ADM-OPS-011, Key Safety Function 6, Containment Closure will be revised to include actions for the operators to increase RCS inventory thereby raising the ratio of closure time to RCS boil in the event of an ORANGE or RED path is identified.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.6.7, Containment Penetrations, Condition B are acceptable.

3.1.16 Proposed Changes to TS 3.6.9, Vacuum Relief Valves, Action G The vacuum relief lines are used to protect the containment vessel from damage due to a negative pressure (e.g., a lower pressure inside than outside). Excessive negative pressure inside containment can occur, if there is a loss of ac power (containment recirculation cooling system (VCS) containment heating not available, reactor trip decay heating only) with a differential (inside to outside) ambient temperature > 90°F. Condition G is applicable when in MODES 5 and 6 without an open containment air flow path 6 inches in diameter.

The current Condition G.1 requires that a containment air flow path 6 inches in diameter shall be opened within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . Any flow path (or paths) with an area equivalent to 6 inches in diameter is adequate to provide the necessary air flow for containment vacuum relief.

The licensee stated that Condition G could be reached with the vacuum relief function still capable of providing a flow path for automatic vacuum relief. For MODES 5 and 6, LCO 3.6.7, Containment Penetrations, requires the capability of closing the containment prior to steaming (e.g., loss of decay heat removal that would lead to steaming in the containment). This represents a potential conflict with a necessary post event action.

The licensee proposed to replace the action to open a containment air flow path with an action to restore compliance with the LCO. In addition, the licensee proposed reducing the Completion Time from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to Immediately.

The licensee stated that the MODE 5 and MODE 6 concerns addressed by TS 3.6.9 are excessive cooling resulting in a negative containment pressure below the design limit. UFSAR Section 6.2.1.1.4, External Pressure Analysis, identifies the conservative and bounding evaluation assumptions which are highly unlikely in MODE 5 and MODE 6. As such, the evaluation of risk significance would focus on the availability of pressure relief capability.

Based on the industry and staff guidance in NUMARC 91-06 and Generic Letter 88-17, respectively, closing the containment is a priority which should not be constrained by a conflicting TS required action to maintain containment average air temperature by opening a containment equipment hatch or a containment airlock. The outage assessment risk monitoring DID tool proceduralized in B-ADM-OPS-11 does not evaluate the need to open a containment vent path. As stated in the RAI response to question 11, B-ADM-OPS-011, Key Safety Function 6, Containment Closure will be revised to include actions for the operators to increase RCS inventory therefore raising the ratio of closure time to RCS boil in the event of an ORANGE or RED path is identified.

Based on its review of the above information along with the information discussed in Section 3.2 (safety analysis), Section 3.3 (TS change consistency), Section 3.4 (maintenance rule) and Section 3.5 (human factors), the NRC staff finds that the proposed changes to TS 3.6.9, Vacuum Relief Valves, Condition G are acceptable.

3.2 Safety Analyses Section 19E.4 of the Vogtle Units 3 and 4 Updated Final Safety Analysis Report (UFSAR) describes the analyses and evaluations of design-basis accidents and transients, as presented in Chapter 15 of the UFSAR, with specific consideration of lower power and shutdown operating modes. The NRC staff has reviewed Section 19E.4 to assess whether the proposed changes, as described in Section 1.1 of this safety evaluation, would affect the results of these evaluations. The proposed changes relate solely to modifications in Required Actions associated with inoperable equipment and do not involve any changes to operator actions in response to transients or accidents. Furthermore, the proposed changes do not alter the assumptions regarding equipment availability during such events. Based on this review, the NRC staff concludes that the proposed changes do not impact the results of the safety analyses documented in UFSAR Section 19E.4.

3.3 TS Change Consistency 10 CFR 50.36(c)(2)(i) states, [l]imiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met. Based on the above, the NRC staff determined that proposed TS changes satisfy the requirements of 10 CFR 50.36(c)(2)(i) because the affected LCOs will continue to specify the lowest functional capability or performance levels of equipment required for safe operation of the facility. In addition, there is reasonable assurance that the actions to be taken when the LCO is not met provide adequate protection of public health and safety and will be completed in a timely manner. The NRC staff also reviewed the proposed TS changes for technical clarity and consistency with the existing requirements for customary terminology and formatting. The NRC staff finds that the proposed changes are consistent with Chapter 16.0 of the SRP and are therefore acceptable.

3.4 Maintenance Rule and Generic Letter 88-17 Section (a)(4) of 10 CFR 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, states:

Before performing maintenance activities (including but not limited to surveillance, post-maintenance testing, and corrective and preventive maintenance), the licensee shall assess and manage the increase in risk that may result from the proposed maintenance activities. The scope of the assessment may be limited to structures, systems, and components that a risk-informed evaluation process has shown to be significant to public health and safety.

As stated in Section 1.0, Summary Description of the Vogtle, Units 3 and 4, shutdown actions LAR (ML25023A275), the changes to the shutdown technical specifications rely on established procedures to manage shutdown risk that implement 10 CFR 50.65 (the Maintenance Rule) through a shutdown DID model which follows NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management (ML14365A203), and NUMARC 93-01, Industry Guidelines for Monitoring the Effectiveness of Maintenance of Nuclear Power Plants (ML18120A069). As stated in Section 3.0, Technical Evaluation of the Vogtle, Units 3 and 4, shutdown actions LAR, Specific SNC controls provided for the purpose of evaluating and reducing risk during shutdown plant evolutions, i.e.,

evaluating shutdown MODES and other conditions prior to entry and conditions involving equipment subsequently determined to be inoperable, include the use of a shutdown DID model that follows NUMARC 91-06 The NRC staff endorsed the use of Revision 4F to NUMARC 93-01 in Revision 4 of RG 1.160 Monitoring the Effectiveness of Maintenance at Nuclear Power Plants (ML18220B281). In RG 1.160 Section 1.8 Scope of Initiators to be Considered for Shutdown Conditions, the staff also endorses NUMARC 91-06 Section 4.0 Shutdown Safety Issues where it is applied in NUMARC 93-01. As stated in the Vogtle, Units 3 and 4, shutdown actions LAR Section 2.2 Current Requirements, the plant UFSAR and technical specification Bases reference the current version of RG 1.160 (revision 4).

Therefore, the licensees use of NUMARC 93-01 and NUMARC 91-06 for implementation of 10 CFR 50.65 section (a)(4) is based on endorsed staff guidance. Future changes to the Vogtle, Units 3 and 4, licensing basis regarding compliance with 10 CFR 50.65, will require the application of the considerations included in 10 CFR 50.59 to determine if prior NRC approval must be obtained before making the change. In addition, continued compliance with the requirements of 10 CFR 50.65(a)(4) are inspected under the NRC Reactor Oversight Program and the Significance Determination Process. The requirements of 10 CFR 50.59, in conjunction with the Vogtle, Units 3 and 4, licensing basis and NRC oversight programs, provide a sufficient level of support for a finding of reasonable assurance that the endorsed methodology will be implemented reliably.

Industrys implementation of the NUMARC 91-06 guidance in conjunction with the committed actions taken in response to Generic Letter (GL) 88-17, Loss of Decay Heat Removal (

Reference:

Loss of Decay Heat Removal - 10 CFR 50.54(f) (Generic Letter No. 88-17)), were found to result in significant risk reductions, as documented in the regulatory analysis provided to the Commission in SECY-97-168, Issuance for Public Comment of Proposed Rulemaking for Shutdown and Fuel Storage Pool Operation (ML20217K211). The reduction in risk was found to be significant enough that it precluded the need for a proposed rulemaking for shutdown operations, as documented in the Federal Register notice withdrawing the proposed rule, Shutdown and Low -Power Operations for Nuclear Power Reactors, in Federal Register notice 64 FR 5623, issued February 4, 1999. SRM-SECY-97-168, Staff Requirements - SECY-97-168 - Issuance for Public Comment of Proposed Rulemaking for Shutdown and Fuel Storage Pool Operation (ML20203G814) states, The Commission expects the staff to continue to monitor licensee performance, through inspections and other means, in the area of shutdown operations to ensure that the current level of safety is maintained.

Although the implementation of NUMARC 91-06 and NUMARC 93-01 are significant to the management of shutdown risk, the guidance found in these documents is not as prescriptive as that found in the current Vogtle, Units 3 and 4, technical specifications (TS) for shutdown operations. The NRC staff reviewed the licensees NUMARC 91-06 implementation programs and procedures as part of the audit to determine if the licensees implementation of maintenance rule during shutdown has the capability to assess conditions and mitigative actions for the LCOs associated with the Vogtle, Units 3 and 4, shutdown actions and mode restraints LARs. NUMARC 91-06 requires the evaluation of DID for five key safety functions - (1) decay heat removal, (2) inventory control, (3) power availability, (4) reactivity control, and (5) containment. These key safety functions are evaluated to ensure they are capable of making an assessment that informs operator action in the absence of prescriptive limiting condition for operations (LCO) actions and mode restraints.

3.4.1 NUMARC 91-06 Shutdown DID Assessment The DID assessments performed per the guidance NUMARC 91-06 Section 3.0 Outage Planning and Control requires evaluations of system availabilities to preclude a loss of any key safety function. It is critical that the DID assessment accurately captures the number of mitigative systems available for each safety function so that the risks posed by shutdown operations at various points of the outage can be dispositioned to inform any decision on the need for mitigative actions or contingency plans. By RAI dated September 30, 2025 (ML25325A350) the NRC staff requested additional information to determine if the DID assessment tool as documented in (B-ADM-OPS-011) sufficiently addresses any shared dependencies of ADS stage 4 for gravity injection using the PXS gravity injection flow path and the RNS gravity injection flow path. In response to the NRC staffs request for additional information by letter dated October 31, 2025 (ML25304A235), the licensee proposed changes to its outage risk assessment monitoring procedure and the shutdown DID software to resolve overcounting of systems which have such a shared dependency. These dependencies include ADS stage 4 and the need for successful containment recirculation. The changes proposed by the licensee are to be made while implementing the license amendment, along with a UFSAR update which documents the changes to their outage risk management program.

The licensee requested changes to numerous LCOs which have Required Actions to open either a containment air flow path 6 inches, the containment equipment hatch, or the containment airlock.

These actions conflict with a Required Action of LCO 3.6.7 - which is to close containment prior to steaming (e.g., loss of decay heat removal that would lead to steaming in containment). In its RAI, the NRC staff requested additional information to determine if the DID assessment evaluates the risk posed by opening containment, or if some other mechanism is in place for the Vogtle, Units 3 and 4, which would prompt consideration of generating such an opening. In its RAI response, the licensee stated that the DID assessment does not evaluate the need to open a containment vent path (only close containment per the containment key safety function). Guidance is provided via alarm response procedures to maintain containment pressure within the appropriate band and to take action if containment pressure drops too low.

The licensee requested changes to numerous LCO which have Required Actions to place the plant reactor coolant system (RCS) at a specified level. The requested changes to the Required Actions provide the licensee with more operational flexibility by eliminating the need to take prescriptive action.

In its RAI, the NRC staff requested additional information to determine if the DID assessment adequately evaluates the impact of RCS level on the overall plant risk profile. In its RAI response, the licensee described how different RCS levels can impact the shutdown DID evaluation. Examples of the RCS levels impact on the DID evaluation include changes to what equipment can be credited for the decay heat removal key safety function, changes to the time-to-boil calculation for evaluating containment closure DID, and changes to the plant operating state (POS).

The licensee requested changes to numerous LCO which have Required Actions to vent the RCS. The requested changes to the LCO Required Actions provide the licensee with more operational flexibility by eliminating the need to take prescriptive action. In its RAI, the NRC staff requested additional information to determine if the DID assessment evaluates the impact of venting the RCS on the overall plant risk profile. In its RAI response, the licensee described how the act of venting the RCS or taking the RCS back to an intact state impacts what POS the plant is in. The change in POS affects what systems can be credited for the DID assessment.

The licensee requested changes to numerous LCO which have Required Actions to remove the reactor vessel upper internals. The NRC staff agrees that plant configurations in Mode 6 with the upper internals installed should be evaluated as drained conditions, which have the highest risk, since the RCS inventory may not communicate with the volume in the refueling cavity for decay heat removal.

The requested changes to the Required Actions found in the technical specifications provide the licensee with more operational flexibility by eliminating the need to take prescriptive action. In its RAI, the NRC staff requested additional information to determine if the DID assessment adequately evaluates the impact of removing the reactor vessel upper internals on the overall plant risk profile. In its RAI response, the licensee described how the status of the installed and removed reactor vessel upper internals affect what systems can be credited in the DID assessment for the decay heat removal and inventory control key safety functions.

The licensee requested changes to numerous LCOs which have Required Actions to establish water level 23 feet above the top of the reactor vessel flange. The requested changes to the Required Actions provide the licensee with more operational flexibility by eliminating the need to take prescriptive action. In its RAI, the NRC staff requested additional information to determine if the DID assessment adequately evaluates the impact of establishing water level 23 feet above the top of the reactor vessel flange on the overall plant risk profile. In its RAI response, the licensee described how the refueling cavity water level affects what systems can be credited in the DID assessment for the containment, decay heat removal, and inventory control key safety functions.

As part of the NRC staffs audit interactions with the licensee, an inaccurate description of the interactions between the venting of the RCS and the establishment of 20% pressurizer level was identified in the original LAR submittal. The licensee corrected this discrepancy in their RAI response.

The licensee requested changes to TS 3.6.7, Containment Penetrations, Required Actions B.1.1 and B.1.2 which would provide the licensee with more operational flexibility by eliminating the need to take a prescriptive action to reach a minimum RCS inventory level. TS 3.6.7 Required Actions B.1.1 and B.1.2 are only entered if it is found that a containment penetration cannot be closed prior to steaming in containment and the penetration cannot be restored in one hour (Required Action A.1). This represents a loss of the containment safety function, which is a significant loss of DID and a loss of a fission product barrier. In its RAI, the NRC staff requested additional information to determine what guidance the operators have during a loss of the containment safety function such that there are appropriate restrictions on placing the plant in risk significant configurations. In its RAI response, the licensee proposed a change to their DID evaluation procedure (B-ADM-OPS-011) to provide operators guidance to increase RCS inventory in the event an orange or red path is identified for the containment key safety function. The proposed procedural changes are to be made by the licensee while implementing the license amendment, along with a UFSAR update which documents the changes to their outage risk management program.

During its audit, the NRC staff assessed the licensees implementation of NUMARC 91-06 by reviewing undocketed supporting documents. Based on the NRC staffs audit, the licensees responses to the NRC staffs request for additional information, the proposed procedural changes to be implemented upon LAR approval, and the above assessment,the NRC staff finds that the licensees proposed implementation and use of the NUMARC 91-06 DID assessment during shutdown operations capable of informing operator action in the absence of the majority of the prescriptive LCO required actions for which changes were requested. For instances where the DID assessment (and associated procedures) do not inform operator action, the licensee described alternate methods including the use of alarm response procedures.

3.4.2 Generic Letter 88-17 The current Vogtle, Units 3 and 4, technical specifications for shutdown operations provide prescriptive requirements and actions to ensure safe plant operation. In the absence of some of those proposed prescriptive LCO actions and mode restraints, and because the industry response to GL 88-17 was significant to the proposed rulemaking on shutdown and low power operations, the NRC staff found it necessary to verify that the licensee is sufficuiently implementing the recommendations of the generic letter. In its RAI, the NRC staff requested additional information to verify that the licensee is adequately implementing the recommended actions of GL 88-17. In its RAI response, the licensee described how they are implementing several expeditious actions from GL 88-17, and proposed procedural changes to include actions for the operators to increase RCS inventory in the event a RED or ORANGE path exists for the containment closure key safety function. As stated in the RAI response to question 11, B-ADM-OPS-011, Key Safety Function 6, Containment Closure will be revised to include actions for the operators to increase RCS inventory therefore raising the ratio of closure time to RCS boil in the event of an ORANGE or RED path is identified. As described in the implementation language of license changes for this amendment, the procedural changes described in the supplements are to be made by the licensee while implementing the license amendment, along with a UFSAR update, which documents the changes to their outage risk management program.

The NRC staff conducted a regulatory audit of the licensees implementation of GL 88-17 by reviewing undocketed supporting documents and analysis. Based on the licensees responses to the staffs RAIs following the audit, the proposed procedural changes and updates to the UFSAR, the NRC staff finds the licensee has sufficiently implemented the GL 88-17 recommended actions which, in part, justify the absence of the prescriptive LCO required actions for the proposed changes.

3.5 Human Factors Assessment The NRC staff reviews the human performance aspects of licensing action requests utilizing guidance in NUREG-1764, Revision 1, Guidance for the Review of Changes to Human Actions (ML072640413).

NUREG-1764 describes human factors reviews as Level I (high risk significance) or Level II (medium risk significance) with the possibility of reduction to a Level III (low risk significance) review, if appropriate. The proposed changes do not introduce new types of operator actions or modify the way plant equipment is operated. In addition, the licensees submittal confirms that the proposed changes involve no significant increase to the plant shutdown, or at-power, risk values reported in Sections 19.9 and 19.19 of the facility UFSAR. Therefore, the NRC staff determined that a Level III human factors review is appropriate per NUREG-1764, Section 2.5, Level of Human Factors Engineering Review for Human Factors.

The proposed changes revise the TS to eliminate potential scenarios where conflicting TS-directed actions could unnecessarily restrict mode changes while the plant is shut down. Mode changes would be allowed in circumstances where the plant risk has been assessed and managed appropriately in accordance with 10 CFR 50.65(a)(4), utilizing the NRC-endorsed risk assessment and management methodology contained in NUMARC 93-01, Section 11, Assessment of Risk Resulting from Performance of Maintenance Activities. Section 3.0, Technical Evaluation, of the submittal under review discusses that section 17.6.1.5 of the facility UFSAR describes that the Maintenance Rule program at Vogtle includes procedures for maintenance risk assessment and management in accordance with 10 CFR 50.65(a)(4). Therefore, the NRC concludes that the proposed changes are encompassed by the existing licensing basis, plant programs, and procedures.

Based on the above, the NRC staff concludes that the proposed changes are procedurally driven, involve no new human-system interfaces, and are encompassed by existing plant programs and procedures. In addition, plant shutdown and at-power operating risk are not increased significantly.

Therefore, the NRC staff concludes that the proposed changes are feasible and reliable and are, therefore, acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on December 8, 2025. On December 18, 2025, the State official confirmed they had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes 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 amendment involves 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 March 21, 2025 (90 FR 12573).

Accordingly, the amendment meets 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 amendment.

6.0 CONCLUSION

Based on the above, the NRC concludes that the proposed changes would continue to meet the requirements of 10 CFR 50.36 and are, therefore, acceptable. 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 amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors:

M. Pohida M. Swim R. Beaton R. Elliott J. Hughey K. Tetter B. Lee A. Stubbs N. Carte Date: February 3, 2026

ML26008A021

via eConcurrence NRR-058 OFFICE NRR/DORL/LPL2-1/PM*

NRR/DORL/LPL2-1/LA*

NRR/DSS/STSB/BC*

NRR/DRA/APLC/BC*

NAME GEMiller KZeleznock SMehta RPascarelli DATE 1/8/2026 1/20/2026 1/20/2026 1/21/2026 OFFICE NRR/DRA/APOB/BC*

NRR/DSS/SNSB/BC*

NRR/DSS/SCPB/BC*

NRR/DEX/EIBC/BC*

NAME APatz NDiFrancesco MValentin SDarbali DATE 1/22/2026 1/21/2026 1/21/2026 1/26/2026 OFFICE NRR/DRO/HFT/TL*

NRR/DORL/LPL2-1/BC*

NAME ADAgostino MMarkley DATE 1/21/2026 2/3/2026

v t e Letter Sequence Approval
EPID:L-2025-LLA-0011, (Approved, Closed)
Initiation Request, Request, Request Acceptance... Administration Meeting Questions 30 September 2025 Answers Results Approval, Approval, Approval, Approval Other: ML25077A233, ML25269A087
MONTHYEAR2025-03-26 [Table View]

Person / Time
ML26008A021
Site:	Vogtle (NFP-091, NPF-092)
Issue date:	02/03/2026
From:	Geoffrey Miller NRC/NRR/DORL/LPL2-1
To:	Coleman J Southern Nuclear Operating Co
References
EPID L-2025-LLA-0011
Download: ML26008A021 (0)
v • d • e

ML26008A021

Text

SUBJECT:

Dear Ms. Coleman:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

3.0 TECHNICAL EVALUATION

Reference:

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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