Text

Request to Revise Technical Specifications Regarding Mode Change Limitations Using the Consolidated Line Item Improvement Process
	ML043030579
Person / Time
Site:	Vogtle
Issue date:	10/26/2004
From:	Grissette D; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-04-0548
	Download: ML043030579 (150)
	v • d • e

Don E. Grissette Southern Nuclear Vice President Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.6474 Fax 205.992.0341 SOUTHERNAEm October 26, 2004 COMPANY Ettergs'to Sera'e otur Mor d-Docket Nos.: 50-424 NL-04-0548 50425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process Ladies and Gentlemen:

In accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications (TS). The proposed changes would revise TS Limiting Conditions for Operations (LCO) 3.0.4, Surveillance Requirement (SR) 3.0.4 and various TS requirements that reference LCO 3.0.4. The proposed changes are based on lndustry/TSTF Standard Technical Specification Change Traveler TSTF-359, Revision 9, "Increased Flexibility in Mode Restraints." The availability of this TS improvement was announced in the Federal Register on April 4, 2003 (68 FR 16579) as part of the Consolidated Line Item Improvement Process (CLIIP).

The proposed changes and their basis are described in Enclosure 1. Marked-up TS and Bases pages are provided in Enclosure 2, and clean-typed pages are provided in Enclosure 3.

SNC requests approval of the proposed changes by November 2005, with the amendment being implemented within 60 days.

This letter contains no NRC commitments. If you have any questions, please advise.

U. S. Nuclear Regulatory Commission NL-04-0548 Page 2 Mr. D. E. Grissette states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

Respectfully submitted, SOU NU AR P G COMPANY Don. E. Grissette Sworn lo andsubscribedbefore me this ___ day of 2004.

Notary Public My commission expires: 4 o DEG/TDH/daj : Basis for Proposed Changes : Marked-up TS and Bases Pages : Clean-typed TS and Bases Pages cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. W. F. Kitchens, General Manager - Plant Vogtle Document Services RTYPE: CVC7000 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle State of Georgia Mr. L. C. Barrett, Commissioner - Department of Natural Resources

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process Basis for Proposed Changes

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process

1.0 DESCRIPTION

The proposed amendment would modify Technical Specification (TS) requirements for MODE change limitations in Limiting Condition for Operation (LCO) 3.0.4 and Surveillance Requirement (SR) 3.0.4. The changes are consistent with Nuclear Regulatory Commission (NRC) approved Industry/Technical Specification Task Force (TSTF) Standard TS (STS) change TSTF-359, Revision 8, as modified by the notice in the Federal Register published on April 4, 2003 (68 FR 16579). That Federal Register Notice (FRN) announced the availability of this TS improvement through the Consolidated Line Item Improvement Process (CLIIP).

TSTF-359, Revision 8 was subsequently revised to incorporate the modifications discussed in the April 4, 2003 FRN and other minor changes. TSTF-359, Revision 9 was subsequently submitted to the NRC on April 28, 2003 and was approved by the NRC on May 9, 2003.

2.0 PROPOSED CHANGE

S Southern Nuclear Operating Company (SNC) proposes to revise the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications (TS). The proposed changes would revise TS Limiting Conditions for Operation (LCO) 3.0.4, Surveillance Requirements (SR) 3.0.4 and various TS requirements that reference LCO 3.0.4. The proposed changes are based on Industry/TSTF Standard Technical Specification Change Traveler TSTF-359, Revision 9, "Increased Flexibility in Mode Restraints." The following is a detailed description of the proposed changes.

Section 1.4, Frequency, Example 1.4-1 is revised to be consistent with the proposed changes to SR 3.0.4 and LCO 3.0.4 as described below. As such, this change is administrative in nature.

LCO 3.0.4 is revised to allow entry into a MODE or other specified condition in the Applicability (MOSCA) while relying on the associated ACTIONS, provided that (a) the ACTIONS to be entered permit continued operation in the MOSCA for an unlimited period of time, or (b) there is a risk assessment performed which justifies the use of LCO 3.0.4 for a MOSCA change, or (c) an NRC-approved allowance is provided in the Specification to be entered. The Applicability of LCO 3.0.4 is expanded to include transition into all MODES (including MODES 5 and 6) or other specified conditions in the Applicability, while retaining the exception that LCO 3.0.4 shall not prevent MOSCA changes that are required to comply with ACTIONS or that are part of a shutdown of the unit. The associated Bases are likewise being modified in accordance with TSTF-359, Revision 9.

SR 3.0.4 is revised to reflect the concepts of the change to LCO 3.0.4. The Applicability of LCO 3.0.4 and SR 3.0.4 is expanded to include transition into all MODES or other specified conditions in the Applicability, except when required to comply with ACTIONS or that are part of a shutdown of the unit.

The associated Bases likewise are being modified in accordance with TSTF-359, Revision 9.

EI-I

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process

TS 3.1.1, "Shutdown Margin (SDM)," the ACTIONS Note is revised to delete reference to entry into Mode 5 from Mode 6.

TS 3.3.1, "RTS Instrumentation," the Note in Condition C is revised to include MODES 3 and 4.

TS 3.3.3, "Post Accident Monitoring (PAM) Instrumentation," the Note "LCO 3.0.4 is not applicable," is deleted.

TS 3.3.4, "Remote Shutdown System," the Note "LCO 3.0.4 is not applicable,"

is deleted.

TS 3.3.8, "High Flux at Shutdown Alarm," the Note in Required Action A. I is revised to state that LCO 3.0.4c is applicable provided that Required Actions B. I and B.2 are met.

TS 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," the Action Note is deleted.

TS 3.4.1 1,"Pressurizer Power Operated Relief Valves (PORVs)," the Note "LCO 3.0.4 is not applicable," is deleted.

TS 3.4.12, "Cold Overpressure Protection System (COPS)," Actions Note 1 is revised to indicate that the new LCO 3.0.4b provision is not applicable when entering MODE 4 in addition to the existing restrictions on entering MODE 6 with the reactor vessel head on from MODE 6, and entering MODE 5 from MODE 6 with the reactor vessel head on.

TS 3.4.15, "RCS Leakage Detection Instrumentation," the Notes in Required Actions for Conditions A, B, and C stating "LCO 3.0.4 is not applicable," are deleted.

TS 3.4.16, "RCS Specific Activity," an Actions Note permitting the use of the new LCO 3.0.4c provision is substituted for the existing LCO 3.0.4 non-applicability Note.

TS 3.5.3, "Emergency Core Cooling Systems (ECCS)," an Actions Note is added to indicate that the new LCO 3.0.4b is not applicable to ECCS centrifugal charging pump subsystem.

TS 3.6.7, "Hydrogen Recombiners," the Note in Required Action A. I, "LCO 3.0.4 is not applicable," is deleted.

TS 3.7.4, "Atmospheric Relief Vales (ARVs)," the Note in Required Action A. 1, "LCO 3.0.4 is not applicable," is deleted.

TS 3.7.5, "Auxiliary Feedwater (AFWV) System," an Actions Note is added to indicate that the new LCO 3.0.4b provision is not applicable when entering MODE 1.

TS 3.7.9, "Ultimate Heat Sink," the Note in Required Action Condition C, "LCO 3.0.4 is not applicable," is deleted.

TS 3.7.10, "Control Room Emergency Filtration System (CREFS)-Both Units Operating," the Notes in the Required Actions for Conditions E and F, "LCO 3.0.4 is not applicable," are deleted.

TS 3.7.1 1,"Control Room Emergency Filtration System (CREFS)-One Unit Operating," the Note in Required Action Condition G, "LCO 3.0.4 is not applicable," is deleted.

El-2

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process

TS 3.7.12, "Control Room Emergency Filtration System (CREFS)-Both Units Shutdown," the Note in Required Action Condition F, "LCO 3.0.4 is not applicable," is deleted.

TS 3.8.1, "AC Sources - Operating," an Actions Note is added to indicate that the new LCO 3.0.4b provision is not applicable to diesel generators.

TS 3.9.1, "Boron Concentration," the Actions Note is deleted.

TS 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level," the Actions Note is deleted.

3.0 BACKGROUND

The early standard Technical Specifications contained Specifications 3.0.4 and 4.0.4 that prohibited entering the Applicability of an LCO with the LCO or Surveillances not met unless a specific exception was provided. NRC Generic Letter 87-09, "Sections 3.0 and 4.0 of the Standard Technical Specifications (STS) on the Applicability of Limiting Conditions For Operation and Surveillance Requirements," June 4, 1987, modified Specifications 3.0.4 and 4.0.4 to allow entering the Applicability of a Specification with the LCO not met when the Actions to be entered would allow operation within the Applicability for an unlimited period of time. It stated, in part:

"With respect to unnecessary MODE changes, Specification 3.0.4 unduly restricts facility operation when conformance with Action Requirements provides an acceptable level of safety for continued operation. For an LCO that has Action Requirements permitting continued operation for an unlimited period of time, entry into an operation mode or other specified condition of operation should be permitted in accordance with the Action Requirements. The solution also resolves the problem of inconsistent application of exceptions to Specification 3.0.4: (a) which delays startup under conditions in which conformance to the Action Requirements establishes an acceptable level of safety for unlimited continued operation of the facility; and (b) which delays a return to power operation when the facility is required to be in a lower mode of operation as a consequence of other Action Requirements."

In the development of Improved Standard Technical Specifications (ISTS), many improvements were made to Specifications 3.0.4 and 4.0.4 (editorially becoming LCO 3.0.4 and SR 3.0.4) including clarification of its applicability regarding normal shutdown and Required Action shutdowns, and MODE changes during Cold Shutdown (MODE 5) and Refueling Operations (MODE 6). Despite these changes, ISTS LCO 3.0.4 and SR 3.0.4 were still overly restrictive. The startup of a unit may be unnecessarily delayed due to the current restrictions of LCO 3.0.4. For example, a single maintenance activity that is almost complete can cause significant delays and changes in the previously well thought out plans for returning the unit to service. In such situations, allowing the unit to enter the MOSCA would allow the work to be completed while reducing the likelihood of human error caused by expediting the completion of required Surveillances and maintenance activities.

El-3

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process While the inoperabilities permitted by the Completion Times of Technical Specification Required Actions take into consideration the safety significance and redundancy of the system or components within the scope of an LCO, the Completion Times generally do not address or consider concurrent system or component inoperabilities in multiple LCOs.

Therefore, the performance of the 10 CFR 50.65(a)(4) risk assessment which looks at the entire plant configuration is essential (and required) prior to changing operational MODE.

The 10 CFR 50.65(a)(4) risk assessment will be used to confirm (or reject) the appropriateness of transitioning up in MODE, or other change in the specified condition in the Applicability, given the actual status of plant safety equipment. TSTF-359, Revision 8 was approved by the NRC, with changes, and a Notice of Availability was published in the Federal Register on April 4, 2003 (68 FR 16579). TSTF-359, Revision 9 was created to incorporate those changes and was approved by the NRC on May 9, 2003.

4.0 TECHNICAL ANAINSES 4.1 Applicability of Published Safety Evaluation SNC has reviewed the NRC safety evaluation dated April 4, 2003 as part of the CLIIP.

This review included the NRC staff's evaluation, as well as the supporting information provided for TSTF-359, Revision 8, and included the consideration of the updates made in TSTF-359, Revision 9. SNC has concluded that the justifications presented in the approved TSTF and the safety evaluation prepared by the NRC staff are applicable to VEGP and justify this amendment for the incorporation of the changes to the VEGP TS.

4.2 Optional Changes and Variations SNC is not proposing any variations or deviations from the model TS and TS Bases changes for LCO 3.0.4 and SR 3.0.4 described in the modified TSTF-359, Revision 8 (as reflected in final form by Revision 9).

However, due to differences between the VEGP TS and TS Bases and the model STS in NUREG-143 1, Revision 2, "Standard Technical Specifications, Westinghouse Plants,"

variations from the TSTF mark-ups are required in some cases. These variations are discussed below, but they do not invalidate the NRC staffs model safety evaluation supporting the adoption of TSTF-359, Revision 9.

Special LCO 3.0.4 Notes Added During ITS Conversion Prior to the approval of TSTF-359, Revision 9, ISTS LCO 3.0.4 and SR 3.0.4 contained a Reviewer's Note which required a plant-specific evaluation and, if necessary, application of specific restrictions on MODE changes or Required Actions in individual LCOs. The Federal Register Notice of Availability (68 FR 16586 dated 4/4/2003) states:

"The notes limiting the applicability of LCO 3.0.4 and SR 3.0.4 are no longer needed and are removed by TSTF-359, Revision 8. The industry owners group analyses would subsequently support adding notes to various TS, as defined by EI-4

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process the tables of higher-risk systems, precluding entry into Modes 5 and 6 for PWRs, and Modes 4 and 5 for BWRs. However, the addition of notes in these cases is made unnecessary by action statements that require immediate completion times, which means that entry into the Mode or other specified condition in the Applicability is not allowed and the notes would be superfluous."

The Federal Register Notice (68 FR 16588) further states:

"In addition, mode transitions for Modes 5 and 6 for PWRs, and Modes 4 and 5 for BWRs, w'ill be addressed by administrative controls."

NEI 03-10, "Risk-informed Technical Specifications Initiative 3, Increased Flexibility in Mode Restraints (TSTF-359), Industry Implementation Guidance," August 2003 (page A-

9) and TSTF-359 Revision 9 (Proposed Change section of the travelerjustification) both indicate that any plant-specific Notes restricting MODE changes added as a result of the evaluation required by the STS 3.0.4 Reviewer's Note are to be deleted.

SNC added the following special LCO 3.0.4 Notes to the TS during the ITS conversion.

The following discussions provide additional justification for deleting these Notes:

In TS 3.1.1, "SHUTDOWN MARGIN (SDM)," the Action Note requires that while the LCO is not met, transition to a lower MODE in the Applicability, and entry into MODE 5 from MODE 6 is not permitted. This Note addresses both transition to a lower MODE in the Applicability (e.g., shutting down) as well as moving up from MODE 6 to MODE 5. With regard to moving up from MODE 6 to MODE 5, the following considerations apply. The NRC's model safety evaluation (68 FR 16586) states that "LCO 3.0.4 allowances related to values and parameters of TS are not typically addressed by LCO 3.0.4(b) risk assessments, and are therefore addressed by a new LCO 3.0.4(c)." In addition NEI 03-10 (page 5) states "....unless a note is provided specifically exempting an individual value and parameter specification, the LCO 3.0.4c guidance is not applicable."

NEI 03-10 further states (pages 5 and 6) that LCO 3.0.4a and LCO 3.0.4b may be applicable for value or parameters used to demonstrate system or component operability. However, since SDM does not demonstrate system or component operability, LCO 3.0.4a and LCO 3.0.4b are not applicable in this case.

Therefore, since SDM is a parameter that is not used to demonstrate system or component operability, and SNC does not propose to add an LCO 3.0.4c note for the purpose of transitioning from MODE 6 to MODE 5, the portion of the Action Note prohibiting entry into MODE 5 from MODE 6 is superfluous and is therefore deleted.

On the other hand, LCO 3.0.4 does not preclude a unit shutdown while not meeting a LCO. Therefore, in the absence of a prohibition, LCO 3.0.4 would allow transition to a lower MODE within the applicability of LCO 3.1.1 without E1-5

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process the required SDM. Since the boron dilution analysis in MODES 3 and 4, and MODE 5 with the loops filled, relies on the boration requirements specified in the COLR, transition to a lower MODE within the requisite SDM may not be prudent, and this portion of the existing Actions Note is retained.

In TS 3.4.8, "RCS Loops - MODE 5, Loops Not Filled," the Actions Note is deleted. This Note requires that while the LCO is not met, entry into MODE 5 Loops Not Filled from MODE 5 Loops Filled is not pennitted. The intent of this Note is to retain the heat removal path afforded by the steam generators when the Residual Heat Removal system is degraded. Since LCO 3.4.8 contains Required Actions with immediate Completion Times, this plant-specific Note is unnecessary given that entry into the LCO is not allowed with the LCO requirements not met. This plant-specific Applicability Note is superfluous and is therefore deleted.

In TS 3.9.1, "Boron Concentration," the Actions Note is deleted. This Note requires that while the LCO is not met, entry into MODE 6 from MODE 5 is not permitted. HIoowever, since LCO 3.9.1 contains Required Actions with immediate Completion Times, this plant-specific Note is unnecessary since entry into the LCO is not allowed with the LCO requirements not met. This will assure that core reactivity is maintained within limits during fuel handling operations. This plant-specific Note is superfluous and is therefore deleted.

In TS 3.9.6, "Residual Hleat Removal (RI-IR) and Coolant Circulation - Low Water Level," the Actions Note is deleted. This Note requires that while the LCO is not met, entry into this LCO is not permitted. Since LCO 3.9.6 contains Required Actions wvith immediate Completion Times related to the restoration of the degraded decay heat removal function, this plant-specific Note is unnecessary since entry into the LCO is not allowed with the LCO requirements not met. This plant-specific Note is superfluous and is therefore deleted.

Mark-ups Required for Consistency with VEGP TS In addition to the deletion of the special LCO 3.0.4 Notes discussed above, the following changes are required to the VEGP TS in order to fully satisfy the intent of the TSTF-359, Revision 9 changes:

In TS 3.3.1, Condition C is currently modified by a Note which is applicable in Mode 5 only because the current version of LCO 3.0.4 would prevent Mode ascension in Modes 3 and 4. However, because the proposed revision to LCO 3.0.4 would make the provisions of proposed LCO 3.0.4b applicable in Modes 3 and 4 as well as Mode 5, the proposed change would revise this Note so that it is applicable in Modes 3 and 4 as well as Mode 5.

In TS 3.3.8, "IHligh Flux at Shutdown Alarm (IIFASA)," Required Action A. I is currently modified by a Note that permits MODE changes only when Required El -6

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process Action B. I and B.2 are met. The proposed change would revise this Note to state that LCO 3.0.4c is applicable provided that Required Actions B. I and B.2 are met. The purpose of the HFASA is to mitigate the design basis boron dilution event. Required Action B. l is a periodic verification of shutdown margin, and Required Action B.2 ensures that the unborated water source isolation valves are shut, thereby precluding the design basis boron dilution event. Therefore, Required Actions B. I and B.2 provide an acceptable level of safety to facilitate mode changes with one channel of H-IFASA inoperable.

In the TSTF mark-ups, STS 3.5.3, "ECCS - Shutdown," an Actions Note is added to indicate that the new LCO 3.0.4b provision is not applicable to the ECCS high head subsystem. In the VEGP TS, the same Actions Note is added but the Note uses the VEGP-specific terninology of "ECCS centrifugal charging pump subsystem." This is strictly an editorial change reflecting plant-specific terminology.

In the TSTF mark-ups, STS 3.6.9, "Hydrogen Mixing System (IIMS)," is modified. The VEGP TS do not have this LCO, so no changes are needed.

In the TSTF mark-ups, STS 3.7.4, "Atmospheric Dump Valves (ADVs)," is revised to delete the Note in Required Action A. 1. The equivalent VEGP TS is titled "Atmospheric Relief Valves (ARVs)," and the same change is made to delete the Note in Required Action A. 1. Future MODE changes with one or more ARVs inoperable because of excessive seat leakage will be evaluated pursuant to the new LCO 3.0.4b.

5.0 REGULATORY ANALYSIS

5.1 No Significant Hazards Consideration SNC has reviewed the proposed no significant hazards consideration determination (NSIICD) published in the Federal Register as part of the CLIIP. SNC has concluded that the NSHCD presented in the Federal Register notice is applicable to VEGP and is, hereby, incorporated by reference to satisfy the requirements of 10 CFR 50.91(a).

5.2 Verification And Commitments As discussed in the notice of availability published in the Federal Register on April 4, 2003 (68 FR 16593), plant-specific verifications were performed as discussed below.

SNC has established TS Bases for LCO 3.0.4 and SR 3.0.4 which state that use of the TS MODE change limitation flexibility established by LCO 3.0.4 and SR 3.0.4 is not to be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the TS Applicability.

El-7

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process The modification also includes changes to the Bases for LCO 3.0.4 and SR 3.0.4 that provide details on how to implement the new requirements. The Bases changes provide guidance for changing MODES or other specified conditions in the Applicability when an LCO is not met. The Bases changes describe in detail how:

LCO 3.0.4a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; LCO 3.0.4b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; and LCO 3.0.4c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification, w~hich is typically applied to Specifications which describe values and parameters (e.g.

Containment Air Temperature, Containment Pressure, Moderator Temperature Coefficient), though it may be applied to other Specifications based on NRC plant-specific approval.

The Bases also state that any risk impact should be managed through the program in place to implement 10 CFR 50.65(a)(4) and its implementation guidance, NRC Regulatory Guide 1.182, "Assessing and Managing Risks Before Maintenance Activities at Nuclear Power Plants," and that the results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. In addition, the Bases state that upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the TS. The Bases also state that SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

The TS Bases will be revised to reflect the changes to the affected TS and will be implemented in accordance with TS 5.5.14, "Technical Specification (TS) Bases Control Program," as part of the implementation of this amendment, upon NRC approval of this amendment application.

El -8

Enclosure I Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process

6.0 ENVIRONMENTAL CONSIDERATION

SNC has reviewed the environmental evaluation included in the model safety evaluation dated April 4, 2003 as part of the CLIIP. SNC has concluded that the staffs findings presented in that evaluation are applicable to VEGP and the evaluation is hereby incorporated by reference for this application.

El -9

Enclosure 2 Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process Marked-up TS and Bases Pages

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-1 SINGLE FREQUENCY (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Example 1.4-3), then SR 3.0.3 becomes applicable.

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, the Sure.'oillanco must be t- - r- - -~i..:th_ t_ thy__ . -- -. m .- T - - - , p %rant*i^tt

-S-D - - e- to-t-trt .'

S acmufmOi E ornotherr cT Oneseo:>t1 5. pclitfdTu rcutty into the MODE orother spcfe"'diK Fa'r tod owuld Fesult

- - -. A_._'

elf- '^^D A Inf a viuoaLtuI Uo aml .u.u then SR 3.0.4 becomes applicable. The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

(continued)

Vogtle Units 1 and 2 1.4-2 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

LCO Applicability 3.0 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY LCO 3.0.1 LCOs shall be met during the MODES or other specified conditions in the Applicability, except as provided in LCO 3.0.2.

LCO 3.0.2 Upon discovery of a failure to meet an LCO, the Required Actions of the associated Conditions shall be met, except as provided in LCO 3.0.5 and LCO 3.0.6.

If the LCO is met or is no longer applicable prior to expiration of the specified Completion Time(s), completion of the Required Action(s) is not required unless otherwise stated.

LCO 3.0.3 When an LCO is not met and the associated ACTIONS are not met, an associated ACTION is not provided, or if directed by the associated ACTIONS, the unit shall be placed in a MODE or other specified condition in which the LCO is not applicable. Action shall be initiated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months to place the unit, as applicable, in:

a. MODE 3 within 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months ;

b. MODE 4 within 13 hours1.50463e-4 days 0.00361 hours 2.149471e-5 weeks 4.9465e-6 months ; and

c. MODE 5 within 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months .

Exceptions to this Specification are stated in the individual Specifications.

Where corrective measures are completed that permit operation in accordance with the LCO or ACTIONS, completion of the actions required by LCO 3.0.3 is not required.

LCO 3.0.3 is only applicable in MODES 1, 2, 3, and 4.

LCO 3.0.4 When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when ethassociated ACTIONS to be cntered permit continued (continued)

Vogtle Units 1 and 2 3.0-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

LCO Applicability 3.0 3.0 LCO APPLICABILITY LCO 3.0.4 opcration iRthc MODE or other pcprified condition in the (continued) Applicability for an unlimited period of time. This Spccification shall not prevent changes in MODES orFother specified Gonditions in the Applicability that arc required to comply with ACTIONS or that arc part of a shutdown of the unit.

Exceptions to this Specification arc stated in the individual Specifications.

These exceptions allow cntry into MODES or other spccified conditions in the Applicability when the associated ACTIONS to be entered allow unit operation in the MODE or other specified condition in the Applicability only for a limited period of time.

LCO 3.0.1 is only applicable for entry into a MODE or other specified oRdit;ion iR the Applicability in MODES 1, 2, 3, and 4.

LCO 3.0.5 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the testing required to demonstrate OPERABILITY.

LCO 3.0.6 When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.15, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.

When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.

(continued)

Vogtle Units 1 and 2 3.0-2 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

INSERT I When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall only be made:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time; or

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate; exceptions to this Specification are stated in the individual Specifications; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SR Applicability 3.0 3.0 SR APPLICABILITY SR 3.0.3 When the Surveillance is performed within the delay period (continued) and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.

SR 3.0.4 Entry into a MODE or other spccified condition in the Applicability of an LCO shall not be made uness the LCO's Surweillanecs have been met I INSERT 2 within their spocified FrcgqueRy. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that arc required to comply with ACTIONS or that arc part of a shutdown of the I

SR 3.0.1 is only applicable for entry into a MODE or other specified GGndition in the Applicability in MODES 1, 2, 3, and 4.

Vogtle Units 1 and 2 3.0-5 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

INSERT 2 Entry into a MODE or other specified condition in the Applicability of an LCO shall only be made when the LCO's Surveillances have been met within their specified Frequency, except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SDM 3.1.1 3.1 REACTIVITY CONTROL SYSTEMS 3.1.1 SHUTDOWN MARGIN (SDM)

LCO 3.1.1 SDM shall be 2 the limit specified in the COLR.

APPLICABILITY: MODES 3, 4, and 5.

ACTIONS

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

While this LCO is not met, transition to a lower MODE within the Applicabilit and cntry y IM is not permitted.

CONDITION REQUIRED ACTION COMPLETION TIME A. SDM not within limit. A.1 Initiate boration to restore 15 minutes SDM to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.1.1.1 Verify SDM is 2 the limit specified in the COLR. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Vogtle Units 1 and 2 3.1.1-1 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

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

APPLICABILITY: According to Table 3.3.1-1.

ACTIONS

NOTE-Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more Functions A.1 Enter the Condition Immediately with one or more referenced in required channels Table 3.3.1-1 for the inoperable. channel(s).

B. One Manual Reactor Trip B.1 Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months channel inoperable. OPERABLE status.

OR I MODES 3, 4, or 5 B.2 Be in MODE 3. 54 hours6.25e-4 days 0.015 hours 8.928571e-5 weeks 2.0547e-5 months C. ---------- NOT -------------- C.1 Restore channel or train 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months While this LCp is not met to OPERABLE status.

for Functions , 17, 18, or 19 in I9E, OR closing the reactor trip breakers is not permitted. C.2 Open RTBs. 49 hours5.671296e-4 days 0.0136 hours 8.101852e-5 weeks 1.86445e-5 months One channel or train inoperable.

(continued)

Vogtle Units 1 and 2 3.3.1-1 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

PAM Instrumentation 3.3.3 3.3 INSTRUMENTATION 3.3.3 Post Accident Monitoring (PAM) Instrumentation LCO 3.3.3 The PAM instrumentation for each Function in Table 3.3.3-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

POO r-".A --------------------------------------------------------

1-1 I "G '2 0.4 is not ap El Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more functions A.1 Enter the applicable Immediately with one or more Condition referenced in required channels Table 3.3.3-1 for the inoperable. channels.

B. -----------NOTE------------ B.1 Restore the channel to 30 days For containment OPERABLE status.

isolation valve position indication, separate Condition entry is allowed for each penetration flow path.

One required channel inoperable.

(continued)

Vogtle Units 1 and 2 3.3.3-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

Remote Shutdown System 3.3.4 3.3 INSTRUMENTATION 3.3.4 Remote Shutdown System LCO 3.3.4 The Remote Shutdown System Functions in Table 3.3.4-1 shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS 4-r ,,-- - - - - - - - - - - - - - - - - - - - - - - - - - - -

3.0.4 is net apliabJ.-. 'J'.

E. Separate Condition entry is allowed for each Function.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more required A.1 Restore required Function 30 days Functions inoperable. to OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Vogtle Units 1 and 2 3.3.4-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

High Flux at Shutdown Alarm 3.3.8 3.3 INSTRUMENTATION 3.3.8 High Flux at Shutdown Alarm (HFASA)

LCO 3.3.8 Two channels of HFASA shall be OPERABLE.

APPLICABILITY: MODES 3, 4, and 5

I------I------------------------I\I.

The HFASA may be blocked in MODE 3 during reactor startup.

ACTIONS COMPLETION CONDITION REQUIRED ACTION TIME A. One channel of HFASA A.1 --------------- NOTF--------------

LCO 3.0.4c is inoperable. Exception to LCG'3.0.4: / I- applicable provided MQDE ch'anges,.are onlV Required Actions permittf whe 'Requrebd A ctions' 8.1 a4d B.2 are met B.1 and B.2 are met.

Restore channel to 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months OPERABLE status.

B. Required Action and B.1 Perform SR 3.1.1.1 (verify 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated Completion SDM).

Time of Condition A not AND met.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter OR Two channels of AND HFASA inoperable.

B.2 Perform SR 3.9.2.1 (verify 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months unborated water source isolated). AND Once per 14 days thereafter Vogtle Units 1 and 2 3.3.8-1 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

RCS Loops - MODE 5, Loops Not Filled 3.4.8 ACTIONS FkITU I

WWIle this LCO is notRmeA Lith into MODE 5 Mentr, RCS loops not filled is not permitte4-CONDITION REQUIRED ACTION COMPLETION TIME A. One RHR loop inoperable. A.1 Initiate action to restore Immediately RHR loop to OPERABLE status.

B. Required RHR loops B.1 Suspend all operations Immediately inoperable. involving reduction in RCS boron concentration.

OR AND No RHR loop in operation.

B.2 Initiate action to restore Immediately one RHR loop to OPERABLE status and to operation.

C. One or more valves used C.1 Initiate action to secure Immediately to isolate unborated water valve(s) in closed sources not secured in position.

closed position. II SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.8.1 Verify one RHR loop is in operation. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months SR 3.4.8.2 Verify correct breaker alignment and indicated power 7 days are available to the required RHR pump that is not in operation.

SR 3.4.8.3 Verify each valve that isolates unborated water 31 days sources is secured in the closed position.

Vogtle Units 1 and 2 3.4.8-2 Amendment No. 108 (Unit 1)

Amendment No. 86 Unit 2)

Pressurizer PORVs 3.4.11 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs)

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

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

NOTI Fl --

3 Separate Condition entry is allowed for each LCO 304 i;- otae lcbl 12-CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 Close and maintain power 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months inoperable and capable to associated block valve.

of being manually cycled.

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

manually cycled.

AND B.2 Remove power from 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months associated block valve.

AND B.3 Restore PORV to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OPERABLE status.

(continued)

Vogtle Units 1 and 2 3.4.11-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

LCO 3.0.4b is not applicable for entry into MODE COPS 4, entry into MODE 6 with the reactor vessel head 3.4.12 on from MODE 6, and entry into MODE 5 from MODE 6 with the reactor vessel head on.

ACTIO S MfVTIZ/o'"M 1.

. I-------.----------------------------------------------

While this ICGO is net mo,-entry into MOI BE 6A with teretor vosIo h-ad on from MODE 6, and ontry' into MODE 5 from MODE 6 with tho reactor VOeel head on he not permittod.

2. With one required PORV inoperable for the purpose of cold overpressure protection, entry into MODE 4 from MODE 3 is permitted provided that RCS temperature is maintained above 2750F, and, within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , either: the PORV is restored to OPERABLE status; or, an RHR suction relief valve is placed in service so that the requirements of LCO 3.4.12 are met. Otherwise, the reactor vessel must be depressurized and vented in accordance with Required Action F.1.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more safety A.1 Render all safety injection 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months injection pumps capable pumps incapable of injecting of injecting into the RCS. into the RCS.

B. An accumulator not B.1 Isolate affected accumulator. 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months isolated when the accumulator pressure is greater than or equal to the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

C. Required Action and C.1 Increase RCS cold leg 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months associated Completion temperature to > 350 0F.

Time of Condition B not met. OR C.2 Depressurize affected 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months accumulator to less than the maximum RCS pressure for existing cold leg temperature allowed in the PTLR.

D. One required RCS relief D.1 Restore required RCS relief 7 days valve inoperable in valve to OPERABLE status.

MODE 4.

(continued)

Vogtle Units 1 and 2 3.4.12-2 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

RCS Leakage Detection Instrumentation 3.4.15 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.15 RCS Leakage Detection Instrumentation LCO 3.4.15 The following RCS leakage detection instrumentation shall be OPERABLE:

a. The containment normal sumps level and reactor cavity sump monitors;

b. One containment atmosphere radioactivity monitor (gaseous or particulate); and

c. Either the containment air cooler condensate flow rate or a containment atmosphere gaseous or particulate radioactivity monitoring system not taken credit for in item b.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One containment sump NOTE monitor inoperable. LCO 3.0.1 i4 notapplicable.

A.1 Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months B. Two or more NOTE containment sump LCO 3.0.4 is not applicable.

monitors inoperable B.1 Perform SR 3.4.13.1 Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND B.2 Restore at least two 30 days containment sump monitors to OPERABLE status.

(continued)

Vogtle Units 1 and 2 3.4.15-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

RCS Leakage Detection Instrumentation 3.4.15 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. Required containment _--NOTE--

atmosphere radioactivity LCO 3.0.4 is not applicable.

monitor(s) inoperable.

C.1.1 Analyze grab samples of Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months the containment atmosphere.

OR C.1.2 Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months AND C.2.1 Restore required 30 days containment atmosphere radioactivity monitor(s) to OPERABLE status.

OR C.2.2 Verify containment air 30 days cooler condensate flow rate monitor is OPERABLE.

D. Required containment D.1 Perform SR 3.4.15.2. Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months air cooler condensate flow rate monitor OR inoperable.

D.2 Perform SR 3.4.13.1. Once per 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months (continued)

Vogtle Units 1 and 2 3.4.15-2 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

RCS Specific Activity 3.4.16 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 RCS Specific Activity LCO 3.4.16 The specific activity of the reactor coolant shall be within limits.

APPLICABILITY: MODES 1 and 2, MODE 3 with RCS average temperature (Tavg) 2 500 0F.

ACTIONS ,<c PSI,.4 LCO 3.0.4is i applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. DOSE EQUIVALENT A.1 Verify DOSE Once per 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months 1-131 > 1.0 gCi/gm. EQUIVALENT 1-131 within the acceptable region of Figure 3.4.16-1.

AND A.2 Restore DOSE 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months EQUIVALENT 1-131 to within limit.

B. Gross specific activity of B.1 Perform SR 3.4.16.2. 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months the reactor coolant not within limit. AND B.2 Be in MODE 3 with 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Tavg < 500'F.

(continued)

Vogtle Units 1 and 2 3.4.16-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

ECCS - Shutdown 3.5.3 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.3 ECCS - Shutdown LCO 3.5.3 One ECCS train shall be OPERABLE.

APPLICABILITY: MIODE 4.

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

LCO 3.0.4b is not applicable to ECCS centrifugal charging pump subsystem.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Required ECCS residual A.1 Initiate action to restore Immediately heat removal (RHR) required ECCS RHR subsystem inoperable. subsystem to OPERABLE status.

B. Required ECCS B.1 Restore required ECCS 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status.

AND At least 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available.

C. Required ECCS C.1 Restore required ECCS 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months centrifugal charging centrifugal charging subsystem inoperable. subsystem to OPERABLE status.

D. Required Actions and D.1 Be in MODE 5. 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months associated Completion Times of Conditions B or C not met.

Vogtle Units 1 and 2 3.5.3-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

Hydrogen Recombiners 3.6.7 3.6 CONTAINMENT SYSTEMS 3.6.7 Hydrogen Recombiners LCO 3.6.7 Two hydrogen recombiners shall be OPERABLE.

APPLICABILITY: MODES 1 and 2.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One hydrogen A.1 NOTE recombiner inoperable. LCO 3.0.4 is not appmieable.

Restore hydrogen 30 days recombiner to OPERABLE status.

B. Two hydrogen B.1 Verify by administrative 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months recombiners inoperable. means that the hydrogen control function is AND maintained.

Once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months AND thereafter B.2 Restore one hydrogen 7 days recombiner to OPERABLE status.

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

Vogtle Units 1 and 2 3.6.7-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

ARVs 3.7.4 3.7 PLANT SYSTEMS 3.7.4 Atmospheric Relief Valves (ARVs)

LCO 3.7.4 Three ARV lines shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required ARV line A.1 -OTE inoperable. LCO 3.0.1 is not applioable.

Restore required ARV line 30 days to OPERABLE status.

B. Two or more required B.1 Restore at least two ARV 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ARV lines inoperable. lines to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 Be in MODE 4 18 hours2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months Vogtle Units 1 and 2 3.7.4-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

AFW System 3.7.5 3.7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFW trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and ----------------------------- NOTE--------------------------------

~LCO 3.0.4b is not applicable when entering MODE 1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One steam supply to A.1 Restore steam supply to 7 days turbine driven AFW OPERABLE status.

pump inoperable. AND 10 days from discovery of failure to meet the LCO B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable for reasons OPERABLE status.

other than Condition A. AND 10 days from discovery of failure to meet the LCO (continued)

Vogtle Units 1 and 2 3.7.5-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

UHS 3.7.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One NSCW basin NOTE--

transfer pump LCO 3.0.1 is not applicabfc.

inoperable.

C.1 Restore the transfer 8 days pump to OPERABLE status.

OR C.2.1 Implement an alternate 8 days method of basin transfer.

AND C.2.2 Restore the transfer 31 days pump to OPERABLE status.

D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND OR D.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months UHS inoperable for reasons other than Conditions A, B, or C.

Vogtle Units 1 and 2 3.7.9-2 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

CREFS - Both Units Operating 3.7.10 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Control room air -------------------- NOTE ----------------

temperature not within LCO 3.0.1 is not applicable.

limit.

E.1 Restore control room air 7 days temperature to within limit.

F. Required Action and ---------------------NOTE -----------------

associated Completion LCO 3.0.4 is not applicable to the Time not met. unaffected unit.

F.1 -------------NOTE-------------

Required Action F.1 is not applicable when entering this Condition from Condition B, D, or E. I Lock closed the outside air 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months (OSA) intake dampers of the affected unit and lock open the OSA intake dampers of the unaffected unit.

AND F.2 Place the affected units(s) 7 hours8.101852e-5 days 0.00194 hours 1.157407e-5 weeks 2.6635e-6 months in MODE 3.

AND F.3 Place the affected unit(s) 37 hours4.282407e-4 days 0.0103 hours 6.117725e-5 weeks 1.40785e-5 months in MODE 5.

Vogtle Units 1 and 2 3.7.10-2 Amendment No. 121 (Unit 1)

Amendment No. 99 (Unit 2)

CREFS - One Unit Operating 3.7.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME G. Control room air temperature not within

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

LGO 3.0.4 is net applicable.

I lim it. L-----3-----------n t pp

-- --- b--o-

I G.1 Restore control room air 7 days I temperature to within limit.

H. Required Action and H.1 Place the unit in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months I associated Completion Time not met for AND operating unit.

H.2 Place the unit in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months I SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.11.1 The Surveillance Requirements of Specification In accordance with 3.7.10 are applicable. applicable SRs.

Vogtle Units 1 and 2 3.7.11-3 Amendment No. 121 (Unit 1)

Amendment No. 99 (Unit 2)

CREFS - Both Units Shutdown 3.7.12 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Four CREFS trains inoperable. E.1 Suspend movement of Immediately irradiated fuel OR assemblies.

The CREFS train AND required in the emergency mode by E.2 Suspend CORE Immediately Required Actions of ALTERATIONS.

Conditions A, B, C, or D not capable of being powered by an OPERABLE emergency power source.

F. Control room air --------------------NOTE------------------

temperature not within LCO 3.0.4 is not applicable.

limit.

F.1 Restore control room air 7 days temperature to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.12.1 The Surveillance Requirements of In accordance with Specification 3.7.10 are applicable. applicable SRs.

Vogtle Units 1 and 2 3.7.12-3 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

AC Sources - Operating 3.8.1 3.8 ELECTRICAL POWER SYSTEMS 3.8.1 AC Sources - Operating LCO 3.8.1 The following AC electrical sources shall be OPERABLE:

a. Two qualified circuits between the offsite transmission network and the onsite Class 1E AC Electrical Power Distribution System; and

b. Two diesel generators (DGs) capable of supplying the onsite Class 1E power distribution subsystem(s).

Automatic load sequencers for Train A and Train B ESF buses shall be OPERABLE.

APPLICABILITY: MODES and 4 --- ------------------------ NOTE ---------------------------

~LCO 3.0.4b is not applicable to DGs.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One required offsite A.1 Perform SR 3.8.1.1 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months circuit inoperable. required OPERABLE offsite circuit. AND Once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months thereafter AND (continued)

Vogtle Units 1 and 2 3.8.1-1 Amendment No. 96 (Unit 1)

Amendment No. 74 (Unit 2)

Boron Concentration 3.9.1 3.9 REFUELING OPERATIONS 3.9.1 Boron Concentration LCO 3.9.1 Boron concentrations of the Reactor Coolant System, the refueling canal, and the refueling cavity shall be maintained within the limit specified in the COLR.

APPLICABILITY: MODE 6.

ACTIONS NJOTE With the RCS boron concentration specified in the COLR for MODE 6 not met, entry into MODE 6 is not permitted.

CONDITION REQUIRED ACTION COMPLETION TIME A. Boron concentration not A.1 Suspend CORE Immediately within limit. ALTERATIONS.

AND A.2 Suspend positive Immediately reactivity additions.

AND A.3 Initiate action to restore Immediately boron concentration to within limit.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.9.1.1 Verify boron concentration is within the limit 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months specified in the COLR.

Vogtle Units 1 and 2 3.9.1-1 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

RHR and Coolant Circulation - Low Water Level 3.9.6 3.9 REFUELING OPERATIONS 3.9.6 Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level LCO 3.9.6 Two RHR loops shall be OPERABLE, and one RHR loop shall be in operation.

APPLICABILITY: MODE 6 with the water level < 23 ft above the top of reactor vessel flange.

ACTIONS While this LOC is not met, entry into MODE 6 with water lovel < 23 ft above the top of the reactor vessel flango is not permitted.

CONDITION REQUIRED ACTION COMPLETION TIME A. Less than the required A.1 Initiate action to restore Immediately number of RHR loops required RHR loops to OPERABLE. OPERABLE status.

OR A.2 Initiate action to Immediately establish 2 23 ft of water above the top of reactor vessel flange.

B. No RHR loop in operation. B.1 Suspend operations Immediately involving a reduction in reactor coolant boron concentration.

AND (continued)

Vogtle Units 1 and 2 3.9.6-1 Amendment No. 108 (Unit 1)

Amendment No. 86 (Unit 2)

LCO Applicability B 3.0 BASES LCO 3.0.3 an Applicability of "During movement of irradiated fuel (continued) assemblies in the fuel storage pool." Therefore, this LCO can be applicable in any or all MODES. If the LCO and the Required Actions of LCO 3.7.15 are not met while in MODE 1, 2, or 3, there is no safety benefit to be gained by placing the unit in a shutdown condition. The Required Action of LCO 3.7.15 of "Suspend movement of irradiated fuel assemblies in the fuel storage pool" is the appropriate Required Action to complete in lieu of the actions of LCO 3.0.3. These exceptions are addressed in the individual Specifications.

LCO 3.0.4 LCO 3.0.4 establishes limitations on changes in MODES or other specified conditions in the Applicability when an LCO is not met. It I alelos Inr placing the unit in a MODE or other specified condition I ~' ao stated in that Applicabili (e.g., Aplicability desired to be entered) when RP5 0 .-1 the r

I INSERT B-1 a. Unit conditions arc ouch that the requircmcnts of the LCO would not be met in the Applicability desired to be entered; and

b. CoRtinued noncompliance with the LCO requirement,tif the Applicability were cntecd, would result in the unit being required to exit the Applicability desired to be cnteed to comply with the Required Actions.

Cnrnn1;nnna udth Pocs-irod Ar-finnQ that nnrm;t Ponfln-ad nnamtenn n

..- t,-.-

I&t-- ..- :& 9-- -- -9 LA LA ifl*5IL~A a:--

tilS ~ ~:-

L L

RA^fr7

V ~~ -

LS Sti tf A

condition nrovidpq an ccrnntahbcpI Il of rafet'. for continued

-- - .-.--- - -. .- ,---- --.-. - j,-,- ,

-r- 1 11 I I - - II- I - -I I-11 ;- - - k A.._ vl .. ,^ i. Ma. sv

- Ft-r'%T=

ve i.

o

,- PAt-AMM

W*x~-

. ... -. -v - v v' orvtr-

... }

r--

l. _v

... ._ ..v.-

otheir ospeified onRdition iR the Applicability may be moade in aGGordaRce with the provisions of the Required-Aff2tfosl e-provisions of this Specification should not be interpreted ks endorsing the failure to exercise the good practice of restoring syste s or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

I (continued)

Vogtle Units 1 and 2 B 3.0-5 Rev. 1-9/99

INSERT B-I unit conditions are such that the requirements of the LCO would not be met, in accordance with LCO 3.0.4a, LCO 3.0.4b, or LCO 3.0.4c.

LCO 3.0.4a allows entry into a MODE or other specified condition in the Applicability with the LCO not met when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. Compliance with Required Actions that pennit continued operation of the unit for an unlimited period of time in a Mode or other specified condition provides an acceptable level of safety for continued operation. This is without regard to the status of the unit before or after the MODE change. Therefore, in such cases, entry into a MODE or other specified condition in the Applicability may be made in accordance with the provisions of the Required Actions.

LCO 3.0.4b allows entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate.

The risk assessment may use quantitative, qualitative, or blended approaches, and the risk assessment will be conducted using the plant program, procedures, and criteria in place to implement 10 CFR 50.65(a)(4), which requires that risk impacts of maintenance activities be assessed and managed. The risk assessment, for the purposes of LCO 3.0.4b, must take into account all inoperable Technical Specification equipment regardless of whether the equipment is included in the nonnal 10 CFR 50.65(a)(4) risk assessment scope. The risk assessments will be conducted using the procedures and guidance endorsed by Regulatory Guide 1.182, "Assessing and Managing Risk Before Maintenance at Nuclear Power Plants." Regulatory Guide 1.182 endorses the guidance in Section I I of NUMARC 93-01, "Industry Guideline for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants." These documents address general guidance for conduct of the risk assessment, quantitative and qualitative guidelines for establishing risk management actions and example risk management actions. These include actions to plan and conduct other activities in a manner that controls overall risk, increased risk awareness by shift and management personnel, actions to reduce the duration of the condition, actions to minimize the magnitude of risk increases (establishment of backup success paths or compensatory measures), and determination that the proposed MODE change is acceptable. Consideration should also be given to the probability of completing restoration such that the requirements of the LCO would be met prior to the expiration of ACTIONS Completion Times that would require exiting the Applicability.

LCO 3.0.4b may be used with single, or multiple systems and components unavailable.

NUMARC 93-01 provides guidance relative to consideration of simultaneous unavailability of multiple systems and components.

The results of the risk assessment shall be considered in determining the acceptability of entering the MODE or other specified condition in the Applicability, and any corresponding risk management actions. The LCO 3.0.4b risk assessments do not have to be documented.

The Technical Specifications allow continued operation with equipment unavailable in MODE 1 for the duration of the Completion Time. Since this is allowable, and since in general the risk impact in that particular MODE bounds the risk of transitioning into and through the applicable MODES or other specified conditions in the Applicability of the LCO, the use of the LCO 3.0.4b allowance should be generally acceptable, as long as the risk is assessed and managed as stated above. However, there is a small subset of systems and components that have been determined to be more important to risk and use of the LCO 3.0.4b allowance is prohibited. The LCOs governing these system and components contain Notes prohibiting the use of LCO 3.0.4b by stating that LCO 3.0.4b is not applicable.

LCO 3.0.4c allows entry into a MODE or other specified condition in the Applicability with the LCO not met based on a Note in the Specification which states LCO 3.0.4c is applicable. These specific allowances permit entry into MODES or other specified conditions in the Applicability when the associated ACTIONS to be entered do not provide for continued operation for an unlimited period of time and a risk assessment has not been performed. This allowance may apply to all the ACTIONS or to a specific Required Action of a Specification. The risk assessments performed to justify the use of LCO 3.0.4b usually only consider systems and components. For this reason, LCO 3.0.4c is typically applied to Specifications which describe values and parameters (e.g.,RCS Specific Activity), and may be applied to other Specifications based on NRC plant-specific approval.

LCO Applicability B 3.0 BASES LCO 3.0.4 The provisions of LCO 3.0.4 shall not prevent changes in INSERT B-2 (continued) MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specifid conditions in the Applicability that result from any unit shutdown. I s,_ _ _v: _ _ _ A_ l Ad A _ __ :_ ALE _

Ia--- ..

~~J(ILUr -.

i-:i'. L -UI.l -- :.1. i I-uI- I---- --- I ~u 1-..Iu

+=*ti(_

A~tiG of a Spi -ritOP - __ ~- _- - --- }a -_

Action of-a Specification.

I CM:) O2f)A 1bs-- nnfi, nnnfinn--.I frr Mflfl=

~ r~h~nqPA 3"'hen P~fMt~rinC MCOl Mjr"---R~

___ .v.- I -_ -l ir F7Fvvv -- d-11-10 Ill--- F11 y --

INSERT B-3 4 frm MODE 5, MODE 3 fom MODE 4, MODE 2 from MODE 3, or MODE 1 from MODE 2. Furthermore, LCO 3.0.4 iv applicable when entering any other specified condition in the Applicability only while Annrprtinn ;n hMCfFUZ I '9 '2 nr d Thr' rp11rorniir rnt"z nf I MC '2 fl d cini~.,

_r,

_-4. ----- h.V :_11I KAf-%f'%=0 II. - - - - C , I__A 0_- _.- - - .- , -

MMUt4 ippay mm a*M m t,,~o t) MuU

, tjM 1Mi *S* MUt IV!

- - - -;;;;-,4 typ h ~lat

.. LUt MLAM WIUM0 W/

_; 4,_

LI

Apn,,InnkmIh, I,,nl-t.,

Ir vvsvv^^.sf Ace .§__ a r.

h~ :

1

'2

~~'2 -, -

^-r

.M ANJULMAJ

-1 - - - - - - -

fh+k

-I .-

Ar71C)NMQ afM I - . - - _.

rr -- J %-*

inriiviriuai I.. --flitnT-iens

- --- stittiirmenti'.

J defi~ne the reomooiai-mceasureF; to

_n k- +-,L,-nr I,, e--,.n^ .- ,... f, r. I t-n i' I 1% fkrrn- A'tICnKlQ mrr~iAt4e, NfnG,. fk=-,. '1Al-.

"-.,n, 4 +.-. I ('n ;.- .,* .- ~-M+ -- +-, infr- - PAniflI A -

. I--- .. - ___ .- .- -1 ... j .. - - - _.

rttFor tA..L.

_

Ls _ _

tonostiorV recent

_ _ _ _ £ : _ A]

UUMMtA*M

'- 4"- A

M*MMMU4

- -4 --. 4+-,4 -I ---

- - -o--

d- -c o- l-it - CO - T-hiI a ro quircI n required to comply with ACTIONS." This Note is a euie 4t P __ I- ? - - lt l.- .- - InA M .~ :__ --- enAZ! Ac h -9AJ;i LWqJIIUIHY PFL-bUIUOIHy L[Fiffy 1FRU d IVl'.JLJr= fdf OUffUI bfpUfU UU bU HUMUVtt 1H-I the eAppli~ay Surveillances do not have to be performed on the associated utilizing LC :O 3.0.4 inoperable equipment (or on variables outside the specified limits), as

*l\permitted bVSR 3.0.1. Therefore Ghanging MODES or eth

\1specified conditions while in an ACTIONS Condition ncmlac with LGO 3.0.4 or where an exception"G to2O3.00.4 is_stated s not a vilto ofkS 3;0< sT}orS304 tor ls 4-I on hhavs Ito be performed Idue to the ascaelioeal qimn n wever, SRs must be met to ensure OPE BILITY prior to declaring the associated equipment OPERABLE (or vanale within limits) and restoring compliance with the affected LCO.

LCO 3.0.5 LCO 3.0.5 establishes the allowance for restoring equipment to service under administrative controls when it has been removed from service or declared inoperable to comply with ACTIONS. The sole purpose of this Specification is to provide an exception to LCO 3.0.2 (e.g., to not comply with the applicable Required Action(s)) to allow the performance of SRs to demonstrate:

a. The OPERABILITY of the equipment being returned to service; or (continued)

Vogtle Units 1 and 2 B 3.0-6 Rev. 1-9/99

INSERT B-2 In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE I TO MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

INSERT B-3 Upon entry into a MODE or other specified condition in the Applicability with the LCO not met, LCO 3.0.1 and LCO 3.0.2 require entry into the applicable Conditions and Required Actions until the Condition is resolved, until the LCO is met, or until the unit is not within the Applicability of the Technical Specification.

SR Applicability B 3.0 BASES SR 3.0.3 evaluation should be used to determine the safest course of action.

(continued) All missed Surveillances will be placed in the licensee's Corrective Action Program.

If a Surveillance is not completed within the allowed delay period, then the equipment is considered inoperable or the variable is considered outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon expiration of the delay period. If a Surveillance is failed within the delay period, then the equipment is inoperable, or the variable is outside the specified limits and the Completion Times of the Required Actions for the applicable LCO Conditions begin immediately upon the failure of the Surveillance.

Completion of the Surveillance within the delay period allowed by this Specification, or within the Completion Time of the ACTIONS, restores compliance with SR 3.0.1.

SR 3.0.4 SR 3.0.4 establishes the requirement that all applicable SRs must be met before entry into a MODE or other specified condition in the Applicability.

This Specification ensures that system and component OPERABILITY requirements and variable limits are met before entry into MODES or other specified conditions in the Applicability for which these systems and components ensure safe operation of the unit.

The provisions of this Specification should not be interpreted as endorsing the failure to exercise the good practice of restoring systems or components to OPERABLE status before entering an associated MODE or other specified condition in the Applicability.

However, in certain circumstances, failing to meet an SR will not result in SR 3.0.4 restricting a MODE change or other specified condition change. When a system, subsystem, division, component, device, or variable is inoperable or outside its specified limits, the associated SR(s) is not required to be performed, per SR 3.0.1, which states that surveillances do not have to be performed on inoperable equipment.

When equipment is inoperable, SR 3.0.4 does not apply to the associated SR(s), since the requirement for the SR(s) to be performed is removed. Therefore, failing to perform the Surveillance(s) within the specified Frequency does not result in an SR 3.0.4 restriction to changing MODES or other specified conditions of the Applicability.

(continued)

Vogtle Units 1 and 2 B 3.0-1 4 Rev. 2-4/02

SR Applicability B 3.0 BASESS SR 3.0.4 However, since the LCO is not met~ti instance, LCO 3.0.4 will (continued) govern any restrictions that mayr may not) apply to MODE or other specified condition changes.

The provisions of SR 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS. In addition, the provisions of LCO 3.0.4 shall not prevent changes in MODES or other specified conditions in the Applicability that result from any unit shutdown.

The precise requirements for performance of SRs are specified such that exceptions to SR 3.0.4 are not necessary. The specific time frames and conditions necessary for meeting the SRs are specified in the Frequency, in the Surveillance, or both. This allows performance of Surveillances when the prerequisite condition(s) specified in a Surveillance procedure require entry into the MODE or other specified condition in the Applicability of the associated LCO prior to the performance or completion of a Surveillance. A Surveille at could not be performed until after entering the LC plicability, would have its Frequency specified such that it is not "due" until the specific conditions needed are met. Alternately, the Surveillance may be stated in the form of a Note as not required (to be met or performed) until a particular event, condition, or time has been, reached. Further discussion of the specific formats of SRs annotation is found in Section 1.4, Frequency.

SR 3.0.1 is only applicable for MODE changes when entering MODE 1 If.ro r rffM 1kFr Qr from Fl-lhnnZ A hAnnl( 0 fr-m hlnF or -i AnlM 1 from MODE 2.l Furthormor, SR 3.0. iApplicable w hcn cntcring any other 6peeificd Gondition in the Applicability only while operwating MODES 1, 2, 3, or 1. The requirements of SR 3.0.1 do not apply in MODES 5 and 6, or in other specified conditions of the Applicability (unless in MODES 1, 2, 3, or 4) because the ACTIONS of individual Specifiaions sufficiently define thc remedial measures to be talken.

Vogtle Units 1 and 2 B 3.0-1 5 Rev. 2-4/02 1

INSERT B-4 A provision is included to allow entry into a MODE or other specified condition in the Applicability when an LCO is not met due to a Surveillance not being met in accordance with LCO 3.0.4.

INSERT B-5 SR 3.0.4 does not restrict changing MODES or other specified conditions of the Applicability when a Surveillance has not been performed within the specified Frequency, provided the requirement to declare the LCO not met has been delayed in accordance with SR 3.0.3.

INSERT B-6 In this context, a unit shutdown is defined as a change in MODE or other specified condition in the Applicability associated with transitioning from MODE I to MODE 2, MODE 2 to MODE 3, MODE 3 to MODE 4, and MODE 4 to MODE 5.

SDM B 3.1.1 BASES APPLICABLE SDM satisfies Criterion 2 of 10 CFR 50.36 (c)(2)(ii). Even I SAFETY ANALYSES though it is not directly observed from the control room, (continued) SDM is considered an initial condition process variable because it is periodically monitored to ensure that the unit is operating within the bounds of accident analysis assumptions.

LCO SDM is a core design condition that can be ensured during operation through control rod positioning (control and shutdown banks) and through the soluble boron concentration.

The MSLB (Ref. 2) and the boron dilution (Ref. 3) accidents are the most limiting analyses that establish the SDM value of the LCO. For MSLB accidents, if the LCO is violated, there is a potential to exceed the DNBR limit and to exceed 10 CFR 100, "Reactor Site Criteria," limits (Ref. 4). For the boron dilution accident, if the LCO is violated, the minimum required time assumed for operator action to terminate dilution may no longer be applicable. The required SDM is specified in the COLR.

APPLICABILITY In MODES 3, 4, and 5, the SDM requirements are applicable to provide sufficient negative reactivity to meet the assumptions of the safety analyses discussed above. In MODE 6, the shutdown reactivity requirements are given in LCO 3.9.1, "Boron Concentration." In MODES 1 and 2, SDM is ensured by complying with LCO 3.1.5, "Shutdown Bank Insertion Limits," and LCO 3.1.6, "Control Bank Insertion Limits."

ACTIONS The ACTIONS table is modified by a Note prohibiting transition to a lower MODE within the Applicability land entr into-MODE 6 fmrni LCO 3.0.4 already prohibits entry into MODE 4 from MODE 5 and into MODE 3 from MODE 4 when DM requirements are not met.

A.1 MODE 5 from MODE 6, If the SDM requirements are not met, boration must be initiated promptly.

A Completion Time of 15 minutes is adequate for an operator to correctly align and start the required systems and components. It is assumed that (continued)

Vogtle Units 1 and 2 B 3.1.1-4 Rev. 2-1 0/01

RTS Instrumentation B 3.3.1 BASES ACTIONS C.1 and C.2 (continued)

Manual Reactor Trip;

RTBs;

RTB Undervoltage and Shunt Trip Mechanisms; and

Automatic Trip Logic. MODES 3,4, or5 This action addresses the train orientation of the SSPS for these Functions. With one channel or train inoperable, the i perable channel or train must be restored to OPERABLE statu within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . If the affected Function(s) cannot be restord to OPERABLE status within the allowed 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Comple ion Time, the unit must be placed in a MODE in which the requi ment does not apply. To achieve this status, the RTBs must be pened within the next hour. The additional hour provides su icient time to accomplish the action in an orderly manner. With e RTBs open, these Functions are no longer required. This ondition is modified by a Note that prohibits closing the RTBs in if any of the above Functions (Function 1, 17, 18, or 19 of Table 3.3.1-1) are not met. Closing the RTBG in MODES 3 or 4 with any of these Functions not mot is prohibited by LCO 3.0.1.

The Completion Time is reasonable considering that in this Condition, the remaining OPERABLE channel or train is adequate to perform the safety function, and given the low probability of an event occurring during this interval.

D.1.1. D.1.2, D.2.1, D.2.2, and D.3 Condition D applies to the Power Range Neutron Flux-High Function. This Condition contains bypass times and Completion Times that are risk-informed. The Configuration Risk Management Program (CRMP) is used to assess changes in core damage frequency resulting from applicable plant configurations.

The CRMP uses the equipment out of service risk monitor, a computer based tool that may be used to aid in the risk assessment of on-line maintenance and to evaluate the change in risk from a component failure. The equipment out of service risk monitor uses the plant probabilistic risk assessment model to evaluate the risk of removing equipment from service based on current plant configuration and equipment condition.

(continued)

Vogtle Units 1 and 2 B 3.3.1-42 Rev. 2-1/01

PAM Instrumentation B 3.3.3 BASES LCO 22, 23, 24, 25. Core Exit Temperature (continued) radial distribution of the coolant temperature rise across representative regions of the core. Power distribution symmetry was considered in determining the specific number and locations provided for diagnosis of local core problems. The two thermocouples in each channel must be located such that the pair of Core Exit Temperatures indicate the radial temperature gradient across their core quadrant. A Note specifies that each channel consists of two CETs. Two sets of two thermocouples ensure a single failure will not disable the ability to determine the radial temperature gradient.

APPLICABILITY The PAM instrumentation LCO is applicable in MODES 1, 2, and 3.

These variables are related to the diagnosis and pre-planned actions required to mitigate DBAs. The applicable DBAs are assumed to occur in MODES 1, 2, and 3. In MODES 4, 5, and 6, unit conditions are such that the likelihood of an event that would require PAM instrumentation is low; therefore, the PAM instrumentation is not required to be OPERABLE in these MODES.

ACTIONS NoeGhas been added in the AGTONS4GeXudeheMODE rhar4ge restriction of LCO 3.0.1. This exoeption atlows-entrypjnto-he applioable-MOQE while relying-onthe ACTIONS even though-he ACTIONS may eventualy-require-unit shutdown. This excceptr4-is aooeptabLue-to the passveunion-ofheinstrumientshe peaWabilito respond4o-anctdeut Using-alternate4nstruments and methods-frd4he low probabity-Gf-aR event-requiring hese instruments-.

Note 2 has been added in the ACTIONS to clarify the application of Completion Time rules. The Conditions of this Specification may be entered independently for each Function listed on Table 3.3.3-1. The Completion Time(s) of the inoperable channel(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

(continued)

Vogtle Units 1 and 2 B 3.3.3-14 Revision No. 0

Remote Shutdown System B 3.3.4 BASES (continued)

APPLICABILITY The Remote Shutdown System LCO is applicable in MODES 1, 2, and 3. This is required so that the unit can be placed and maintained in MODE 3 for an extended period of time from a location other than the control room.

This LCO is not applicable in MODE 4, 5, or 6. In these MODES, the facility is already subcritical and in a condition of reduced RCS energy. Under these conditions, considerable time is available to restore necessary instrument control functions if control room instruments or controls become unavailable.

ACTIONS LCO 3.0.4. This Ieurptie ett~s-en a-an-appliGable-MODE-while relyng-Gn~he AACFIONS vent~hough the AGTIONS-may eventualty4equire aunit-hutdown. his--excefion-is aGaeptable-due t9the low-probbifity-Gf-aR-ev/ef~t equifiRq4he-Remote-Shutdown Sytr~n bbueteequippentGa~-erly ereireddu rzi-- :. Note 2 has been added to the ACTIONS to clarify the application of Completion Time rules. Separate Condition entry is allowed for each Function listed on Table 3.3.4-1. The Completion Time(s) of the inoperable channel(s)/train(s) of a Function will be tracked separately for each Function starting from the time the Condition was entered for that Function.

A.1 Condition A addresses the situation where one or more required Functions of the Remote Shutdown System are inoperable. This includes any Function listed in Table 3.3.4-1, as well as the transfer switches and control circuits. A required Function is considered to be inoperable if one or more of its required channels is inoperable.

The Required Action is to restore the required Function to OPERABLE status within 30 days. The Completion Time is based on operating experience and the low probability of an event that would require evacuation of the control room.

(continued)

Vogtle Units 1 and 2 B 3.3.4-3 Revision No. 0

HFASA Instrumentation B 3.3.8 BASES APPLICABILITY In MODES 1 and 2, operators are alerted to an unplanned (continued) dilution event by a reactor trip on overtemperature delta-T or power range neutron flux high, low setpoint, respectively. As a protective measure in addition to HFASA, in MODE 5 with the loops not filled, unplanned dilution events are precluded by requiring the unborated water source (reactor makeup water storage tank (RMWST)) to be isolated.

ACTIONS A.1 With one channel of HFASA inoperable, Required Action A.1 requires the inoperable channel to be restored within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months .

In this condition, one channel of HFASA remains available to provide protection. The 48 hour5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months Completion Time is consistent with that required for an inoperable source range channel.

Required Action A.1 is modified by a Note providing an exceptions When Condition A (and Required Action A.1) are stating that LCO 3.0.4c applicable, the Note permits MODE changes provided that is applicable provided Required Action B.1 and B.2 are met. LCO 3.0.1 allows MODE that Required Actions 1 chngesud operthation iated ACTIONc p S t be otime,or ide fot B.1 and B.2 are met. coninud oeraionfor an unlimited period of time, ort cml with ACTIONS, or to facilitate a shutdown of the unit. The arcociated ACTIONS of LCO 3.3.8 provide for coRtinued operation for an unlimited period of time. Therefore, with one channel of HFASA inoperable, LCO 3.0.4 would permit entry into the Applicability of LCO 3.3.8 and MODE changes within the 18 hour2.083333e-4 days 0.005 hours 2.97619e-5 weeks 6.849e-6 months CompletioR Time allowed by Required Action AA, before Condition B-and Required Actionc B.1 and B.2 would become applicable. In particular, when trancitioning down through MODES 3, 1, and 5, the shutdown margin requirements become More rpstrietivptm nnMnenPatrk fnr Iteboron dillution even Required Action B.1 is a periodic verification of shutdown margin, and Required Action B.2 ensures that the unborated water source isolation valves are shut, precluding a boron dilution event. With one channel of HFASA inoperable, it is prudent to take the compensatory actions of Required Actions B.1 and B.2 if MODE changes are desired or required.

B.1 and B.2 With the Required Action A.1 and associated Completion Time not met, or with both channels of HFASA inoperable, the appropriate ACTIONS are to verify that the required SDM is present and isolate the unborated water source by performing (continued)

Vogtle Units 1 and 2 B 3.3.8-2 Rev. 2-9/99

RCS Loops-MODE 5, Loops Not Filled B 3.4.8 BASES LCO Note 3 allows valves in the flowpath from the RMWST, through (continued) the chemical mixing tank, to the suction of the charging pumps to be open under administrative control provided the SDM requirements of LCO 3.1.1 are met and the high flux at shutdown alarm is OPERABLE. (OPERABILITY of the high flux at shutdown alarm is defined by LCO 3.3.8.) This permits the addition of chemicals to the RCS as necessary in this MODE of operation while minimizing the risk of an uncontrolled boron dilution transient.

An OPERABLE RHR loop is comprised of an OPERABLE RHR pump capable of providing forced flow to an OPERABLE RHR heat exchanger. RHR pumps are OPERABLE if they are capable of being powered and are able to provide flow if required.

APPLICABILITY In MODE 5 with loops not filled, this LCO requires core heat removal and coolant circulation by the RHR System.

Operation in other MODES is covered by:

LCO 3.4.4, "RCS Loops-MODES 1 and 2";

LCO 3.4.5, "RCS Loops-MODE 3";

LCO 3.4.6, "RCS Loops-MODE 4";

LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled";

LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation-High Water Level" (MODE 6); and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation - Low Water Level" (MODE 6).

ACTIONS l The-ACTI)NS table is modified by a Note pFhibititrtr to-MDE- l 5--iIh the lop ntR filled While4he-k IGO-r r-m t I A.1 If only one RHR loop is OPERABLE and in operation, redundancy for RHR is lost. Action must be initiated to restore a second loop to OPERABLE status. The immediate Completion Time reflects the importance of maintaining the availability of two paths for heat removal.

(continued)

Vogtle Units 1 and 2 B 3.4.8-3 Rev. 1-9/99

Pressurizer PORVs B 3.4.11 BASES APPLICABILITY requirements in MODES 4, 5, and 6 with the reactor vessel head in place.

(continued)

ACTIONS Fw Note 4 has been added to clarify that all pressurizer PORVs are treated as separate entities, each with separate ComPletion Times (i.e., the Completion Time is on a component basis. The-exoeption for LCO 3.0.1, Note 2-pemitFe-inyt0 MGDFS 1,2, and-3-with inoperable PORVs that-are-n~t Gapableof beingmaFraully cyGed or inoperable bIoGk valves.

A.1 PORVs may be inoperable and capable of being manually cycled (e.g.,

excessive seat leakage, instrumentation problems, or other causes that do not create a possibility for a small break LOCA). In this condition, either the PORVs must be restored or the flow path isolated within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The associated block valve is required to be closed, but power must be maintained to the associated block valve, since removal of power would render the block valve inoperable. The PORVs may be considered OPERABLE in either the manual or automatic mode. This permits operation of the plant until the next refueling outage (MODE 6) so that maintenance can be performed on the PORVs to eliminate the problem condition.

Quick access to the PORV for pressure control can be made when power remains on the closed block valve. The Completion Time of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months is based on plant operating experience that has shown that minor problems can be corrected or closure accomplished in this time period.

B.1, B.2, and B.3 If one PORV is inoperable and not capable of being manually cycled, it must be either restored or isolated by closing the associated block valve and removing the power to the associated block valve. The Completion Times of 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months are reasonable, based on challenges to the PORVs during this time period, and provide the operator adequate time to correct the situation. If the inoperable valve cannot be restored to OPERABLE status, it must be isolated within the specified time. Because there is at least one PORV that remains OPERABLE, an additional 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months is provided to restore the inoperable PORV to (continued)

Vogtle Units 1 and 2 B 3.4.1 1-4 Rev. 1-2/00

COPS B 3.4.12 BASES APPLICABILITY OPERABILITY of the pressurizer safety valves that provide (continued) overpressure protection during MODES 1, 2, and 3.

Low temperature overpressure prevention is most critical during shutdown when the RCS is water solid, and a mass or heat input transient can cause a very rapid increase in RCS pressure when little or no time allows operator action to mitigate the event.

The Applicability is modified by a Note stating that accumulator isolation is only required when the accumulator pressure is more than the application of _eIt perature, as LCO 3.0.4b for allowed by the P/T limit curves. This Note permits the accumulator entry into MODE 4 discharge isolation valve Surveillance to be perform d only under as well as these pressure and temperature conditions.

ACTIONS Two Notes modify the ACTIONS table. Note 1 prohibitsJentry into MODE 6 with the vessel head on from MODE 6 and MODE 5 from MODE 6 with the vessel head on.

,tlalr Prohibited by LG 3.0.1.1 irNote 2 permits entry into MODE 4 from MODE 3 with a PORV that is inoperable for the purpose of cold IINSERT - overpressure protection provided that RCS temperature is maintained above 275 0F, and, within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , either: the PORV is restored to OPERABLE status; or, an RHR suction relief valve is placed in service so that the requirements of LCO 3.4.12 are met. Otherwise, the reactor vessel must be depressurized and vented in accordance with Required Action F.1. With only one PORV OPERABLE, the COPS remains capable of mitigating a design basis cold overpressurization event.

However, the system cannot withstand a single failure of the remaining PORV. The current COPS enable temperature is established very conservatively at 350 0F. However, the application of ASME Code Case N-514 would allow the enable temperature to be lowered to less than 2750F. Therefore, when entering this LCO from MODE 3 with one required PORV inoperable, maintaining RCS temperature above 2750 F minimizes actual exposure to a cold overpressure event. Furthermore, requiring action within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months minimizes the exposure to a single failure while allowing sufficient time to either restore the inoperable PORV or to place RHR in service. Note 2 is only applicable to the condition of entering MODE 4 from MODE 3 with one required PORV inoperable for the purpose of cold overpressure protection. If operating in MODE 4 and a failure of a required RCS relief valve occurs, Condition D applies.

(continued)

Vogtle Units 1 and 2 B 3.4.12-9 Rev. 1-9/99

INSERT B-7 There is an increased risk associated with entering MODE 4 from MODE 5, MODE 6 with the reactor vessel head on from MODE 6, and MODE 5 from MODE 6 with the reactor vessel head on with COPS inoperable. The provisions of LCO 3.0.4b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in these circumstances.

RCS Leakage Detection Instrumentation B 3.4.15 BASES (continued)

ACTIONS A.1 With one containment sump monitor inoperable, the remaining containment sump monitors, the containment atmosphere radioactivity monitor, and/or the containment air cooler condensate flow rate monitor will provide indications of changes in leakage. Together with these monitors, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Requierd Action A.4 is modified by a Note that indicates thatthe prIoviso of LCG 3.0.4 are not applicable. As a result, a MDE-chango is allowed when a containment cump monitor is inoperable.

This-allowance is provided because other instrumentation is available to monitor RCS leakaae.

B.1 and B.2 With two or more containment sump monitors inoperable, no other form of sampling or monitors can provide the equivalent information; however, the containment atmosphere radioactivity and/or containment air cooler condensate flow rate monitors will provide indications of changes in leakage. Together with these remaining monitors, the periodic surveillance for RCS water inventory balance, SR 3.4.13.1, must be performed at an increased frequency of 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months to provide information that is adequate to detect leakage.

Restoration of at least two sump monitors to OPERABLE status within a Completion Time of 30 days is required to regain most of this function and allow operation to continue under the provisions of Condition A. This Completion Time is acceptable, considering the remaining OPERABLE atmosphere radioactivity and/or condensate flow rate monitors and the Frequency and adequacy of the RCS water inventory balance required by Action B.1.

The Required Actions are modified by a Note that indicates that the provisicns of LCOQ 3.0.4 are enotapplicable. As a result, a MODE change is allowed when two or more oRtaiRnmeRt sump rnoitors are iRnperable. This allowaRne is (continued)

Vogtle Units 1 and 2 B 3.4.15-5 Revision No. 0

RCS Leakage Detection Instrumentation B 3.4.15 BASES ACTIONS B.1 and 8.2 (continued) previded eGause other instrumentationi is available and additional action is required to monitor RCS loakage.

C.1.1. C.1.2. C.2.1, and C.2.2 With both gaseous and particulate containment atmosphere radioactivity monitoring instrumentation channels inoperable, alternative action is required. Either grab samples of the containment atmosphere must be taken and analyzed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

With a sample obtained and analyzed or water inventory balance performed every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , the reactor may be operated for up to 30 days to allow restoration of the required containment atmosphere radioactivity monitors. Alternatively, continued operation is allowed if the air cooler condensate flow rate monitoring system is OPERABLE, provided grab samples are taken every 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months interval provides periodic information that is adequate to detect leakage. The 30 day Completion Time recognizes at least one other form of leakage detection is available.

Required Action C.1 and Required Action C.2 are modified by a Note that indicates that the previsions of LIO 3.0. are Rnot appliGable. As a result, a MODE change is allowed when the gaseous and partiGulate containment atmosphere radioactivity MORito channel is inoperable. This allowance is provided because other instrumentation is available to monitor for RCS LEAI*AKGE.

D.1 and D.2 With the required containment air cooler condensate flow rate monitor inoperable, alternative action is again required. Either SR 3.4.15.2 must be performed or water inventory balances, in accordance with SR 3.4.13.1, must be performed to provide alternate periodic information.

(continued)

Vogtle Units 1 and 2 B 3.4.15-6 Revision No. 0

A Note permits the use of the provisions of LCO 3.0.4c. This allowance RCS Specific Activity permits entry into the applicable MODE(S) while relying on the ACTIONS. B 3.4.16 BASES (continued) _

ACTIONS A Notc to the ACTIONS excludes the MODE change rFetriction of LGO 3.0.4. This exception allows entry into the applicable MulODE(S) while relyinRg on the Actios even; thouh the Actin ma 3vntually requir9 plan~t shutdown. rnhis lxeplr Iasettjldue to tile significant conservatism incorporated intake specific activity limit, the low probability of an event which is limiting crtmto exceeding this limit, and the ability to restore transient specific activi xcursions while the unit remains at or proceeds to power operation. aloac A.1 and A.2 With the DOSE EQUIVALENT 1-131 greater than the LCO limit, samples at intervals of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months must be taken to demonstrate that the limits of Figure 3.4.16-1 are not exceeded. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain and analyze a sample. Sampling is done to continue to provide a trend.

The DOSE EQUIVALENT 1-131 must be restored to within limits within 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months . The Completion Time of 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months is acceptable because of the low probability of an SGTR accident occurring during this period.

B.1 and B.2 With the gross specific activity in excess of the allowed limit, an analysis must be performed within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to determine DOSE EQUIVALENT 1-131. The Completion Time of 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months is required to obtain and analyze a sample.

The change within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months to MODE 3 and RCS average temperature

< 500OF lowers the saturation pressure of the reactor coolant below the setpoints of the main steam safety valves and prevents venting the SG to the environment in an SGTR event. The allowed Completion Time of 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months is reasonable, based on operating experience, to reach MODE 3 below 500OF from full power conditions in an orderly manner and without challenging plant systems.

(continued)

Vogtle Units 1 and 2 B 3.4.16-4 Revision No. 0

ECCS-Shutdown B 3.5.3 BASES LCO In MODE 4, an ECCS train consists of a centrifugal charging (continued) subsystem and an RHR subsystem. Each train includes the piping, instruments, and controls to ensure an OPERABLE flow path capable of taking suction from the RWST and transferring suction to the containment sump.

During an event requiring ECCS actuation, a flow path is required to provide an abundant supply of water from the RWST to the RCS via the ECCS pumps and their respective supply headers to each of the four cold leg injection nozzles. In the long term, this flow path may be switched to take its supply from the containment sump and to deliver its flow to the RCS hot and cold legs.

APPLICABILITY In MODES 1, 2, and 3, the OPERABILITY requirements for ECCS are covered by LCO 3.5.2.

In MODE 4 with RCS temperature below 350 0F, one OPERABLE ECCS train is acceptable without single failure consideration, on the basis of the stable reactivity of the reactor and the limited core cooling requirements.

In MODES 5 and 6, plant conditions are such that the probability of an event requiring ECCS injection is extremely low. Core cooling requirements in MODE 5 are addressed by LCO 3.4.7, "RCS Loops-MODE 5, Loops Filled," and LCO 3.4.8, "RCS Loops-MODE 5, Loops Not Filled." MODE 6 core cooling requirements are addressed by LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation -High Water Level," and LCO 3.9.6, "Residual Heat Removal (RHR) and Coolant Circulation-Low Water Level."

ACTIONS A.1 I INSERT B-8 With no ECCS RHR subsystem OPERABLE, the plant is not prepared to respond to a loss of coolant accident or to continue a cooldown using the RHR pumps and heat exchangers. The Completion Time of im-mediately to initiate actions that would restore at least one ECCS RHR subsystem to OPERABLE status ensures that prompt action is taken to restore the required cooling capacity. Normally, in MODE 4, reactor (continued)

Vogtle Units 1 and 2 B 3.5.3-2 Revision No. 0

INSERT B-8 A Note prohibits the application of LCO 3.0.4b to an inoperable ECCS centrifugal charging pump subsystem when entering MODE 4. There is an increased risk associated with entering MODE 4 from MODE 5 with an inoperable ECCS centrifugal charging pump subsystem and the provisions of LCO 3.0.4b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

Hydrogen Recombiners B 3.6.7 BASES ACTIONS A.1 (continued)

Ad Z A _*'__ 4 1L J!£. J L. . _ ^ And_ sL is Ares__ *L _

'A 5 SLII5S.I *5*IS .AJJ%4t flAb %LAb.

nrn'A.innq nflI CO 'R0 41 iriz nnt innnlir",hk' r~ Ari mrw~it P MMR change is aliowed whenone reombi r i Inoprablo. This nllnwAncon is hbased-n thn availaihlit. nf the othemr hdroncnm.

rFeembiner, the emall probabilifty of a lOCA or SL=B oeGurring (that would generate an amount of hydrogen that exceeds the flammability limit), and the amount of time available after a LOCA or SLB (should one occur) for operator action to prevent hydrogen accumulation from exceeding the flammability limit.

B.1 and B.2 With two hydrogen recombiners inoperable, the ability to perform the hydrogen control function via alternate capabilities must be verified by administrative means within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months . The alternate hydrogen control capabilities are provided by the containment Hydrogen Purge System/Containment Air Dilution System. The 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months Completion Time allows a reasonable period of time to verify that a loss of hydrogen control function does not exist. In addition, the alternate hydrogen control system capability must be verified every 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months thereafter to ensure its continued availability. Both the initial verification and all subsequent verifications may be performed as an administrative check by examining logs or other information to determine the availability of the alternate hydrogen control system. It does not mean to perform the Surveillances or other testing needed to demonstrate OPERABILITY of the alternate hydrogen control system.

If the ability to perform the hydrogen control function is maintained, continued operation is permitted with two hydrogen recombiners inoperable for up to 7 days. Seven days is a reasonable time to allow two hydrogen recombiners to be inoperable because the hydrogen control function is maintained and because of the low probability of the occurrence of a LOCA that would generate hydrogen in the amounts capable of exceeding the flammability limit.

(continued)

Vogtle Units 1 and 2 B 3.6.7-4 Revision No. 0

ARVs B 3.7.4 BASES APPLICABILITY to provide the decay heat removal function in MODE 4.

(continued) Therefore, the ARVs are not required OPERABLE in MODE 4 to satisfy the safety analysis assumptions of the DBA. However, the capability to remove decay heat from an SG required OPERABLE in MODE 4 by LCO 3.4.6, "RCS Loops - MODE 4" is implicit in the requirement for an OPERABLE SG and may require the associated ARV be capable of removing that heat if the normal decay heat removal system (steam dump) is not available.

In MODE 5 or 6, an SGTR is not a credible event.

ACTIONS A.1 With one required ARV line inoperable, action must be taken to restore OPERABLE status within 30 days. The 30 day Completion Time is reasonable considering the low probability of an SGTR event coincident with a loss of offsite power requiring the use of the ARVs and the redundant capability afforded by the remaining OPERABLE ARV lines, a nonsafety grade backup in the Steam Dump System, and MSSVs. I FquwoG ItIG

-^. Is-Imodifi-ed by a Notoe indic-ating that not-ap~ply.

eSO304des B.1 With two or more required ARV lines inoperable, action must be taken to restore all but one required ARV line to OPERABLE status. Since the block valve can be closed to isolate an ARV, some repairs may be possible with the unit at power. The 24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months Completion Time is reasonable to repair inoperable ARV lines, based on the availability of the Steam Dump System and MSSVs, and the low probability of an event occurring during this period that would require the ARV lines.

C.1 and C.2 If the ARV lines cannot be restored to OPERABLE status within the associated Completion Time, the unit must be placed in a MODE in which the LCO does not apply. To (continued)

Vogtle Units 1 and 2 B 3.7.4-4 Revision No. 0

AFW System B 3.7.5 BASES LCO inoperable, the turbine driven AFW train is to be considered (continued) inoperable. If 125 V MCC 1/2CD1M becomes inoperable, the turbine driven AFW train is to be considered inoperable.

The AFW System is configured into three trains. The AFW System is considered OPERABLE when the components and flow paths required to provide redundant AFW flow to the steam generators are OPERABLE. This requires that the two motor driven AFW pumps be OPERABLE in two diverse paths, each supplying AFW to separate steam generators. The turbine driven AFW pump is required to be OPERABLE with redundant steam supplies from each of two main steam lines upstream of the MSIVs, and shall be capable of supplying AFW to any of the steam generators. The piping, valves, instrumentation, and controls in the required flow paths also are required to be OPERABLE. The AFW pumphouse ESF supply fans and associated dampers must be OPERABLE to support operation of the motor driven pumps, and the ESF outside air intake and exhaust dampers must be OPERABLE to support operation of the turbine driven pump.

Although the AFW System can be used in MODE 4 to add to SG inventory when the SG is being used to support RCS operability requirements in accordance with LCO 3.4.6, the LCO does not require the AFW System to be OPERABLE in MODE 4.

APPLICABILITY In MODES 1, 2, and 3, the AFW System is required to be OPERABLE in the event that it is called upon to function when the MFW is lost.

In MODE 4 the AFW System may be used for heat removal via the steam generators, but is not required since the RHR System is available in this MODE.

In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.

ACTIONS I.

I INSERT B-9 If one of the two steam supplies to the turbine driven AFW train is inoperable, action must be taken to restore OPERABLE status within 7 days. The 7 day Completion Time is reasonable, based on the following reasons:

(continued)

Vogtle Units 1 and 2 B 3.7.5-4 Rev. 1-1/00

INSERT B-9 A Note prohibits the application of LCO 3.0.4b to an inoperable AFW train when entering MODE 1. There is an increased risk associated with entering MODE 1 with an AFW train inoperable and the provisions of LCO 3.0.4b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

CREFS - Both Units Operating B 3.7.10 BASES ACTIONS D.1 (continued)

If the control room boundary is inoperable in MODES 1, 2, 3, and 4, the CREFS trains cannot perform their intended functions. Actions must be taken to restore an OPERABLE control room boundary within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . During the period that the control room boundary is inoperable, appropriate compensatory measures (consistent with the intent of GDC 19) will be utilized to provide physical security and to protect control room operators from potential hazards such as radioactive contamination, smoke, temperature, and relative humidity. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. These preplanned measures will include, but not necessarily be limited to, suspension of movement of irradiated fuel assemblies and/or loads over irradiated fuel assemblies within the fuel handling building. The 24-hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period and the use of compensatory measures. The 24-hour Completion Time is a typically reasonable time to test, diagnose, plan, and possibly execute a repair of most problems with the control room boundary.

E.1 With the control room air temperature outside its limit, action must be taken to restore the air temperature to within the limit within 7 days. If the control room air temperature exceeds its limit, the ability of a single train of CREFS to maintain control room temperature after a CRI may be affected. The completion time of 7 days is reasonable considering the number of CREFS trains available to perform the required temperature control function and the low probability of an event occurring that would require the CREFS operation during that time.

The RequiFred AtioRsc are modified by a Ntoe that 6tates LCO 3.0.4 iE not applicable. In consideration of the number of redundant CREFS trains available, the small variation in temperature expected between 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months curvoillanc"e, and the marginal impact cmall temperature vapriations may haveon tho ability of a GREES traRn to maintain the centre roeom temperature within limits, an exception to LCO 3.0.4 is applicable for this GOndition.

(continued)

Vogtle Units 1 and 2 B 3.7.10-6 Rev. 1-5/01

CREFS - Both Units Operating B 3.7.10 BASES ACTIONS F.1, F.2, and F.3 (continued)

If the Required Actions and associated Completion Times of Conditions A, B, C, D, or E are not met, action must be. taken to place the unit in a condition where the inoperable CREFS train(s) are no longer required. Locking closed the outside air (OSA) dampers in the affected unit and locking open the OSA dampers in the unaffected unit within 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months , ensure that all control room air intake is monitored by redundant radiogas monitors that actuate OPERABLE CREFS trains. The affected unit(s) must also be placed in MODE 3 within the following 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within the following 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , which removes the requirement for control room protection in the event of an SI in the affected unit(s). These actions ensure that if the control room cannot be protected from all postulated accident and single failure conditions, the unit or units are placed in a MODE where the protection is no longer required. The allowed Completion Times are reasonable, based on operating experience, to perform the Required Actions and to reach the required unit conditions from full power conditions in an orderly manner without challenging unit systems.

All tho Required Actions are modified by a Noto that c-1aifioc the application of LGO 3.0.4. Since the shutdow-actions may only apply to the affected unit and the unaffected unit may continue to operate, LCO 3.0.4 does not apply to the unaffected unit in thiCos4ndfiton.

Required Action F.1 is modified by a Note that excepts Conditions B, D, and E. Conditions B, D, and E affect both units, and Required Action F.1 is based on a single affected unit.

Therefore, upon entry into Condition F from Condition B, D, or E, only Required Actions F.2 and F.3 apply.

SURVEILLANCE SR 3.7.10.1 REQUI REMENTS The CREFS is required to maintain the control room temperature

< 850 F in the event of a CRI. The maintenance of the control room below this temperature ensures the operational requirements of equipment located in the control room will not be exceeded. To accomplish this function, the CREFS air flow is directed through cooling coils which are supplied by the Essential Chilled Water System. The design cooling capacity of the CREFS and the limitation of the normal control room ambient temperature (before CRI) ensure the capability of the CREFS to maintain the (continued)

Vogtle Units 1 and 2 B 3.7.10-7 Rev. 1-5/01

CREFS -One Unit Operating B 3.7.11 BASES ACTIONS F.1 (continued) temperature, and relative humidity. Preplanned measures should be available to address these concerns for intentional and unintentional entry into the condition. These preplanned measures will include, but not necessarily be limited to, suspension of CORE ALTERATIONS and/or movement of irradiated fuel assemblies and/or loads over irradiated fuel assemblies. The 24-hour Completion Time is reasonable based on the low probability of a DBA occurring during this time period and the use of compensatory measures. The 24-hour Completion Time is a typically reasonable time to test, diagnose, plan, and possibly execute a repair of most problems with the control room boundary.

G.1 With the control room air temperature outside its limit, action must be taken to restore the air temperature to within the limit within 7 days. If the control room air temperature exceeds its limit, the ability of a single train of CREFS to maintain control room temperature after a CRI may be affected. The completion time of 7 days is reasonable considering the number of CREFS trains available to perform the required temperature control function and the low probability of an event occurring that would require the CREFS operation during that time.

The Required Actions are modified by a Note that states 1LGG 3.0.4 is,not applicabl e. in consideration of the number of redundant nREFS trains available, the small variation in temporsatr expected betweon 12 hour1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months curve1!lanRes,andthe marginal impact small temperature variations may have on the ability of a CREFS train to maintain the control room temperature within limits, an exception to LCO 3.0.4 is applicable for this Genditien.

H.1 and H.2 I If the Required Actions and associated Completion Times for the operating unit are not met, action must be taken to place the unit in a condition where the inoperable CREFS train(s) are no longer required. The operating unit must be placed in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months , which removes the requirement for control room protection in the event of an Si in the (continued)

Vogtle Units 1 and 2 B 3.7.1 1-5 Rev. 1-5/01

CREFS -Both Units Shutdown B 3.7.12 BASES ACTIONS F.1 (continued) of CREFS to maintain control room temperature after a CRI may be affected. The completion time of 7 days is reasonable considering the number of CREFS trains available to perform the required temperature control function and the low probability of an event occurring that would require the CREFS operation during that time.

The Roquirod Aetions are modified by a Note that states LCO 3.0.4 is not applicable. In consideration of the number of redundant CREFS trains available, the rmanl Yariation in temporeature expeted between 12 h our eurwillnces, and the marginal impact small temperature variations may have on the ability of a CREFS train to maintain the control room temperature within limits, an exception to LCO 3.0.4 is applicable for this Gen&!GFo-.

SURVEILLANCE SR 3.7.12.1 REQUIREMENTS SR 3.7.12.1 requires that the SRs specified in LCO 3.7.10 be applicable for this LCO as well. The description and Frequencies of those required SRs are included in the Bases for LCO 3.7.10.

REFERENCES 1. VEGP Calculation No. X6CNA.09.01, Control Room HVAC Technical Specifications, October 21, 1988.

Vogtle Units 1 and 2 B 3.7.12-5 Revision No. 0

AC Sources - Operating B 3.8.1 BASES LCO train. For the DGs, separation and independence are complete.

(continued)

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

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

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

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

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

ACTIONS A.

To ensure a highly reliable power source remains with one offsite INSERT B-10 circuit inoperable, it is necessary to verify the OPERABILITY of the remaining required offsite circuit on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action not met.

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

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

(continued)

Vogtle Units 1 and 2 B 3.8.1-5 Rev. 1-6/98

INSERT B-JO A Note prohibits the application of LCO 3.0.4b to an inoperable DG. There is an increased risk associated with entering a MODE or other specified condition in the Applicability with an inoperable DG and the provisions of LCO 3.0.4b, which allow entry into a MODE or other specified condition in the Applicability with the LCO not met after performance of a risk assessment addressing inoperable systems and components, should not be applied in this circumstance.

Boron Concentration B 3.9.1 BASES APPLICABLE The RCS boron concentration satisfies Criterion 2 of 10 CFR 50.36 SAFETY ANALYSES (c) (2) (ii). I (continued)

LCO The LCO requires that a minimum boron concentration be maintained in all filled portions of the RCS, the refueling canal, and the refueling cavity while in MODE 6. The boron concentration limit specified in the COLR ensures that a core keff of

0.95 is maintained during fuel handling operations. Violation of the LCO could lead to an inadvertent criticality during MODE 6.

APPLICABILITY This LCO is applicable in MODE 6 to ensure that the fuel in the reactor vessel will remain subcritical. The required boron concentration ensures a kef

0.95. In MODES 1 and 2, LCO 3.1.4, "Rod Group Alignment Limits," LCO 3.1.5, "Shutdown Bank Insertion Limits,' and LCO 3.1.6, "Control Bank Insertion Limits," ensure an adequate amount of negative reactivity is available to shut down the reactor. In MODES 3,4, and 5, LCO 3.1.1, "SHUTDOWN MARGIN" ensures an adequate amount of negative reactivity is available to shut down the reactor.

ACTIONS The ACTIONS table is modified by a Noto prohibiting ent' into MODE 6 if the RCS boron concentration specified in the COLR is not met.

A.1 and A.2 Continuation of CORE ALTERATIONS or positive reactivity additions (including actions to reduce boron concentration) is contingent upon maintaining the unit in compliance with the LCO. If the boron concentration of any coolant volume in the filled portions of the RCS, the refueling canal, or the refueling cavity is less than its limit, all operations involving CORE ALTERATIONS or positive reactivity additions must be suspended immediately.

Suspension of CORE ALTERATIONS and positive reactivity additions shall not preclude moving a component to a safe position or normal cooldown of the coolant volume for the purpose of system temperature control.

(continued)

Vogtle Units 1 and 2 B 3.9.1-3 Rev. 2-1 0/01

RHR and Coolant Circulation - Low Water Level B 3.9.6 BASES LCO Additionally, one loop of RHR must be in operation in order (continued) to provide:

a. Removal of decay heat;

b. Mixing of borated coolant to minimize the possibility of criticality; and

c. Indication of reactor coolant temperature.

An OPERABLE RHR loop consists of an RHR pump, a heat exchanger, valves, piping, instruments and controls to ensure an OPERABLE flow path and to determine the low end temperature. The flow path starts in one of the RCS hot legs and is returned to the RCS cold legs.

APPLICABILITY Two RHR loops are required to be OPERABLE, and one RHR loop must be in operation in MODE 6, with the water level < 23 ft above the top of the reactor vessel flange, to provide decay heat removal and mixing of the borated coolant. Requirements for the RHR System in other MODES are covered by LCOs in Section 3.4, Reactor Coolant System (RCS), and Section 3.5, Emergency Core Cooling Systems (ECCS). RHR loop requirements in MODE 6 with the water level 2 23 ft are located in LCO 3.9.5, "Residual Heat Removal (RHR) and Coolant Circulation - High Water Level."

ACTIONS ThoACTINS table ismoifed dby a Nete that prehibits ent~y-inte4thel IApI a wt.hile this LCOQ isnR-m I I A.1 and A.2 If less than the required number of RHR loops are OPERABLE, action shall be immediately initiated and continued until the RHR loop is restored to OPERABLE status and to operation or until Ž 23 ft of water level is established above the reactor vessel flange. When the water level is 2 23 ft above the reactor vessel flange, the Applicability changes to that of LCO 3.9.5, and only one RHR loop is required to be OPERABLE and in operation. An immediate Completion Time is necessary for an operator to initiate corrective actions.

(continued)

Vogtle Units 1 and 2 B 3.9.6-2 Rev. 1-9/99

Enclosure 3 Vogtle Electric Generating Plant Request to Revise Technical Specifications Regarding Mode Change Limitations Using The Consolidated Line Item Improvement Process Clean-typed TS and Bases Pages

Frequency 1.4 1.4 Frequency EXAMPLES EXAMPLE 1.4-1 SINGLE FREQUENCY (continued)

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY Perform CHANNEL CHECK. 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months Example 1.4-1 contains the type of SR most often encountered in the Technical Specifications (TS). The Frequency specifies an interval (12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months ) during which the associated Surveillance must be performed at least one time. Performance of the Surveillance initiates the subsequent interval. Although the Frequency is stated as 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , an extension of the time interval to 1.25 times the stated Frequency is allowed by SR 3.0.2 for operational flexibility. The measurement of this interval continues at all times, even when the SR is not required to be met per SR 3.0.1 (such as when the equipment is inoperable, a variable is outside specified limits, or the unit is outside the Applicability of the LCO). If the interval specified by SR 3.0.2 is exceeded while the unit is in a MODE or other specified condition in the Applicability of the LCO, and the performance of the Surveillance is not otherwise modified (refer to Example 1.4-3), then SR 3.0.3 becomes applicable.

If the interval as specified by SR 3.0.2 is exceeded while the unit is not in a MODE or other specified condition in the Applicability of the LCO for which performance of the SR is required, then SR 3.04 becomes applicable. The Surveillance must be performed within the Frequency requirements of SR 3.0.2, as modified by SR 3.0.3, prior to entry into the MODE or other specified condition or the LCO is considered not met (in accordance with SR 3.0.1) and LCO 3.0.4 becomes applicable.

(continued)

Vogtle Units 1 and 2 1.4-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)