Text

License Amendment Request for Incorporation of Previously NRC Approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-439-A, Rev. 2, Eliminate Second Completion Times Limiting
	ML12248A037
Person / Time
Site:	Vogtle
Issue date:	08/31/2012
From:	Ajluni M; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of Nuclear Reactor Regulation
References
	NL-12-1002
	Download: ML12248A037 (42)
	v • d • e

Mark J. Ajluni. P.E.

Southern Nuclear Nuclear Licensing Director Operating Company. Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7673 Fax 205.992.7885 August 31,2012 SOUTHERN '\\'

COMPANY Docket Nos.: 50-424 NL-12-1002 50-425 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 and 2 License Amendment Request for Incorporation of Previously NRC Approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" and Administrative Revision to Technical Specification 3.6.6 Ladies and Gentlemen:

In accordance with the provisions of Title 1 0, Part 50, Section 90 of the Code of Federal Regulations (10 CFR 50.90), Southern Nuclear Operating Company (SNC) is submitting a request for an amendment to the Technical Specifications (TSs) for Vogtle Electric Generating Plant (VEGP), Units 1 and 2.

This License Amendment Request (LAR) proposes to revise VEGP TSs 3.6.6, 3.7.5, 3.8.1, 3.8.9, and TS Example 1.3-3 by eliminating second Completion Times from the TSs. These changes are consistent with NRC-approved Industry/Technical Specification Task Force (TSTF) Traveler TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO," dated June 20,2005 [Agencywide Documents Access and Management System (ADAMS) Accession Number ML051860296].

Additionally, the proposed LAR will make an administrative revision to TS 3.6.6 by removing an obsolete note associated with Condition 3.6.6.A provides a description of the proposed changes and the requested confirmation of applicability associated with TSTF-439-A Enclosure 2 provides the existing VEGP Units 1 and 2 TS and TS Bases pages marked up to show the proposed changes. Enclosure 3 provides revised, clean-typed pages for the VEGP Units 1 and 2 TSs.

SNC requests approval of the proposed LAR by August 31, 2013 with the amendment being implemented within 90 days of issuance of the amendment

U. S. Nuclear Regulatory Commission NL-12-1002 Page 2 In accordance with 10 CFR 50.91, a copy of this LAR with enclosures is being provided to the designated Georgia State Officials.

There are no NRC commitments contained in this letter. If you have any questions, please contact Lesa Hill at (205) 992-5727.

Mr. Ajluni states he is Nuclear Licensing Director 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.

5f..

/l Sworn to and subscribed before me thiS.:J..t: day of lbqLw f-

,2012.

~yf!MloC.(jb

~otary Public My commission expires: tl:-o 2-- 6::::>(3 Respectfully submitted, M. J. Ajluni Nuclear Licensing Director MJAlEGAllac

Enclosures:

1. Basis for Proposed Change - Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-439-A and Administrative Revision to Technical Specification 3.6.6

2. Technical Specifications and Technical Specifications Bases Marked-Up Pages

3. Technical Specifications Clean-Typed Pages

U.

Nuclear Regulatory Commission NL-12-1002 Page 3 cc:

Mr. S. E. Kuczynski, Chairman, President &

Mr. D.

Bast, Executive Vice President &Chief Nuclear Officer Mr.

Tynan, Vice

- Vogtle Mr.

L. Ivey, Vice

- Regulatory Affairs Mr.

J. Adams, Vice President - Fleet Operations RType: CVC7000 Mr. V. M. McCree, Administrator Mr.

Martin, NRR Senior Project Manager - Vogtle Mr. L. M. Cain, Senior Resident Inspector -

Mr. M. O. Miller, Senior Project Engineer, NRC Region II Mr. J. H. Turner, Environmental Director Protection Division

Vogtle Electric Generating Plant, Units 1 and 2 License Amendment Request for Incorporation of Previously NRC Approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" and Administrative Revisions to Technical Specification 3.6.6 Basis for Proposed Change - Technical Specification Task Force (TSTF)

Standard Technical Specification Change Traveler TSTF-439-A and Administrative Revision to Technical Specification 3.6.6 Basis for Proposed Table of

1. Summary

2. Detailed

3. Technical Evaluation

4. Regulatory 4.1. Significant hazards Consideration 4.2. Applicable Regulatory Requirements/Criteria 4.3. Precedent 4.4. Conclusions

5.

6.

to 002 for Proposed Change

1.

Summary na'~l"rintir'n Technical Specification Task Force Standard Technical Specification Traveler Revision Electric Generating Plant (VEGP)

Specification Times 1

to catv,r,/"'! completion and to replace regarding Completion Times with a new discussion.

Completion associated with Required Actions (RAs) A.1 and B.1, RAs A. 1 and 1,

RA A.3, and RAs A.1, B.1, and 1 are being deleted.

Bases associated with these RAs are being revised to nCllaTO discussion of Completion Additionally, the proposed change to TS 3.6.6.

is a note associated Condition 3.6.6.A is obsolete, so it is being The time constraints on this note are no longer applicable.

are no TS Bases changes required for this deletion.

Detailed Description TS Example 1 is revised to eliminate the second Completion and to replace regarding Completion with the following:

lilt is possible alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever restoring systems to the LCO. However, doing so would be inconsistent with the basis of Completion Therefore, there shall administrative controls to limit the maximum time allowed combination of Conditions that result in a single contiguous occurrence of failing to LCO.

administrative controls ensure that Completion Times for Conditions are not inappropriately extended."

A second Completion Time is included for certain Conditions/Required Actions to establish a limit on the maximum time allowed for any combination of Conditions that result in a contiguous failure to meet the Limiting Condition for Operation (LCO).

These second Completion Times are joined to the Condition Completion discovery of meet the The second Completion Times associated with 3.6.6 RAs A.1 and 1,

TS3.7.5RAs 1 andB.1,TS3.8.1 RA andTS3.8.9RAsA.1, 1,

and C.1 are being It is proposed to VEGP TS \\:)el(;lICln to conform to the changes. Additionally, the TS Bases are revised in the TSTF to the changes in 1

There is one the TSTF.

to Condition 439-A, Revision E1 to NL-1 for Proposed not be adopted in this license amendme for VEGP Units 1 and 2 TSs and TS nt request. The markup are included in pages

2.

The administrate amendment is to note from TS RA which states, Unit 2 2008 entry into Technical Specification 3.6.6, Containment Pump B may be inoperable for a period not to 7 days" Technical Evaluation

..:..=-'-'--==-:~~'-'-=;;;:.:..:..=. As discussed in TSTF-439-A, adoption of a Completion was based on a plant could continue to operate a LCO significant never being met by meeting requirements of Conditions. In 1 the NRC could not identify I

any regulatory requirement or program which could prevent this of the Technical Specifications. However, that is no longer the case. There are now two programs which would provide a strong disincentive continued operation with concurrent multiple inoperabilities of the type the second Completion were designed to prevent.

The 10 CFR

), the Maintenance to monitor the performance or condition of goals to ensure that the SSCs are capable of fulfilling their functions. If the performance or condition of an SSC does not meet established goals, appropriate corrective action is required to be taken. The NRC Resident Inspectors monitor the licensee's Action process and could take action if licensee's maintenance program allowed the required by a single to become concurrently inoperable The performance condition activities 50.65(a)(1)

(a)(2) would identify if poor maintenance resulted in multiple into the ACTIONS of the Technical Specifications and unacceptable unavailability of The effectiveness of performance monitoring activities, and associated actions, is evaluated at least every refueling cycle, not to exceed 24 months per 10 CFR 50.65(a)(3).

Specifications, the inoperable equipment.

were an the Completion the condition of system, if the two were required by same LCO. However 10 CFR 50.65(a)(4) is a much better mechanism to apply this influence as the Maintenance Rule considers all inoperable risk-significant equipment, not just the one or two governed by same LCO.

Under 10 50.65(a)(4), the risk impact of inoperable risk-significant equipment is managed preventative or corrective risk assess are conducted using procedures and endorsed by Guide 1.182, AS!)eSSI and Managing Risk nOTnro Maintenance at Nuclear Power E1-4

1 to NL-12-1002 for Proposed Change Regulatory Guide 1.1 the guidance in 11 of NUMARC 93-01, "Industry Guideline for Monitoring the of Maintenance Nuclear Power documents guidance for conduct of the risk quantitative and guidelines for establishing risk management actions, and example risk management actions. These include to plan and conduct activities in a manner that controls overall increased risk awareness by shift and management personnel, actions to reduce the duration of condition, actions to minimize magnitude of risk (establishment of backup success paths or compensatory measures),

determination that the proposed maintenance is acceptable. This program provides much assurance of safe plant operation the second Completion Times in the Specifications.

The Reactor Oversight NEI 99-02, "Regulatory Assessment Performance Indicator

" describes the tracking reporting of performance indicators to support the NRC's Reactor Oversight Process (ROP). The NEI document is endorsed by RIS 2001-11, "Voluntary Submission of Performance Indicator Data." NEI Section 2.2, describes the Mitigating Cornerstone.

specifically addresses emergency Sources (which the AC Sources Distribution System Extended unavailability to multiple entries into the ACTIONS would affect the NRC's of the licensee's performance under the ROP.

In addition to these a requirement is Section 1.3 of the Technical Specifications require licensees to administrative controls limit the maximum allowed for any combination of Conditions that result in a single contiguous occurrence of failing to meet the LCO. These administrative controls should consider plant risk and limit the maximum contiguous time of failing to meet the This requirement, when considered with regulatory processes above, provides an equivalent or of plant safety without unnecessary complication of the Completion on some Specifications.

Condition 3.6.6.A was via a one-time emergency TS change for a specific date of entry, 2008. As a result of the completed work on the system, it is no longer necessary to retain the note in note was added to via Amendment Number 131 to the VEGP Unit 2 TS, which was by the NRC in "Vogtle Generating Plant, Unit 2, Issuance of Amendment One-Time Extension to Allowed for Technical 3.6.6 (TAC No. MD9003)" on June 2008 - Agency Wide and Management (ADAMS) Accession E1 to NL-12-1002 Basis for Proposed Change This note expired when the June 23, 2008 entry into TS 3.6.6 was exited, and it is no longer necessary to retain it at the bottom of page 3.6.6-1 of the TS. Therefore, this change is considered administrative.

4.

Regulatory Evaluation:

4.1. Significant hazards Consideration SNC has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: No.

The change proposed by incorporating TSTF-439-A, Revision 2, eliminates certain Completion Times from the Technical Specifications. Completion Times are not an initiator to any accident previously evaluated. As a result, the probability of an accident previously evaluated is not affected. The consequences of an accident during the revised Completion Time are no different than the consequences of the same accident during the existing Completion Times. As a result, the consequences of an accident previously evaluated are not affected by this change. The proposed change does not alter or prevent the ability of structures, systems, and components (SSCs) from performing their intended function to mitigate the consequences of an initiating event within the assumed acceptance limits.

The proposed change described above does not affect the source term, containment isolation, or radiological release assumptions used in evaluating the radiological consequences of an accident previously evaluated. Further, the proposed change does not increase the types or amounts of radioactive effluent that may be released offsite, nor significantly increase individual or cumulative occupational/public radiation exposures. The proposed change is consistent with the safety analysis assumptions and resultant consequences. Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Additionally, the proposed change to delete the note from TS Condition 3.6.6.A is administrative in nature and does not impact the operation, physical configuration, or function of plant structures systems, or components (SSCs). The proposed change does not impact the initiators or assumptions of analyzed events, nor does the proposed change impact the mitigation of accidents or E1-6

Basis transient events. Therefore, this proposed change not involve a significant in the probability or consequences of an accident previously evaluated.

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

No.

proposed changes do not involve a physical alteration of the plant (Le. no new or different type of equipment will installed) or a change in the methods governing normal plant operation. The proposed changes do not any assumptions in the analysis. Therefore, the proposed changes not create possibility of a new or kind of accident from any previously the proposed involve a significant reduction in a margin of safety?

No.

proposed change to the second Completion Time does the manner in which safety limits, limiting system or limiting conditions for operation are The analysis are not change.

proposed change in plant operation in a configuration outside of basis. Therefore, the proposed does not involve a significant reduction in a of safety.

proposed change to the note from TS Condition 3.B.B.A is administrative in does not involve to plant SSCs, or manner in which f'\\nt:l.!"~'rQ" maintained, modified, or change a change to any

limits, system limiting conditions of operation, or parameters for any The proposed not impact any safety analysis assumptions and do not involve a change in initial conditions, system response times, or other affecting any analysis. The proposed change will not result in plant operation in a configuration of the basis. Therefore, proposed change significant reduction in a margin of safety.

l::Saf:;ea on above, SNC the proposed amendment involve a significant consideration the set forth in 10 and, accordingly, a finding of no significant hazards consideration is justified.

4.2. Applicable Regulatory Requirements/Criteria to NL-12-1002 Basis for Proposed Change 10 CFR 50.36, "Technical Specifications" - 10 CFR 50.36(c)(2) states, "When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." The proposed change continues to meet the requirements of this regulation.

10 CFR 50.65, "Requirements for Monitoring the Effectiveness of Maintenance at Nuclear Power Plants" - The overall objective of this performance-based rule is to ensure that nuclear power plant structures, systems, and components (SSCs) will be maintained so that they will perform their intended function when required.

4.3. Precedent TSTF-439-A, Revision 2 was approved for use as described in the following letter:

1. Letter from J. D. Hughey (U. S. Nuclear Regulatory Commission) to M. J. Pacilio (Exelon Nuclear), "Peach Bottom Atomic Power Station, Units 2 And 3 -Issuance Of Amendments Re: Adoption Of Technical Specification Task Force (TSTF) Traveler 439, Revision 2, 'Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet An LCO (Limiting Condition For Operation),' (TAC NOS. MD9449 AND MD9450)," dated July 30, 2010.

4.4. Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

5.

Environmental Consideration SNC has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released off site, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

E1-8 to NL-12-1002 Basis for Proposed Change

6.

References

1. IndustryfTechnical Specification Task Force (TSTF) Standard Technical Specification Change TSTF-439, Revision 2, "Eliminate Second Completion Time From Discovery of Failure To Meet an LCO," June 20, 2005.

2. NRC Letter dated January 11,2006, to the Technical Specification Task Force regarding "Status of TSTF 439, 'Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO'."

3. Letter from J. D. Hughey (U. S. Nuclear Regulatory Commission) to M.

J. Pacilio (Exelon Nuclear), "Peach Bottom Atomic Power Station, Units 2 And 3 -Issuance Of Amendments Re: Adoption Of Technical Specification Task Force (TSTF) Traveler 439, Revision 2, 'Eliminate Second Completion Times Limiting Time From Discovery of Failure To Meet An LCO (Limiting Condition For Operation),' (TAC I\\lOS. MD9449 AND MD9450)," dated July 30, 2010.

4. Letter from R. A. Jervey (U. S. Nuclear Regulatory Commission) to T. E.

Tynan (Southern Nuclear Operating Company), "Vogtle Electric Generating Plant, Unit 2, Issuance of Emergency Amendment Regarding One-Time Extension to Allowed Outage time for Technical Specification 3.6.6 (TAC No. MD9003)" dated June 25,2008.

E1-9

Vogtle Electric Generating Plant, Units 1 and 2 license Amendment Request for Incorporation of Previously NRC Approved Technical Specification Task (TSTF) Standard Technical Specification Change Traveler TSTF-439-A, Revision 2, "Eliminate Second Completion Limiting from Discovery of to an LCO" Administrative Revisions to Technical Specification 3.6.6 Technical Specifications and Technical Specification Bases Marked-Up Pages

1.3 Completion Times 1.3 Completion Times DESCRIPTION (continued)

However, when a subsequent train, subsystem, component, or variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of b the hrase "from discove (continued)

Vogtle Units 1 and 2 1.3-2 Amendment Noj W j (Unit 1)

Amendment No 74 (Unit 2)

1.3 1.3 Completion Times EXAMPLES EXAMPLE 1.3-3 (continued)

ACTIONS CONDITION A. One Function X train inoperable.

B. One Function Y train inoperable.

C. One Function X train inoperable.

AND One Function Y train inoperable.

Vogtle Units 1 and 2 Completion Times MULTIPLE FUNCTION COMPLETION TIMES!

SEPARATE COMPLETION TIMES REQUIRED ACTION COMPLETION TIME A.1 Restore 7 days Function X train to OPERABLE AN{).

status.

~Q says fF9Ff1

, ~

'J r.f f"ilt Ir.t::LLo Ffleet tAe bGQ B.1 Restore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y train To OPERABLE AN{).

Status.

~ Q says fF9Ffl

..I:

.~ ~. ;I,,~. +.

'J Ffleet tAe bGQ C.1 Restore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X train To OPERABLE Status.

OR C.2 Restore 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y train To OPERABLE Status.

(continued) 1.3-6 Amendment Nol ge I(Unit 1)

Amendment No 74 (Unit 2)

1.3 Completion Times 1.3 Completion Times EXAMPLES INSERT EXAMPLE 1.3-3 (continued)

When one Function X train and one Function Y train are inoperable, Condition A and Condition B are concurrently applicable. The Completion Times for Condition A and Condition B are tracked separately for each train starting from the time each train was declared inoperable and the Condition was entered. A separate Completion Time is established for Condition C and tracked from the time the second train was declared inoperable (Le., the time the situation described in Condition C was discovered).

If Required Action C.2 is completed within the specified Completion Time, Conditions Band C are exited. If the Completion Time for Required t expired Acion r

A 1 h as no opera Ion may con Inue r

r'In accordance WI'th

..c,.-n,.,;,,;..,ro ("',....-n" I,...t;r..., T;.-n,... ;.., (",,...,,..4;t;,....., 1\\ ;c-.-n"",",,,.,.,.rl Condition A. ITh,.,.

from the time the affeoted train was deolared inoperable (i.e., initial entry into Condition A).

+he Completion +imes of Coneitions A and Bare moeified by a lo§ieal oonneotor with a separate ~ Q gay Completion +ime measl:lred from the time it 'Alas diseovered the bCG '#as not met. In this e*ample, withol:lt the separate Completion :rime, it wOl:llEl be possible to alteFAate between ConElitions A, 13, anEl C in sl:leh a manner that operation eOl:lld oontinl:le inElefinitely withol:lt ever restorin§ systems to meet the bCG. +he separate Completion :rime moElifieEl by the phrase "from EliseoveFY of faill:lre to meet the bCG" is Elesi§neEl to prevent inElefinite eontinl:leEl r...,r.,....t;,..."..h;l,.,...,r.t.-nr.r.t;..,ro th,.,. I ("'n Th;c- ("',....-n..,I,...t;r.n T;,....,,...... 11,...*,c-f,.............

.~

,~

.~

~.

~f"'~ ~.

~~."

,~

~.,~

~

e*eeption to the normal "time i!'ero" for be§innin§ the Completion +ime "oloek." In tRis instanee, tRe Completion +ime "time i!'ero" is speoifiee as oommenoin§ at the time the bCG was initially not met, insteaEl of at the time the assoeiated Condition was entered.

(continued)

Vogtle Units 1 and 2 1.3-7 Amendment Noj W j (Unit 1)

Amendment No +4 (Unit 2)

INSERT It is possible to alternate between Conditions A, B, and C in such a manner that operation could continue indefinitely without ever systems to meet the LCO. However, doing so would be inconsistent with the of the Completion Therefore, there shall be administrative controls to the maximum time allowed any combination of Conditions that result in a contiguous occurrence of failing to the LCO. These administrative controls shall ensure that the Completion Times for Conditions are not inappropriately extended.

Containment Spray and Cooling Systems 3.6.6 3.6 CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling Systems LCO 3.6.6 Two containment spray trains and two containment cooling trains shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One containment spray A.1 Restore containment 72 hourd3 train inoperable.

spray train to OPERABLE status.

ANf)

I lays fFOFR sis6evefJ' of failuFe to meet the

~

B.

One containment cooling train inoperable.

B.1 Restore containment cooling train to OPERABLE status.

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

I says fForn li66o~JeFY ef-failuFe to meet tAo bGG 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 5.

84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months 3.6.6-1 Vogtle Units 1 and 2 Amendment No.11 ~1(Unit 1)

Amendment No. +d4 (Unit 2)

3.7.5 AFW System 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 3.

ACTIONS

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

LCO 3.0.4b is not applicable.

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.

ANQ

~ G lays fr:em ElisseveFY ef fail~Fe te meet tl=le bGG 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.

ANQ

~ Glays fr:em Elis6eveFY ef faill:lFe te meet tl=le bGG (continued)

Vogtle Units 1 and 2 3.7.5-1 Amendment No.1 :~; I(Unit 1)

Amendment No. ~ (Unit 2)

3.8.1 ACTIONS CONDITION A. (continued)

REQUIRED ACTION A.2 Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

AND A.3 Restore required offsite circuit to OPERABLE status.

AC Sources - Operating COMPLETION TIME 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months ANQ

~ 4 says fFsffi sisGs'Ier-y sf failure ts

!'fleet bGG (continued)

Vogtle Units 1 and 2 3.8.1-2 Amendment No.14OOl (Unit 1)

Amendment No.~ Unit 2)

Distribution Systems - Operating 3.8.9 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 The required AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

NOT E --------------------------------------------

The redundant emergency buses of 4160 V switchgear 1/2AA02 and 1/2BA03 may be manually connected within the unit by tie breakers in order to allow transfer of preferred offsite power sources provided SR 3.8.1.1 is successfully performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to the interconnection. The interconnection shall be implemented without adversely impacting the ability to simultaneously sequence both trains of LOCA loads.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

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

OPERABLE status.

~ I R9t1FS fF9ffi rI;~~~~~,,.f.f~;I,,~~...

, J_

ffieet bGG B.

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

OPERABLE status.

~ I R9t1FS fF9ffi rI;,,~~,,-.~,

~.f.f.... ;1,..,.....,..,

~ ~~~ ~>'_ ~

,~ ~. ~,~

ffiget bGG (continued)

Vogtle Units 1 and 2 3.8.9-1 Amendment NO.!W! (Unit 1)

Amendment No. +4 (Unit 2)

3.8.9 Distribution Systems - Operating ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One or more DC electrical power distribution subsystems inoperable.

C.1 Restore DC electrical power distribution subsystems to OPERABLE status.

2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months AN{;}

~ 6 Rel:lFS fFeFR disceveFY ef faill:lFe te FAeet bGG D.

Required Action and associated Completion Time not met.

0.1 AND Be in MODE 3.

6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months 0.2 Be in MODE 5.

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

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

E.1 Enter LCO 3.0.3.

Immediately SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to In accordance with required AC, DC, and AC vital bus electrical power the Surveillance distribution subsystems.

Frequency Control Program Vogtle Units 1 and 2 3.8.9-2 Amendment NO.~ (Unit 1)

Amendment No.~ (Unit 2)

BASES APPLICABILITY (continued)

ACTIONS Containment Spray and Cooling Systems B

In 5 and 6, probability consequences these events are reduced due to the pressure and temperature limitations of MODES.

the Containment Spray System and the Containment Cooling System are not required to be OPERABLE in MODES 5

6.

With one containment spray train inoperable, the inoperable containment spray must be to OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . In this Condition, the remaining OPERABLE spray and cooling trains are adequate to perform the iodine removal and containment cooling functions.

72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time into account redundant removal afforded by Containment Spray reasonable time for repairs, low probability of a DBA occurring during this period.

containment cooling trains inoperable, the containment cooling train must be restored within hours. The components in this degraded capabilities are providing at least 100%

the heat needs.

Completion Time was developed taking into account removal afforded by combinations of Containment System and Containment Cooling System, the low probability of a DBA occurring during this period.

Vogtle Units 1 and 2 B3.6.6-6 Revision NO.[£]

Containment Spray and Cooling Systems B 3.6.6 BASES ACTIONS SURVEILLANCE REQUIREMENTS B.1 (continued)

+Re esay f)eFtieA ef tRe Gemf)IetieA +ime feF ReEjl:liFeS ActieA B. ~ is eases l:If)eA eA§iAeeFiA§ jI:lS§FAeAt. It takes iAte a66Sl:lAt tRe Isw f)Fseaeility sf ceiAciEleAt eAtFy iAtS tws GSAElitieAs iA tRis ~f)e6ifi6atieA cSI:lf)led with the lew weeaeility sf aA acciEleAt sC6I:1FFiA§ ElI:IFiA§ tRis tiFA8. RefeF ts ~e6tieA ~.3 fSF a FAeFe setaileEl Eliscl:IssieA sf the f)I:IFf)ese ef tRe "fram Eliscevery sf faill:lFe te moot the LGO" peFtieA sf tRe GSFApletieA +imo.

C.1 and C.2 If the inoperable containment spray or cooling train cannot be restored to OPERABLE status within the required Completion Time, the plant must be brought to a MODE in which the LCO does not apply. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months . 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 from full power conditions in an orderly manner and without challenging plant systems. The extended interval to reach MODE 5 allows additional time for attempting restoration of the containment spray or cooling train and is reasonable when considering the driving force for a release of radioactive material from the Reactor Coolant System is reduced in MODE 3.

SR 3.6.6.1 Verifying the correct alignment for manual, power operated, and automatic valves in the containment spray flow path provides assurance that the proper flow paths will exist for Containment Spray System operation. This SR does not apply to valves that are locked, sealed, or otherwise secured in position, since these were verified to be in the correct position prior to locking, sealing, or securing. This SR does not require any testing or valve manipulation. Rather, it involves verification that those valves outside containment (only check valves are inside containment) and capable of potentially being mispositioned are in the correct position.

(continued)

Vogtle Units 1 and 2 B 3.6.6-7 Rev. b~ ~ /00 I

BASES APPLICABILITY (continued)

ACTIONS Vogtle Units 1 and 2 AFW System B 3.7.5 In MODE 5 or 6, the steam generators are not normally used for heat removal, and the AFW System is not required.

A Note prohibits the application of LCO 3.0.4b to an inoperable AFW train. There is an increased risk associated 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.

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:

a.

The redundant OPERABLE steam supply to the turbine driven AFW pump;

b.

The availability of redundant OPERABLE motor driven AFW pumps; and

c.

The low probability of an event occurring that requires the inoperable steam supply to the turbine driven AFW pump.

The seoond Completion Time for Required Action /\\.1 establishes a limit on the maximum time allowed for any combination of Conditions to be inoperable during any continuous failure to meet this LCO.

between 7 days and 10 days dictates that both Completion Times apply simultaneously, and the more restrictive must be met.

B.1 With one of the required AFW trains (pump or flow path) inoperable for reasons other than Condition A, action must be taken to restore OPERABLE status within 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . This (continued)

B 3.7.5-5 Rev*14 9/051

BASES ACTIONS Vogtle Units 1 and 2 AFW System B 3.7.5 B.1 (continued)

Condition includes the loss of two steam supply lines to the turbine driven AFW pump. The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time is reasonable, based on redundant capabilities afforded by the AFW System, time needed for repairs, and the low probability of a DBA occurring during this time period.

+Re sesens GSffiJ3letisn +iFfle fSF ReEjl:liFes Astien l"iU estaslisRes a liFflit sn tRe Ffla*iFfll:lffi tiffie allewes fSF any cSFflsinatisn ef Gensitiens te se insJ3eFasle sl:lFin§ any centinl:lsl:Is faill:lFe te ffieet tRis LGO.

+Re ~ Q say GsmJ3letisn +ime J3FsviEles a limitatisn tiFfle alls'.veEi in tRis sJ3ecifieEl Gsnditisn afteF disceveFY sf faill:lFe te meet tRe LGO. +Ris liFflit is csnsiseFed Feasenasle feF sitl:latisns in IIt!RicR Gsnditisns A and g aFe enteFed censl:lFFently. +Re AN!;) ssnnesteF setween 1'J. RSI:IFS and

~ Q lays E1ictates tRat sStR GsmJ3letisn +iFfles aJ3J3ly siml:lltanssl:lsly, ans lRe FflSFe FestFictive ml:lst se met.

C.1 and C.2 When Required Action A.1 or B.1 cannot be completed within the required Cornpletion Time, or if two AFW trains are inoperable, the unit must be placed in a MODE in which the LCO does not apply. To achieve this status, the unit must be placed in at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and in MODE 4 within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

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

In MODE 4, AFW is not required since RHR is available.

If all three AFW trains are inoperable, the unit is in a seriously degraded condition with no safety related means for conducting a cooldown, and only limited means for conducting a cooldown with nonsafety related equipment. In such a condition, the unit should not be perturbed by any action, including a power change, that might result in a trip. The seriousness of this condition requires that action be started immediately to restore one AFW train to OPERABLE status.

( continued)

B 3.7.5-6 Rev.I'J. 6/Qsl

BASES ACTIONS (continued)

AC Sources -

Operating B 3.8.1 According to Regulatory Guide 1.93 (Ref. 6), operation may continue in Condition A for a period that should not exceed 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months . With one required offsite circuit inoperable, the reliability of the offsite system is degraded, and the potential for a loss of offsite power is increased, with attendant potential for a challenge to the unit safety systems. In this Condition, however, the remaining OPERABLE offsite circuit and DGs are adequate to supply electrical power to the onsite Class 1 E Distribution System.

The 72 hour8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Completion Time takes into account the capacity and capability of the remaining AC sources, a reasonable time for repairs, and the low probability of a DBA occurring during this period.

+Ae seeeAS GeFfl~letieA +ime feF ReEll:liFel AetieA,6..~ estaslisAos a limit eA the Ffla*iml:lm tiFfle alielNel feF aAY eemsiAatieA ef FOEll:lires AG

~ewer Sel:lFeeS te ee iAef)eraele Sl:lriA§ aAY siR§le eeRti§l:lel:ls eeSl:lrreASO ef failiR§ te meet tAe bGG. If GeAsitieA A is eRteFes wAile, fer iAstaRee, a QG is iRef)eraelo aRs that QG is sl:leseElueAtly FetUFRol GP~J~,6.BbE, tAo bGG Fflay alrealy Aal;lo eeeR Ret met feF u~ te

~ ~ lays. +Ais seull leal te a tetal ef ~ 4 lays, siRee iAitial failure te meet tAe bGG, te restere tAe e#site 6ir6l:lit. At tAis tiFfle, a QG seuld a§aiA eeseFfle iAef)eraelo, tAe eirsl:lit Festerod GPERABbE, aAd aA adlitieAal 7'2. Aew::s, er ~ 4 says so~eAliA§ eA S;A.+ availaeility, allewel

~rier te seFflFllete resteratieA ef tAe bGG. +Ae ~ 4 lay Gem~letieA

+imo Flr9vides a liFflit eA tAe tiFflo allewel iR a sl3esifies eeAditieA after lissevory ef failure te Ffleet tAo bGG. +his IiFflit is seAsidered reaseAasle fer sitl:latieAs iA whish GeRsitieAs A aRd Bare eAtered seAsurreAtly. +Re "At-m" seRAester eetweeA tAe 7'2. Fleur aAd ~ 4 day GeFflf)letieA +iFfles FfleaAS that eeth GeFfll3letieA +imes a~l3ly simultaAeeusly, aAl tRo meFO Fostristivo Gom~letieA +imo must ee

~

+rasl~iR§ tho ~ 4 say GeFfl~lotieR +imo is a rOEll:lirOmoAt fer SO§iRRiR§ the Goml3lotieA +iFflo "slesk" that is iA alditieA te the Rermal Geml3letieR +ime rOEll:liFemeRts. WitA FeSl3eet te tAo ~ 4 lay GeFflf)lotieR +ime, the "time 2OeFO" is sl30sified as (continued)

Vogtle Units 1 and 2 B3.8.1-7 Rev.l~ 6/981

AC Sources -

Operating B 3.8.1 BASES ACTIONS A.3 (continued) commencing at the time LCO 3.8.1 was initially not met, instead of at tAe time Condition A was entered. This results in the requirement when in this Condition to traci{ the time elapsed from both the Condition A "time zero" and the "time zero" \\vhen LCO 3.8.1 was initially not met.

B.1 To ensure a highly reliable power source remains with an inoperable DG, it is necessary to verify the availability of the offsite circuits on a more frequent basis. Since the Required Action only specifies "perform," a failure of SR 3.8.1.1 acceptance criteria does not result in a Required Action being not met. However, if a circuit fails to pass SR 3.8.1.1, it is inoperable. Upon offsite circuit inoperability, additional Conditions and Required Actions must then be entered.

The 13.8/4.16 kV Standby Auxiliary Transformer (SAT) is a qualified offsite circuit that may be connected to the onsite Class 1 E distribution system independently of the RATs and may be utilized to meet the LCO 3.8.1 requirements for an offsite circuit. Its availability permits an extension of the allowable out-of-service time for a DG to 14 days from the discovery of failure to meet LCO 3.8.1. The SAT is available when it is:

II Operable in accordance with plant procedures; II Not already being applied to any of the four 4.16 kV ESF buses for Units 1 and 2 in accordance with Specification 3.8.1 as either an offsite source or to meet the requirements of an LCO 3.8.1 Condition; and, II Not providing power to the other unit when that unit is in MODE 5 or 6 or defueled.

(continued)

Vogtle Units 1 and 2 B 3.8.1-8 Rev.11 6/981

BASES (continued)

ACTIONS Distribution Systems -

Operating B 3.8.9 A.1 With one or more required AC buses, load centers, motor control centers, or distribution panels, except AC vital buses, inoperable, and the remaining AC electrical power distribution subsystems capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure, the overall system reliability is reduced. A single failure in the remaining power distribution subsystems could result in the minimum required ESF functions not being supported. Therefore, the required AC buses, load centers, motor control centers, and distribution panels must be restored to OPERABLE status within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months .

Condition A worst scenario is one train without AC power (i.e., no offsite power to the train and the associated DG inoperable). In this Condition, the unit is more vulnerable to a complete loss of AC power.

The 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months time limit before requiring a unit shutdown in this Condition is acceptable because of:

a.

The potential for decreased safety if the unit operator's attention is diverted from the evaluations and actions necessary to restore power to the affected train, to the actions associated with taking the unit to shutdown within this time limit; and

b.

The potential for an event in conjunction with a single failure of a redundant component in the train with AC power.

The second Completion Time for Required I'.ction 1'..1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition I'. is entered while, for instance, a DC bus is inoperable and subsequently restoreG OPER/\\BLE, the LCO may already have been not met for up to 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months . This could lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months . since initial failure of the LCO, to restore the I'.C distribution system. I\\t this time, a DC circuit could again become inoperable, and I'.C distribution restored OPERl\\BLE. This could continue indefinitely.

(continued)

Vogtle Units 1 and 2 B 3.8.9-5 Revision NO.[£]

BASES ACTIONS Distribution Systems -

Operating B 3.8.9 A.1 (continued)

The Completion Time allows for an exception to the normal "time zero" for beginning the allowed outage time "clock." This will result in establishing the "time zero" at the time the LCO was initially not met, instead of the time Condition A was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

B.1 With one or more AC vital buses inoperable and the remaining OPERABLE AC vital buses capable of supporting the minimum safety functions necessary to shut down the unit and maintain it in the safe shutdown condition, overall reliability is reduced. An additional single failure could result in the minimum required ESF functions not being supported. Therefore, the required AC vital buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated inverter with DC power available to the inverter or the Class 1 E regulating transformer.

Condition B represents one or more AC vital buses without power; potentially both the DC source and the associated AC source are nonfunctioning. In this situation, the unit is significantly more vulnerable to a complete loss of all non interruptable power.

This 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months limit is more conservative than Completion Times allowed for the vast majority of components that are without adequate vital AC power. Taking exception to LCO 3.0.2 for components without adequate vital AC power, that would have the Required Action Completion Times shorter than 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months if declared inoperable, is acceptable because of:

a.

The potential for decreased safety by requiring a change in unit conditions (Le., requiring a shutdown) and not allowing stable operations to continue;

b.

The potential for decreased safety by requiring entry into numerous Applicable Conditions and Required Actions for components without adequate vital AC power and not providing sufficient time for the operators to

( continued)

Vogtle Units 1 and 2 B 3.8.9-6 Revision NO.~

BASES ACTIONS Distribution Systems -

Operating B 3.8.9

b.

(continued) perform the necessary evaluations and actions for restoring power to the affected train; and

c.

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

The 2 hour2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months Completion Time takes into account the importance to safety of restoring the AC vital buses to OPERABLE status, the redundant capability afforded by the other OPERABLE vital buses, and the low robabilit of a DBA occurrin durin this eriod.

The second Completion Time for Required Action B.1 establishes a limit on the maximum allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition B is entered while, for instance, an AC bus is inoperable and subsequently returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This Gould lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the vital bus distribution system. I\\t this time, an AC train could again become inoperable. and vital bus distribution restored OPERABLE. This could continue indefinitely.

This Completion Time allo'...,s for an exception to the normal "time zero" for beginning the allowed outage time "clool(." This *...,ill result in establishing the "time zero" at the time the LCO 'Nas initially not-met, instead of the time Condition B was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the With one or more DC buses inoperable and the remaining DC electrical power distribution subsystems capable of supporting the minimum safety functions necessary to shut down the reactor and maintain it in a safe shutdown condition, assuming no single failure, the overall system reliability is reduced. A single failure in the remaining DC electrical power distribution subsystem could result in

( continued)

Vogtle Units 1 and 2 B 3.8.9-7 Revision NO.~

BASES ACTIONS Distribution Systems -

Operati ng B 3.8.9 C.1 (continued) the minimum required ESF functions not being supported. Therefore, the required DC buses must be restored to OPERABLE status within 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months by powering the bus from the associated battery or charger.

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

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

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

a.

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

b.

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

c.

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

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

The second Completion Time for Required Action C.1 establishes a limit on the maximum time allowed for any combination of required distribution subsystems to be inoperable during any single contiguous occurrence of failing to meet the LCO. If Condition C is entered while, for instance, an AC bus is inoperable and subsequently

( continued)

Vogtle Units 1 and 2 B3.8.9-8 Revision NO.~

Distribution Systems -

Operating B 3.8.9 BASES ACTIONS SURVEILLANCE REQUIREMENTS C.1 (continued) returned OPERABLE, the LCO may already have been not met for up to 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . This could lead to a total of 10 hours1.157407e-4 days 0.00278 hours 1.653439e-5 weeks 3.805e-6 months , since initial failure of the LCO, to restore the DC distribution system. At this time, an AC train could again become inoperable, and DC distribution restored OPERABLE. This could continue indefinitely.

This Completion Time allo'...,s for an exception to the normal "time zero" for beginning the allO'tved outage time "Glock." This will result in establishing the "time zero" at the time the LCO INas initially not met, instead of the time Condition C was entered. The 16 hour1.851852e-4 days 0.00444 hours 2.645503e-5 weeks 6.088e-6 months Completion Time is an acceptable limitation on this potential to fail to meet the LCO indefinitely.

0.1 and 0.2 If the inoperable distribution subsystem cannot be restored to OPERABLE status within the required Completion Time, the unit must be brought to a MODE in which the LCO does not apply. To achieve this status, the unit must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 5 within 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required unit conditions from full power conditions in an orderly manner and without challenging plant systems.

With two or more electrical power distribution subsystems inoperable that result in a loss of safety function, vital functions for DBA mitigation would be compromised, and immediate plant shutdown in accordance with LCO 3.0.3 is required.

SR 3.8.9.1 This Surveillance verifies that the required AC, DC, and AC vital bus electrical power distribution systems are

( continued)

Vogtle Units 1 and 2 B 3.8.9-9 Revision NO.~

Vogtle Electric Generating Plant, Units 1 and 2 License Amendment Request for Incorporation of Previously NRC Approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-439-A, Revision 2, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" and Administrative Revisions to Technical Specification 3.6.6 Technical Specifications Clean-Typed Pages

1.3 Completion Times 1.3 Times DESCRIPTION However, when a subsequent train, subsystem, component, or (continued) variable expressed in the Condition is discovered to be inoperable or not within limits, the Completion Time(s) may be extended. To apply this Completion Time extension, two criteria must first be met. The subsequent inoperability:

a.

Must exist concurrent with the first inoperability; and

b.

Must remain inoperable or not within limits after the first inoperability is resolved.

The total Completion Time allowed for completing a Required Action to address the subsequent inoperability shall be limited to the more restrictive of either:

a.

The stated Completion Time, as measured from the initial entry into the Condition, plus an additional 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ; or

b.

The stated Completion Time as measured from discovery of the subsequent inoperability.

The above Completion Time extensions do not apply to those Specifications that have exceptions that allow completely separate re-entry into the Condition (for each train, subsystem, component, or variable expressed in the Condition) and separate tracking of Completion Times based on this re-entry. These exceptions are stated in individual Specifications.

The above Completion Time extension does not apply to a Completion Time with a modified "time zero." This modified "time zero" may be expressed as a repetitive time (i.e., "once per 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months ," where the Completion Time is referenced from a previous completion of the Required Action versus the time of Condition entry) or as a time modified by the phrase "from discovery..."

(continued)

Vogtle Units 1 and 2 1.3-2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

Completion Times 1.3 1.3 EXAMPLE 1.3-3 (continued)

CONDITION ACTION COMPLETION TIME One A.1 7 days X

train inoperable.

status.

One B.1 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function Y train inoperable.

C.

One C.1 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months Function X train inoperable.

AND One hours Function Y train inoperable.

1 2

1 No.

(Unit 1)

Amendment No.

(Unit 2)

1.3 1

Completion Times (continued) are inoperable.

The separately for each train each train was inoperable and Condition was entered. A separate Completion is established for Condition C tracked from the time train was declared inoperable

. the time the situation in Condition C was discovered}.

If Action C.2 is completed within Completion Conditions B C are exited. If the Time for Required Action A 1 not expired, operation may continue in accordance with Condition A.

It is systems to me could continue et LCO. However.

Completion Times.

C in such a without ever restoring so would be inconsistent with shall be administrative controls to limit the maximum allowed for any combination of Conditions that result in a contiguous occurrence of failing to meet the LCO. These administrative controls shall ensure that the Completion Times for those Conditions are not inappropriately Vogtle Units 1 and 2 1.3-7 Amendment No.

(Unit 1)

Amendment No.

(Unit

Containment Spray and Cooling CONTAINMENT SYSTEMS 3.6.6 Containment Spray and Cooling LCO 3.6.6 Two containment two containment cooling OPERABLE.

APPLICABILITY:

1, ACTIONS CONDITION A.

One containment spray A.1 train inoperable.

B.

One containment 1

cooling train inoperable.

Required Action and Completion Time not met.

IRED ACTION COMPLETION TIME containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months spray train to OPERABLE status.

containment 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months cooling train to status.

in

3.

6 in 84 hours9.722222e-4 days 0.0233 hours 1.388889e-4 weeks 3.1962e-5 months Vogtle Units 1 and 2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.7.5 AFW System 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 3.

ACTIONS

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

LCO 3.0Ab is not applicable.

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.

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.

(continued)

Vogtle Units 1 and 2 3.7.5-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

3.8.1 AC

- Operating ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. (continued)

A.2 required feature(s) hours from with no power discovery no available inoperable when power to one train its redundant required concurrent with is inoperability of redundant required feature(s) required 72 circuit to OPERABLE Units 1 and 2 3.8.1 Amendment No.

(Unit 1)

Amendment No.

(Unit (continued)

3.8.9 Distribution Systems - Operating 3.8 ELECTRICAL POWER SYSTEMS 3.8.9 Distribution Systems - Operating LCO 3.8.9 The required AC, DC, and AC vital bus electrical power distribution subsystems shall be OPERABLE.

~OTE---------------------------------------------

The redundant emergency buses of 4160 V switchgear 1/2AA02 and 1/2BA03 may be manually connected within the unit by tie breakers in order to allow transfer of preferred offsite power sources provided SR 3.8.1.1 is successfully performed within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months prior to the interconnection. The interconnection shall be implemented without adversely impacting the ability to simultaneously sequence both trains of LOCA loads.

APPLICABILITY:

MODES 1, 2, 3, and 4.

ACTIO~S CO~DITIO~

REQUIRED ACTIO~

COMPLETIO~ TIME A.

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

OPERABLE status.

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

OPERABLE status.

(continued)

Vogtle Units 1 and 2 3.8.9-1 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

CONDITION power subsystems 1

Required Action and Completion Time not met.

0.1 0.2 or more electrical distribution "CTorr,e inoperable in a loss of 1

S IREMENTS SURVEILLANCE 1

Verify correct required AC, DC, and distribution subsystems.

Distribution Systems ACTION COMPLETION 2

in MODE 3.

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

36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months Immediately FREQUENCY voltage to In with electrical power the Surveillance Frequency Control Program Units 1 and 2 Amendment No.

(Unit 1)

Amendment No.

(Unit 2)

v t e Letter Sequence Request
TAC:ME9470, Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO (Approved, Closed)
Initiation Request Acceptance... Administration Questions 13 November 2012 Answers 6 December 2012 Results Approval Other:
MONTHYEAR2012-12-06 [Table View]

NL-12-1002, License Amendment Request for Incorporation of Previously NRC Approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-439-A, Rev. 2, Eliminate Second Completion Times Limiting

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Enclosures:

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NL-12-1002, License Amendment Request for Incorporation of Previously NRC Approved Technical Specification Task Force (TSTF) Standard Technical Specification Change Traveler TSTF-439-A, Rev. 2, Eliminate Second Completion Times Limiting

Text

Enclosures:

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