NL-16-1008, Response to Request for Additional Information on Technical Specifications Change to Allow Risk Informed Completion Times

Response to Request for Additional Information on Technical Specifications Change to Allow Risk Informed Completion Times

ML16195A503
Person / Time
Site:	Vogtle
Issue date:	07/13/2016
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-16-1008
Download: ML16195A503 (22)

Text

Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7872 SOUTHERN << \

Fax 205.992.7601 NUCLEAR A SOUTHERN COMPANY JUL 1 3 2016 Docket Nos.: 50-424 NL-16-1008 50-425 U.S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 and 2 Response to Request for Additional Information on Technical Specifications Change to Allow Risk Informed Completion Times Ladies and Gentlemen:

By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license amendment request to modify the Vogtle Electric Generating Plant, Units 1 and 2, Technical Specifications (TS) to implement risk informed completion times into their TS, per the guidelines of Nuclear Energy Institute (NEI) Report NEI 06-09, Revision 0-A, "Risk-Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS)

Guidelines".

By letters dated May 16, 2013, June 9, 2014, June 25, 2014, October 14, 2014, and December 17, 2015, the U.S. Nuclear Regulatory Commission (NRC) requested additional information (RAI). SNC responded to those requests by letters dated August 2, 2013, July 3, 2014, July 17, 2014, November 11, 2014, December 12,2014, March 16,2015, May 5, 2015, February 17,2016, and April 18,2016.

On June 15, 2016, the NRC issued another RAI and requested a response within 30 days. Accordingly, Enclosure 1 provides the SNC responses. Enclosure 2 includes the marked-up TS changes which support the responses to NRC questions PRA RAI S-1(A), PRA RAI S-2, and DORL-RAI-1. Enclosure 3 provides the clean-typed TS pages.

In preparing this response, it was noticed that LCO 3.5.4.D, "RWST inoperable ... ", had not previously been identified to NRC as a Loss of Function (LOF) condition. Consequently, SNC is also including, in Enclosures 2 and 3 respectively, marked-up and clean typed pages of LCO 3.5.4. These pages identify Condition 3.5.4.D as a LOF.

U.S. Nuclear Regulatory Commission NL-16-1008 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. C. A. Pierce states he is Regulatory Affairs 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 I

ce~s~

C. A. Pierce Regulatory Affairs Director

'2016.

My commission expires: I

/0 cl-O t-1

Enclosures:

1. Responses to Request for Additional Information

2. Marked-Up Technical Specifications Pages

3. Clean-Typed Technical Specifications Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. A. Madison, Vice President- Fleet Operations Mr. M.D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatorv Commission Ms. C. Haney, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. W. D. Deschaine, Senior Resident Inspector- Vogtle 1 & 2 State of Georaia Mr. J. H. Turner, Director- Environmental Protection Division

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the Use of Risk Informed Completion Times Enclosure 1 Responses to Request for Additional Information to NL-16-1008 Responses to Request for Additional Information NRC Question PRA RAI S-1 (A}

Limiting conditions for operation (LCOs) are the lowest functional capability, or performance levels, of equipment required for safe operation of the facility.

Section 50.36 of Title 10 of the Code of Federal Regulations requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the Technical Specifications (TSs) until the condition can be met. Upon declaration of TS Loss of Function (TS LOF) i.e.,

that the TS-required equipment is inoperable and the TS specified safety function cannot be accomplished, the associated TS completion time permits a brief period to restore equipment to operable status, if possible, and to prepare for an orderly shutdown. If the restoration is unsuccessful, then the TSs require a plant shutdown.

Technical Specifications Task Force (TSTF) Traveler TSTF-505 guidance for of an LAR instructs a licensee to include a description of PRA functionality used for each associated inoperable safety function. In Section 4.0, "Limitations and Conditions," of the NRC staff's safety evaluation (SE) dated May 17, 2007, for NEI topical report NEI 06-09, the NRC staff stated that LARs should provide a comparison of the TS functions to the PRA modeled functions of the SSCs subject to those LCO actions. The SE states that this comparison should justify that the scope of the Probabilistic Risk Assessment (PRA) model, including applicable success criteria such as number of SSCs required, flowrate, etc., are consistent with the licensing basis assumptions (i.e., 10 CFR 50.46 Emergency Core Cooling System (ECCS) flowrates) for each of the TS requirements, or an appropriate disposition or programmatic restriction will be provided. The licensee's submittal did not provide a sufficient level of detail for the NRC staff to evaluate how PRA Functional compares with each associated inoperable safety function.

To address that issue, by letter dated December 17, 2015, the NRC staff requested the licensee to provide additional explanation about how the definition of PRA Functional in NEI 06-09 maintains sufficient defense-in-depth and safety margins when used during a TS-LOF condition. SNC responded to RAis 1.a, and 2.c in its letter dated February 17, 2016, and RAI 2.a in its letter dated April 18, 2016, and proposed additional constraints on establishing PRA Functional to maintain sufficient defense-in-depth and safety margins when using PRA Functional during TS-LOF conditions.

The NRC staff determined that even with the additional constraints proposed by the licensee, there remains uncertainty associated with establishing and maintaining PRA Functional during a TS-LOF without the comparison of TS functions to PRA modeled functions when all trains of equipment are inoperable.

All configurations that could be assigned PRA Functional under these conditions have not been predetermined nor reviewed and approved by the NRC.

Considering the remaining uncertainty associated with the PRA Functionality determination, the NRC staff requests that SNC provide justification for its position and/or any additional constraints or controls that may be warranted to address this uncertainty.

E1-1 to NL-16-1008 Responses to Request for Additional Information The NRC staff requests SNC to discuss the completion time backstop associated with TS-LOF and its basis. In particular, the NRC requests SNC to clarify whether it intends to adopt a 24-hour backstop (and if so, how it intends to do so, in addition to providing marked-up TS pages) and whether SNC intends to revise TS 5.5.22 to incorporate the following constraints delineated in SNC's previous RAI response (and if so, how it intends to do so, in addition to providing marked up TS pages):

i) Alternative SSCs cannot replace the SSCs covered by the TSs as described in the response to RAI 1.a ii) Design basis success criteria parameters shall be met for design basis accident scenarios that are not modelled in the internal events PRA as described in the response to 2.a.

iii) Design basis success criteria parameters shall be met for design basis accident scenarios modelled in the internal events PRA as described in the response to 2.c.

SNC Response:

Southern Nuclear Operating Company (SNC) does not intend to adopt a flat 24-hour Completion Time for the LOF Conditions but rather a graduated backstop, described in the response to part B of this question below.

SNC intends to place the above three constraints for PRA Functionality on Loss of Function into Section 5.5 of the TS. Additionally, the constraints will be included in RICT program procedures to be used at the actual RICT entry for their evaluation at that particular time. provides a mark-up of the proposed revised Section 5.5 with a description of the PRA Functionality constraints and the graduated backstop.

NRC Question PRA RAI S-1 (B)

If SNC does not intend to adopt the 24-hour backstop and the aforementioned constraints in PRA RAI S-1.A, then the staff requests SNC to discuss a proposed alternative to RAI S-1.A to address the aforementioned uncertainty and the Limitations and Conditions SNC Response Based on the discussion at the June 20, 2016 NRC Public Meeting on TSTF-505, SNC intends to adopt a graduated approach to determine the completion time for a TS LOF Condition. Specifically, SNC intends to use an administrative backstop of either 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 7 days based on the calculated plant configuration-specific Risk Informed Completion Time (RICT). This concept mirrors the current TS philosophy where the SSCs that are regarded as most important to safety are assigned the most limiting Completion Times prior to requiring a plant shutdown.

E1-2 to NL-16-1008 Responses to Request for Additional Information A list of systems with descriptions of the TS LOF Conditions is provided in the table below.

Item LCO Description RICT No. Condition 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Administrative LOF Backstop 1 3.7.8 B Nuclear System Cooling Water cNote 11 RICT<7 days 2 3.8.1 G AC Sources Operating (three or more RICT<7 days required AC sources) 1Note 11 3 3.8.7 B Inverters Operating tNote 11 RICT<7 days 4 3.8.9 D Distribution Systems Operating tNote 11 RICT<7 days 5 3.7.7 B Component Cooling Water(Note2) RICT>100 days Exception MSPI system 6 3.5.4 D RWST(Note 3) RICT>100 days Exception - Single train system 7 3.7.5C AFW(Note2) RICT>7 days Exception MSPI system.

8 3.8.1 E AC Sources Operating (DGs) (Note 2) RICT>7 days Exception MSPI system 9 3.4.10 A Pressurizer Safety Valves cNote 3l RICT>100 days 7 day Administrative LOF Backstop 1 3.4.11 E PORVs tNote 11 RICT>30 days 2 3.5.1 c Accumulators cNote 11 RICT>7 days 3 3.7.2 B MSIVs cNote 11 RICT>100 days 4 3.7.4 B Atmospheric Relief Valves (ARVs) RICT>90 days INote 11 5 3.8.4 D DC Sources Operating cNote 11 RICT>7 days 6 3.7.14 B ESF Coolers and Chillers cNote 1l RICT>100 days Note 1: RICTs are estimates based on assuming at least one train is PRA Functional and an assumed worst-case hypothetical SSC is out of service. The actual RICT values that determine the applicable backstops of 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 7 days will be based on the actual plant configuration, operating equipment alignments and the on-record version of the PRA model available at the time of RICT Program implementation.

Note 2: RICTs are estimated based on Note 1 assumptions. However, the backstop for these TS LOF Conditions was adjusted back to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> even though the estimated RICT was greater than 7 days since these are MSPI systems.

Note 3: RICTs are estimated based on Note 1 assumptions. However, the backstop for these TS LOF Conditions was adjusted back to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> since these are single train systems.

In order to continue operation and apply a RICT administrative backstop, the requirements as requested in NRC Question PRA RAI S-1 (A) will be placed in Section 5.5 of the TS.

The constraints identified above limit the application of a RICT to a narrow range of degradation conditions in which all trains are declared inoperable. A graduated risk-informed backstop recognizes the relative importance of SSCs to the safe operation of the plant. Additionally, use of a graduated backstop will allow the E1-3 to NL-16-1008 Responses to Request for Additional Information plant to reduce unnecessary forced shutdowns with TS Inoperable Conditions which do not impact plant design parameters.

In conclusion, SNC's approach to use a graduated RICT administrative backstop of either 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or 7 days during TS LOF Conditions mirrors the current TS concept of using a graduated approach to determine Completion Times for addressing nuclear safety.

NRC Question PRA RAI S-2 The proposed revision toTS 3.5.2, ECCS- Operating", on page 3.5.2-1 of the submittal dated September 13, 2012, includes an "Insert 5". Insert 5 includes a new Condition B that states, "Less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available," with a Completion Time of "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OR in accordance with the Risk Informed Completion Time Program." The attachments to the licensee's supplement dated November 11, 2014, provide new and/or changes to the TSs proposed in the amendment request. TS 3.5.2 is not listed as being changed from the supplement dated November 11, 2014.

A. It appears that the proposed revision to TS 3.5.2 still includes a new Condition B, "Less than 100% of the ECCS flow equivalent to a single OPERABLE ECCS train available" with a Completion Time of "1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OR in accordance with the Risk Informed Completion Time Program". The NRC staff requests SNC to clarify its intent to proceed with the requested change to TS 3.5.2.

B. If Insert 5 is still intended to be included, then the NRC staff requests SNC to explain how this is consistent with the constraints identified in PRA RAI S-1.A above or to remove the new condition.

C. The NRC staff requests SNC to identify any proposed changes to the TSs that conflict with the constraints or controls identified in PRA RAI S-1 and to provide a disposition of any conflict.

SNC Response SNC will remove proposed Condition 3.5.2.B from the scope of the VEGP Risk Informed Completion Time program.

SNC has also identified two other LCO Conditions that must be removed from the scope of the RICT program.

LCO 3.7.6 states, "One CST shall be OPERABLE with a safety related volume of

~ 340,000 gallons." Condition 3.7.6.A states, "CST volume not within limit".

Condition 3.7.6.A specifically refers to the 340,000 gallons, which is a design parameter. Therefore, including this in the RICT program as an LOF condition conflicts with the constraint which requires that design basis success parameters be met during LOF Conditions. Consequently, LCO 3.7.6 will also be removed from the RICT program. (Note that there is a separate LCO 3.7.6 for each VEGP unit. Both will be removed from the program).

E1-4

Enclosure 1 to NL-16-1008 Responses to Request for Additional Information Condition 3.5.4.A specifically refers to boron concentration limits and water temperature limits for the Refueling Water Storage Tank. Therefore, for the same reason as Condition 3.7.6.A, it too must be removed from the RICT program.

SNC has not identified any other LOF Conditions that would, at all times, conflict with the constraints listed in PRA RAI S-1.

Additionally, the Note for LCO Condition 3.5.2.A is being removed since it is now obsolete. The Note was a one-time change to the Completion Time, used for VEGP Unit 1 during Cycle 19. VEGP Unit 1 is now operating in Cycle 20. This change has no effect on the proposed changes to LCO 3.5.2, or to any other aspect of the proposed TS change to implement the Risk Informed Completion Time program for the VEGP.

The revised LCO 3.5.2 page and LCO 3.5.4 pages are included in Enclosures 2 and 3.

With the elimination of the change to LCO Condition 3.7.6.A, no changes are being proposed to these TS pages from the current TS version. Therefore, no revised pages are necessary for LCO 3.7.6.

NRC Question DORL-RAI-1 In the LAR and its associated revised TS pages, SNC refers to NEI 06-09, Revision 0. NEI 06-09, Revision 0-A incorporates changes based on the NRC staff's safety evaluation dated May 7, 2007, of NEI 06-09, Revision 0. The staff requests SNC to clarify whether it intended to incorporate NEI 06-09, Revision 0-A in the TS, and if so, to submit marked up TS pages that reference Revision 0-A of NEI 06-09.

SNC Response SNC intends to incorporate NEI 06-09, Revision 0-A into the VEGP TS.

Accordingly, proposed Section 5.5.22 of the VEGP TS will specifically reference this version. provides the marked up TS pages and Enclosure 3 the clean-typed pages.

Additional Loss of Function Condition The Table on page E1-3 of this letter lists LCO 3.5.4.D as a LOF Condition.

However, this particular LCO Condition has not been identified in any of SNC's previous correspondences as a LOF. Consequently, Enclosures 2 and 3 also include a marked-up and clean typed page showing LCO Condition 3.5.4.D, "RWST inoperable for reasons other than Condition A or 8", as a LOF.

E1-5

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the Use of Risk Informed Completion Times Enclosure 2 Marked-Up Technical Specifications Pages

ECCS- Operating 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

---

N 0 TE ----------------------------------------------

In MODE 3 , either residual heat removal pump to cold legs injection flow path may be isolated by closing the isolation valve to perform pressure isolation valve testing per SR 3.4.14.1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more trains A.1 Restore train(s) to NG+

inoperable. OPERABLE status. A oRe tiFf!e oRiy sl=laR§e of tl=le AND GoFfiJ'IIetioA +iA=~e to 7 Elays is J'leFFflitteEI feF At least 100% of the tl=le ~A RI=IR f:IUR=IJ'I ECCS flow equivalent to FflotoF FeJ'IIaseFf!eAt a single OPERABLE GI:.IFiA§ Vo§tle 6JAit ~ ,

ECCS train available. Gysle ~9 . +l=le iASFeaseEI GoFfiJ'IIetioA

+iA=~e is 8f'lf:llisaele oAiy to tl=le 1A RHR

. ~

I Insert

~ ~ hours B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Vogtle Units 1 and 2 3.5.2-1 Amendment No. +79 (Unit 1)

Amendment No . .:+ae (Unit 2)

Insert OR In accordance with the Risk Informed Completion Time Program

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A RWST boron A.1 Restore RWST to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> concentration not within OPERABLE status.

limits.

OR RWST borated water temperature not within limits.

B. One or more sludge B.1 Restore the valve(s) to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mixing pump isolation OPERABLE status. +

valves inoperable. ~Insert 2 C. Required Action and C.1 Isolate the sludge mixing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion system.

~me of Condition B not I Insert et.

D. RWST inoperable for reasons other than Condition A or B.

D.1 Restore RWST to OPERABLE status. ...

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

-i Insert 2 (continued)

Vogtle Units 1 and 2 3.5.4-1

Insert NOTE Not Applicable when the RWST is intentionally made inoperable.

Insert 2 OR In accordance with the Risk Informed Completion Time Program

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Control Room Envelope Habitability Program (continued)

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

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

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

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

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

I 31 I

Insert Vogtle Units 1 and 2 5.5-20

INSERT 3 5.5.22 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI-06-09, Revision 0-A ,

"Risk-Managed Technical Specifications (RMTS) Guidelines." The program shall include the following :

a. The RICT may not exceed 30 days;

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

c. When a RICT is being used, any plant configuration change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

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

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

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

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function of all required trains of a system required to be OPERABLE if one or more of the trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09, Revision 0-A. However, the following additional constraints shall be applied to the criteria for "PRA Functional":

1. Any SSCs credited in the PRA Functionality determination shall be the same SSCs relied upon to perform the Technical Specifications safety function .

2. For design basis accident scenarios that are not modeled in the PRA because they do not affect the CDF or the LERF, the PRA Functionality evaluation performed following a TS LOF Condition entry will ensure SSCs not supporting CDF/LERF will remain available and sufficient.

3. For design basis initiators modeled in the internal events PRA, the PRA Functionality determination performed subsequent to a TS LOF Condition entry will ensure design basis success criteria for parameters (e.g., flow rate, temperature limits) are met.

The RICT for high risk plant configurations may not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; the RICT for low risk plant configurations may not exceed 7 days.

f. A RICT entry is not permitted , or a RICT entry made shall be exited , for any condition involving a TS loss of Function if a PRA Functionality determination that reflects the plant configuration concludes that the LCO cannot be restored without placing the TS inoperable trains in an alignment which results in a loss of functional level PRA success criteria .

Vogtle Electric Generating Plant Response to Request for Additional Information on License Amendment Request to Permit the Use of Risk Informed Completion Times Enclosure 3 Clean Typed Technical Specifications Pages

ECCS- Operating 3.5.2 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.2 ECCS - Operating LCO 3.5.2 Two ECCS trains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

---

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

In MODE 3, either residual heat removal pump to cold legs injection flow path may be isolated by closing the isolation valve to perform pressure isolation valve testing per SR 3.4.14.1.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One or more trains A.1 Restore train(s) to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable. OPERABLE status.

OR AND In accordance with At least 100% of the the Risk Informed ECCS flow equivalent to Completion Time a single OPERABLE Program ECCS train available.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND B.2 Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Vogtle Units 1 and 2 3.5.2-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RWST 3.5.4 3.5 EMERGENCY CORE COOLING SYSTEMS (ECCS) 3.5.4 Refueling Water Storage Tank (RWST)

LCO 3.5.4 The RWST shall be OPERABLE.

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

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. RWST boron A.1 Restore RWST to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> concentration not within OPERABLE status.

limits.

OR RWST borated water temperature not within limits.

B. One or more sludge B.1 Restore the valve(s) to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> mixing pump isolation OPERABLE status.

valves inoperable. OR In accordance with the Risk Informed Completion Time Program

c. Required Action and C. 1 Isolate the sludge mixing 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion system.

Time of Condition B not met.

(continued)

Vogtle Units 1 and 2 3.5.4-1 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RWST 3.5.4 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME D. ------NOTE---------- D.1 Restore RWST to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Not Applicable when the OPERABLE status.

RWST is intentionally OR made inoperable.

---

In accordance with RWST inoperable for the Risk Informed reasons other than Completion Time Condition A or B. Program E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A or D AND not met.

E.2 Be in MODE 5. 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.5.4.1 -------------------------NOTE------------------------------

Only required to be performed when ambient air temperature is< 40°F.

Verify RWST borated water temperature is In accordance with

~ 44°F and:::; 116°F. the Surveillance Frequency Control Program SR 3.5.4.2 Verify RWST borated water volume is~ 686,000 In accordance with gallons. the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.5.4-2 Amendment No. (Unit 1)

Amendment No. (Unit 2)

RWST 3.5.4 SURVEILLANCE REQUIREMENTS (continued)

SURVEILLANCE FREQUENCY SR 3.5.4.3 Verify RWST boron concentration is ~ 2400 ppm In accordance with and ~ 2600 ppm. the Surveillance Frequency Control Program SR 3.5.4.4 Verify each sludge mixing pump isolation valve In accordance with automatically closes on an actual or simulated the Surveillance RWST Low-Level signal. Frequency Control Program Vogtle Units 1 and 2 3.5.4-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 Control Room Envelope Habitability Program (continued)

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

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

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

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

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

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

a. The RICT may not exceed 30 days;

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

c. When a RICT is being used, any plant configuration change within the scope of the Risk Informed Completion Time Program must be considered for the effect on the RICT.

( continued)

Vogtle Units 1 and 2 5.5-20 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.22 Risk Informed Completion Time Program (continued)

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

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

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

d. Use of a RICT is not permitted for voluntary entry into a configuration which represents a loss of a specified safety function or inoperability of all required trains of a system required to be OPERABLE.

e. Use of a RICT is permitted for emergent conditions which represent a loss of a specified safety function of all required trains of a system required to be OPERABLE if one or more of the trains are considered "PRA Functional" as defined in Section 2.3.1 of NEI 06-09, Revision 0-A. However, the following additional constraints shall be applied to the criteria for "PRA Functional":

1. Any SSCs credited in the PRA Functionality determination shall be the same SSCs relied upon to perform the Technical Specifications safety function.

2. For design basis accident scenarios that are not modeled in the PRA because they do not affect the CDF or the LERF, the PRA Functionality evaluation performed following a TS LOF Condition entry will ensure SSCs not supporting CDF/LERF will remain available and sufficient.

3. For design basis initiators modeled in the internal events PRA, the PRA Functionality determination performed subsequent to a TS LOF Condition entry will ensure design basis success criteria for parameters (e.g., flow rate, temperature limits) are met.

The RICT for high risk plant configurations may not exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; the RICT for low risk plant configurations may not exceed 7 days.

f. A RICT entry is not permitted , or a RICT entry made shall be exited, for any condition involving a TS loss of Function if a PRA Functionality determination that reflects the plant configuration concludes that the LCO cannot be restored without placing the TS inoperable trains in an alignment which results in a loss of functional level PRA success criteria.

Vogtle Units 1 and 2 5.5-21 Amendment No. (Unit 1)

Amendment No. (Unit 2)