NL-14-1703, Response to Request for Additional Information on LAR to Revise Technical Specifications to Implement NEI-06-09, Rev 0, Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications Guidelines.

From kanterella
Revision as of 04:27, 28 April 2019 by StriderTol (talk | contribs) (Created page by program invented by StriderTol)
Jump to navigation Jump to search
Response to Request for Additional Information on LAR to Revise Technical Specifications to Implement NEI-06-09, Rev 0, Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications Guidelines.
ML14315A051
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/11/2014
From: Pierce C R
Southern Co, Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-14-1703
Download: ML14315A051 (87)
v • d • e


Text

Charles R. Pierce Regulatory Affairs Director November 11, 2014 Docket Nos.: 50-424 50-425 Southern Nuclear Operating Company, Inc. 40 Inverness Center Pa r kway Post Office Box 1295 Birmingham , AL 35242 Tel 205.992.7872 Fax 205.992.7601 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant , Units 1 and 2 SOUT ERN*\ COMPANY NL-14-1703 Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09 , Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines" Ladies and Gentlemen:

By Reference 1, Southern Nuclear Operating Company (SNC) submitted a license amendment request for the Vogtle Electric Generating Plant (VEGP) Technical Specifications (TS) to permit the use of the Risk Managed Technical Specifications per Reference

2. Per References 3 and 5 (as amended by Reference 6} the NRC requested additional information (RAI) to facilitate their review. SNC provided responses to those requests by References 4 and 7. Another RAI was sent from the NRC via Reference 8 to further facilitate the staff's review. Enclosure 1 to this letter contains SNC's responses to those NRC questions, which are transcribed prior to each SNC response.

Per References 4 and 7, SNC proposed revisions to the applicable TS LCOs as well as the TS mark-ups provided in Reference

1. The changes to the Reference 1 letter are described in References 4, 7, and Enclosure 1 of this letter. The updated list of applicable TS LCOs is provided in Enclosure 2 to this letter, revised TS mark-ups are provided in Enclosure 3 to this letter, and clean-typed pages are provided in Enclosure 4 to this letter. In addition to the TS Revisions discussed in References 4 , 7 , and Enclosure 1 of this letter, the NRC issued Amendment Nos. 169 and 151 to the VEGP Unit 1 and Unit 2 TS via Reference 9 to revise TS LCOs 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 in accordance with TS Task Force Traveler (TSTF)-439.

These changes were incorporated into the VEGP TS, and the mark-ups provided in Enclosure 3 to this letter incorporate the proposed amendment into the most current version of these TS LCOs. This letter contains no NRC commitments.

If you have any questions, please contact Ken McElroy at (205) 992-7369.

U.S. Nuclear Regulatory Commission NL-14-1703 Page2 Mr. C. R. 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. Respectfully C. R. Pierce Regulatory Affairs Director . ..:.,_ ..... --..... "* -. ,.... *._ __ . '-

CRP/EGA / 1'1J._ day Sworn to and subscribed before me this NOtar}/PUbliC My commission expires: 1-2-2.0/ ?1

References:

1. Southern Nuclear Operating Company letter, NL-12-1344, dated September 13, 2012, License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines'
2. NEI 06-09-A, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines, November, 2006 3. NRC Letter dated May 16, 2013, Vogtle Electric Generating Plant, Units 1 and 2 (VEGP) Request for Additional Information, (TAG Nos. M£9555 and ME9556) 4. Southern Nuclear Operating Company letter, NL-13-1540, dated August 2, 2013, Vogtle Electric Generating Plant Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines" 5. NRC Letter dated June 9, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Request for Additional Information (TAG Nos. ME9555 and ME9556) 6. NRC Letter dated June 25, 2014, Vogtle Electric Generating Plant, Units 1 and 2 -Corrected-Request for Additional Information, (T AC Nos. ME9555 and ME 9556)
-.; -. : *,:
  • d *** , * *** .: *.*; 1 .*.' *: _ .... *. ; .... .. * . . *'::,*_ . .. * .*.*" .!*,
  • .-: '*i. *'(* .-:**.*.*
  • -. **.*.' *,._* **. ....... ,': . ;. .L* ****.: *, *, .. *.;= . ... *'

-." .... .. *,.,, .:i. . .. . .,., ,., . . , ,. '*-<, i_ .**

  • U. S. Nuclear Regulatory Commission NL-14-1703 Page 3 7. Southern Nuclear Operating Company letter, NL-14-1016, dated July 17, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines" 8. NRC Letter dated October 14, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Request for Additional Information (TAG Nos. ME9555 and ME9556) 9. NRC Letter dated April 24, 2013, Vogtle Electric Generating Plant, Units 1 and 2, Issuance of Amendments Regarding Adoption of TSTF-439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" (TAG Nos. ME9470 and ME9471)

Enclosures:

1. Response to Nuclear Regulatory Commission Questions
2. Revised Applicable Technical Specifications Limiting Conditions of Operation
3. Revised Technical Specifications Mark-Ups 4. Revised Technical Specifications Clean-Typed Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President

& CEO Mr. D. G. Bast, Executive Vice President

& Chief Nuclear Officer Mr. D. R. Madison, Vice President-Fleet Operations Mr. B. L. lvey, Vice President-Regulatory Affairs Mr. B. K. Taber, Vice President-Vogtle -Vogtle 1 & 2 Mr. B. J. Adams, Vice President-Engineering Mr. G. W. Gunn, Regulatory Affairs Manager (Acting)-Vogtle 1 & 2 RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager-Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector-Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Director-Environmental Protection Division Vogtle Electric Generating Plant Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines"

  • Enclosure 1 Response to Nuclear Regulatory Commission Questions Enclosure 1 to NL-14-1703 Response to NRC Questions NRC Technical Specifications RAI3.1 (follow-up toTS Review RAI3) Per the licensee response (ADAMS Accession No. ML 14198A574) toTS Request for Additional Information (RAJ) 3, "LCOs 3.5.5, 3.7.3 and 3.8.3 will be removed from the [Southern Nuclear Operating Company (SNC) Vogtle Electric Generating Plant (VEGP)] Risk Informed Completion Time Program. The [License Amendment Request (LAR)] will be revised to reflect these changes." Please clarify if both Limiting Condition for Operation (LCO) 3.8.3 Condition A and F will be removed or if only LCO 3.8.3 Condition A will be removed. SNC Response to Question 3.1 Yes, both Limiting Condition for Operation (LCO) 3.8.3 Condition A and F will be removed from the [Southern Nuclear Operating Company (SNC) Vogtle Electric Generating Plant (VEGP)] Risk Informed Completion Time Program. NRC Technical Specifications RAI 5.1 (follow-up to TS Review RAI 5) The response to TS RAJ 5 proposes an addition to TS Administrative Controls, Section 5.5.22. Please clarify whether "loss of functional level [Probabilistic Risk Assessment (PRA)] success criteria" means loss of safety function.

SNC Response to Question 5.1 The phrase referenced above, "loss of functional level PRA success criteria" does not mean loss of safety function.

The SNC addition to Section 5.5.22.f of the Technical Specifications, proposed in the SNC correspondence of July 17, 2014 (Reference

7) states the following:

A RICT entry is not permitted, or a RICT entry 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.

The TS condition being referred to in the above proposed addition is one in which the TS safety function has been lost, placing the plant in the particular LCO Action statement for a loss of safety function.

Per NEI 06-09, a RICT may be used for a condition involving a loss of safety function, or an inoperability of all required trains, provided one or more of the trains can be considered "PRA Functional." This provision was proposed as an addition to Section 5.5. of the Vogtle TS, "Programs and Manuals", in the original Vogtle Licensing Amendment Request of September 13, 2012, (Reference 1). The proposed addition was made in accordance with TSTF-505 and NEI 06-09. E1-1 Enclosure 1 to NL-14-1703 Response to NRC Questions So, when the Control Room staff discovers a loss of safety function, the appropriate LCO Action statement is entered. At this point, the ability to enter a RICT will depend upon one or more of the trains being "PRA Functional".

Additionally, per the proposed section, 5.5.22.f, it will also depend on being able to restore the LCO, i.e., repair the system, while maintaining at least one train "PRA Functional". "Loss of functional level PRA success criteria," therefore, cannot mean loss of safety function, as the loss of safety function has already occurred.

In essence, the plant is in the LCO Action statement by the definition of a loss of safety function.

Accordingly, "loss of functional level PRA success criteria" means "loss of PRA Functionality." It does not mean "loss of safety function." NRC PRA RAI 2.1 (follow-up to PRA Review RAI 2) The response to PRA RAI 2 noted a response to RAI 27 for the Vogtle 10 CFR 50.69 application (ADAMS Accession No. ML 13184A267).

The NRC staff reviewed that response and noted methodologies potentially important for the Vogtle Initiative 4b application.

The methodology for Main Control Room (MCR) abandonment fire scenarios uses a Conditional Core Damage Probability (CCDP) of 1.0 according to the response to RAI 27 for the Vogtle 10 CFR 50.69 application.

As such, a CCDP of 1.0 does not result in any delta risk if equipment relied upon for these scenarios are not available.

Please explain why this method may be acceptable for the Initiative 4b application, or describe how this observation will be addressed such that the methodology is capable of evaluating the risk of equipment out of service which affects the MCR abandonment fire scenario CCDP in order to include the associated risk in the RICT calculation.

Please propose an implementation item which addresses this methodology for the Fire PRA application in the RICT program. SNC Response to Question 2.1 For the MCR abandonment scenarios, full room damage is assumed. The scope of cable failures in the MCR results in a quantified CCDP of 1.0. Recovery from outside the MCR is not quantified.

While alternate shutdown capability (ASC) would provide potential for recovery outside the MCR, there is the potential that some relied upon equipment may not be available for the required function given the potential for spurious operation prior to establishing ASC. Typical ASC calculations are dominated by human error events related to actions taken outside the MCR and not equipment failures or maintenance outages. Therefore, a more rigorous evaluation of ASC would not provide any additional insights or risk reduction which would be of significant impact to configuration risk calculations to support RMTS. E1-2 Enclosure 1 to NL-14-1703 Response to NRC Questions NRC PRA RAI10.1 (follow-up to PRA Review RAI10) The NRC Safety Evaluation (SE) (ADAMS Accession No. ML071200238) for Topical Report (TR) Nuclear Energy Institute (NEI) 06-09 (ADAMS Accession No. ML 12286A321) discusses common cause failures (CCFs), on page 6 it states: Emergent Failures.

During the time when an RICT is in effect and risk is being assessed and managed, it is possible that emergent failures of SSCs may occur, and these must be assessed to determine the impact on the RICT. If a failed component is one of two or more redundant components in separate trains of a system, then there is potential for a common cause failure mechanism.

Licensees must continue to assess the remaining redundant components to determine there is reasonable assurance of their continued operability, and this is not changed by implementation of the RMTS. If a licensee concludes that the redundant components remain operable, then these components are functional for purposes of the RICT. However, the licensee is required to consider and implement additional risk management actions (RMAs), due to the potential for increased risks from common cause failure of similar equipment.

The staff interprets TR NEI 06-09, Revision 0, as requiring consideration of such RMAs whenever the redundant components are considered to remain operable, but the licensee has not completed the extent of condition evaluations, and additionally, as required by a followup prompt operability determination.

Pages 9 and 10 of the SE state: TR NEI 06-09, Revision 0, uses both the [core damage frequency (CDF) and Large Early Release Frequency (LERF)] metrics to assess and establish

[TS LCO Completion Times (CTs)], which addresses maintaining a balance between core damage prevention and containment failure prevention.

Compliance with the guidance of [Regulatory Guide (RG)] 1.17 4, Revision 1, and RG 1.177 for and is achieved by evaluation using a comprehensive risk analysis, which assesses the configuration-specific risk by including contributions from human errors and common cause failures.

The use of extended CTs is restricted to conditions which do not involve a total loss of function, which assures preservation of redundancy and diversity.

Both the quantitative risk analysis and the qualitative considerations assure a reasonable balance of defense in depth is maintained to ensure protection of public health and safety, satisfying the second key safety principle of RG 1.177. RG 1.177, Revision 1, provides guidance on the treatment of CCF for risk-informed TSs on page 15: The CCF contributions should be modeled so that they can be modified to reflect the condition in which one or more of the components is unavailable.

It should be noted, however, that CCF modeling of components is not only dependent on the number of remaining inservice components, but is also dependent on the E1-3 Enclosure 1 to NL-14-1703 Response to NRC Questions reason components were removed from service (i.e., whether for preventive or corrective maintenance).

For appropriate configuration risk management and control, preventive and corrective maintenance activities need to be considered, and licensees should, therefore, have the ability to address the subtle difference that exists between maintenance activities (see Section A-1.3.2 of Appendix A to this guide for details).

Further guidance is provided in RG 1.177, Revision 1, Appendix A, page A-3: Contributions from common-cause failures (CCFs) need special attention when calculating the increased risk level R 1. If the component is down because of a failure, the common-cause contributions involving the component should be divided by the probability of the component being down because of failure since the component is given to be down. If the component is down because it is being brought down for maintenance, the CCF contributions involving the component should be modified to remove the component and to only include failures of the remaining components (also see Regulatory Position 2.3.1, of Regulatory Guide 1.177). Additional guidance is given in RG 1.177, Sections A-1.3.2.1 and A-1.3.2.2, regarding the treatment of CCFs for a component failed or in preventive maintenance.

Please address the following two parts with respect to CCF treatment for the RICT program: a. The RAI response notes the guidance in NEI 06-09, Section 3.3.6: "For all RICT assessments of planned configuration, the treatment of common cause failure in the quantitative

[Configuration Risk Management (CRM)] Tools may be performed by considering only the removal of the planned equipment and not adjusting common cause failure terms." The NRC staff notes that page 14 of theSE for NEI 06-09 states: "As part of its review and approval of a licensee's application requesting to implement the RMTS, the NRC staff intends to impose a license condition that will explicitly address the scope of the PRA and non-PRA methods approved by the NRC staff for use in the plant-specific RMTS program." The NRC staff considers that the RMTS PRA method for CCF should be consistent with the RG 1.177 treatment of CCF, as described above. Please provide assurance that RICT calculations will be consistent with RG 1.177 guidance for CCF treatment.

b. Secondly, with respect to the response which describes outcomes from an "extent of condition" evaluation, explain how "Outcome 3," which does not consider RMAs, is consistent with NEI 06-09 guidance which appears to apply when the "extent of condition" is incomplete rather than completed with redundant equipment found to be TS-inoperable.

E1-4 Enclosure 1 to NL-14-1703 Response to NRC Questions SNC Response to NRC PRA Question 10.1 (a) The noted sentence on page 14 of theSE for NEI 06-09 , Rev.O-A , regarding the imposition of a license condition on the scope of PRA and non-PRA methods used for the plant-specific RMTS comes from the safety evaluation discussion in the section entitled "Quality of the PRA." The section discusses the scope of PRA (e.g., internal events , fire PRA , etc.) that the NEI 06-09 , Rev.O-A , guidance permits to be used for the RMTS program i n calculating a risk informed completion time. When taken i nto context with the entire discussion in this section of the safety evaluation , it is a license condition concerning the methods used to address haza r ds that are not in the scope of endorsed standards , RG 1.200 as it existed in 2007 (see f i gure 10.1-1 below for a visual representat i on of how VEGP is complying with this section of theSE). This sentence of theSE was clearly not i ntended to have the NRC staff identify and impose any specific PRA methods , and especially not when those methods conflict with the approved methods of NEI 06-09 , Rev. 0-A. Therefore , the interpretation of this portion of the safety evaluation to apply to CCF calculation methods deviates from the intent of the SE. The discussion below further explains the NRC-approved methodology described in NEI 06-09 , Rev.O-A, and why the guidance presented in NEI 06-09 , Rev.O-A , for the treatment of common cause failures is an appropr i ate alternative to the common cause failure treatment guidance given in RG 1.177. Figure 10.1-1 Int e rna l F i re Se i s mi c Other Externa l Shutd o wn Events R i s k R i s k R i s k Ev e nts R i s k R i s k In te r na l Events F i re Sei sm i c P RA PRA

  • P R A * (I n c l ud es I n te rn al
  • Bounding
  • Updated IPEEE Power F l oo d i ng & S eismi c FIVE Ana l ysis
  • s .
  • L OO P) creenmg On l y SNC agrees that RG 1.177 provides one method , acceptable to the NRC , to address the risk impact on CCFs when equipment is removed from service. The adjustment of CCF factors assumes no additional knowledge of the failure mode and represents a bounding probability given that a failure of one component has occurred. Such calculations are appropriate to support proposed changes to Technical Specification complet i on times which do not provide any compensatory measures or restrictions on the use of the completion time. This permits a license amendment request to implement a specific change to a completion time to demonstrate that the risk level remains acceptable to support the proposed change under any conditions. As noted on page 12 of RG 1.177 , the regulatory positions in Appendix A apply only to Tier 1 , which requires the licensee to assess proposed TS changes and identify the impact of the changes on plant r isk. Appendix A does not apply to Tier 3 , which is the risk-informed configurat i on r i sk management.

The Tier 1 calculations are performed to support a license amendment request to support approval of the proposed TS changes wh i le the Tier 3 E1-5 Enclosure 1 to NL-14-1703 Response to NRC Questions calculations are performed in real-time to support the actual use of the TS. RG 1.177 Appendix A is not applied to these real-time calculations of risk, as per page 12 of RG 1. 177. The RMTS process is an adaptation of the configuration risk management process used for Tier 3 in RG 1.177 for the calculation of completion times. Appendix A would not apply to the calculations to support configuration risk assessments just as it does not apply to Tier 3 configuration risk calculations for non-RMTS TS. For RMTS, application-specific guidance in NEI 06-09, Rev. 0-A, approved by the NRC for use to support plant-specific implementation of RMTS, provides an acceptable method to manage the risk impact of potential CCF vulnerability when equipment is removed from service. The method, clearly described in NEI 06-09 Section 2.3.1, paragraph 15, and Section 3.3.6, requires 1) a prompt operability assessment (i.e., extent of condition) on the remaining redundant components to determine if they are impacted by the failure mechanism, and 2) until such an assessment is completed, the redundant components are assumed to be impacted by the failure mechanism and risk management actions (RMAs) are required to be put in place to manage risk. The NRC-approved guidance further clearly states that quantitative changes to the PRA are not required.

In its safety evaluation of NEI 06-09, Rev. 0-A, the NRC did not take any exception to the guidance regarding CCF, other than to clarify its interpretation that RMAs are required while the extent of condition assessment is in progress and not yet completed.

SNC procedures that implement the "extent of condition" review are consistent with RIS 2005-020 and NRC Inspection Manual Part 9900, which is also consistent with NEI 06-09, Rev.O-A, guidance.

According to SNC plant procedures, if a SSC provides a Specified Safety Function(s) and the affected SSC is tagged out, inoperable, or not required to be operable based on plant conditions, an "extent of condition" review is performed to determine if similar degradation may be present on other similar components, trains, systems or units. A condition report is initiated in which the Immediate Determination of Operability (I DO) will address continued operability of the degraded SSC identified in that review. The result of that review is documented in the condition reporting software with rationale why the condition is isolated to the affected sse or if other SSCs are affected, including resulting Condition Report (CR) numbers as appropriate.

The IDO will document the extent of condition for SSCs known to be affected by entry conditions.

This review may involve walkdowns, component testing and inspections, or other operability assessments based on the specific situation.

A checklist provides additional guidance on determining if a degraded condition exists. For preventive maintenance, no adjustment of CCF probabilities is required since the intentional out-of-service status of one piece of equipment cannot physically alter the status of other equipment and change its CCF probability.

Again, NEI 06-09, Rev. 0-A, specifically states that no CCF adjustment is required for preventive maintenance (section 3.3.6). SNC maintains that the NRC-approved guidance in NEI 06-09, Rev. 0-A, for addressing the impact of emergent equipment failures on potential CCF mechanisms is the appropriate method to be used in RMTS. Adjustments to CCF probabilities, as described in RG 1.177, is not required, and it is a deviation from the approved method in NE 06-09, Rev. 0-A, that requires prompt assessment of the CCF potential and uses RMAs to manage the uncertainty in risk while this assessment is conducted.

E1-6 Enclosure 1 to NL-14-1703 Response to NRC Questions SNC Response to Question 10.1 (b) Outcome 3 identified the situation where the "extent of condition" evaluation is completed and the redundant components are inoperable due to a common cause impact. If the inoperability of all redundant components resulted in a loss of the LCO function, then the RICT Program would not be permitted to be entered, or if in effect would be exited. Therefore, RMAs would not be required since the RICT Program would not be in effect. If the loss of all redundant components did not result in a total loss of the LCO function (e.g., one train of redundant components is PRA Functional in a two train system), then the RICT would have to be based on the failed status of the redundant components (e.g., emergent redundant components are PRA Functional in a two train system). Since the "extent of condition" is completed, and the components are inoperable, additional RMAs to address common cause concern are not applicable.

This is consistent with the NEI 06-09, Rev.O-A, guidance which applies only while the redundant components are operable and the extent of condition is incomplete, consistent with the NRC safety evaluation.

It should be noted that independent of the potential for common cause, when in a RICT, RMAs are always implemented before a plant configuration exceeds an ICDP/ILERP of 1 E-06/1 E-07. NRC PRA RAI11.1 (Follow-up to PRA Review RAI11) Please expand on the response to Part (b)(ii) regarding inclusion of TS LCO 3.6.2 Containment Air Locks in the RICT program. The response does not clarify if there is no expected impact on CDF (page E1-20), and, why LERF considerations do not exclude the TS LCO 3.6.2 from the RICT program (page E1-32). The response indicates that PRA functionality could result in "a longer RICT forTS inoperable conditions." For the LERF assessment provided in the LAR Table E1-3, please explain how PRA functionality could result in an increase in the CT if the function cannot be achieved by TS operability considerations.

For the containment air lock function, is its function evaluated differently for a PRA functionality determination than for a design basis evaluation?

SNC Response to Question 11.1 The risk impact of an open or not fully closed containment airlock is considered in the RICT calculation.

The LERF logic in the Vogtle PRA model used for RICT calculations has a basic event for "Administratively controlled penetrations not isolated," which represents the status of the containment airlocks.

There is no CDF impact modeled for an open airlock in the Vogtle PRA. The equipment tag numbers for the personnel airlock, escape airlock, and the equipment hatch, along with LCO 3.6.2.C, are mapped to the containment isolation failure basic event in EOOS. Selecting either of these tag numbers or LCO 3.6.2.C to remove it from service in EOOS, reflecting an open airlock, results in a direct impact on LERF. Removal of any airlock from service in EOOS produces a RICT based solely on LERF, which is less than the 1 day front-stop.

E1-7 Enclosure 1 to NL-14-1703 Response to NRC Questions Therefore, PRA Functionality and the Design Basis (Tech Spec) Safety Function of limiting containment leakage rates are evaluated similarly in that the airlock must be closed. However, an airlock could be determined PRA functional if it is TS inoperable as a result of a condition other than an inoperable door or interlock and the door on the affected airlock is confirmed closed. It would not be PRA functional if the airlock is TS inoperable and an airlock door is open. Therefore, if it is determined an airlock is PRA functional, there would be no impact on LEAF and the back stop would apply. NRC PRA RAI 13.1 (Follow-up to PRA Review RAI 13) Since the TS LCOs may require evaluation of success criteria at different levels, documentation of success criteria should support the level needed (e.g., system level, train level, etc.). Review of the response appears to show documentation of system-level success criteria only, and not train-level success criteria, or lower level if necessary, for a RICT program evaluation of success criteria.

For example, in response to PRA Review RAI 6, 1 of 3 Auxiliary Feedwater (AFW) pumps provides flow to 2 of 4 steam generators; however, in some applications of the RICT program it may be necessary to know the success criteria of one train of AFW (e.g. turbine-driven AFW) rather than the system-level success criteria.

Please explain whether success criteria at different levels other than the system level are documented for use in RICT program evaluations.

SNC Response to Question 13.1 When applicable, the success criteria at different levels other than the system level are documented for use in RICT program evaluations.

NRC PRA RAI 16.1 (Follow-up PRA Review RAI16) The response to this RAI considers that, upon calculating a new RICT given the emergent condition, the 1 E-5 incremental core damage probability (I COP) and the 1 E-6 incremental large early release probability (I LEAP) are applicable and implies that the plant configuration could be maintained until these RICT program limits are reached. NEI 06-09 guidance (page 2-6) notes that the plant shall implement appropriate risk management actions to limit the extent and duration of the high risk configuration.

The NRC staff notes the NEI 06-09 guidance is to limit the extent and duration of the condition rather than to remain in the condition until reaching the above limits. Please explain if your RICT program considers returning equipment to service which provides a quantitative measure of risk decrease, as well as RMAs which may not be quantified, to decrease risk prior to reaching the ICDP/ILERP limits qf 1 E-5/1 E-6 for an emergent plant condition.

E1-8 Enclosure 1 to NL-14-1703 Response to NRC Questions SNC Response to Question 16.1 The 1 E-5 ICDP and 1 E-6 ILERP are the basis for the RICT in RMTS. The 1 E-3/year CDF and 1 E-4/year LERF are the basis for a "high-risk configuration." The voluntary use of the RICT Program for a high-risk configuration is not permitted by NEI 06-09. However, if a high-risk configuration occurs due to an emergent condition while a RICT is already in effect, NEI 06-09 permits continuation of the RICT Program and requires the use of RMAs to address the risk configuration.

The Vogtle RICT Program will include consideration of return-to-service of equipment whenever possible, as well as other RMAs, depending upon the specific nature of the high-risk configuration, which is consistent with the guidance of NEI 06-09. NRC PRA RAI17.1 (Follow-up to PRA Review RAI17) a. The response to the RAI cites a quote from the NRC SE for the requirements of Tier 2; which references NUMARC 93-01 as endorsed by RG 1.182. These references have been updated such that the latest guidance is NUMARC 93-01, Revision 4, as endorsed by RG 1.160. Please confirm these updated references are applicable for your RICT program Tier 2 requirements.

b. As described in RG 1.177, Revision 1, on pages 11 and 12: Tier 2 is an identification of potentially high-risk configurations that could exist if equipment, in addition to that associated with the change, were to be taken out of service simultaneously or other risk-significant operational factors, such as concurrent system or equipment testing, were also involved.

The objective of this part of the evaluation is to ensure that appropriate restrictions on dominant risk-significant configurations associated with the change are in place ... Once plant equipment is so evaluated, an assessment can be made as whether certain enhancements to the TS or procedures are needed to avoid risk significant plant configurations.

In addition, compensatory actions that can mitigate any corresponding increase in risk (e.g., backup equipment, increased surveillance frequency, or upgraded procedures and training) should be identified and evaluated.

i. The response indicates that the 1E-6/1E-71CDP/ILERP RMTS thresholds are the triggers for RMA implementation.

Please provide clarification on this response since this appears to be different from the guidance in NEI 06-09 for risk management action times (RMATs) which states on page A-5: "This guidance requires risk management actions to be taken no later than the calculated RMAT." E1-9 Enclosure 1 to NL-14-1703 Response to NRC Questions ii. Also, discuss the Tier 2 assessment process to accomplish Tier 2 objectives, and discuss the timeline to perform the Tier 2 assessment (e.g., with respect to the TS front stop, the RMA thresholds).

SNC Response to Question 17.1(a) A conclusion was made by the NRC in the NEI 06-09 SE that the limits established for entry into a RICT and for RMA implementation are consistent with the guidance of NUMARC 93-01 endorsed by RG 1.182 as applicable to plant maintenance activities for meeting the principle of Tier 2 to avoid risk-significant configurations.

The limits established for entry into a RICT and for RMA implementation do not conflict with the updated version of NUMARC 93-01, Revision 4, as endorsed by RG 1.160. SNC Response to Question 17.1(b)(i)

The Vogtle RICT Program is consistent with NEI 06-09 guidance with regards to the use of RMAs. When the configuration risk exceeds or is expected to exceed the RMAT, RMAs are considered and implemented at the earliest appropriate time, not to exceed the RMAT. If a high-risk configuration occurs due to an emergent condition, RMAs are similarly implemented as required by NEI 06-09. SNC Response to Question 17.1(b)(iil For pre-planned uses of the RICT Program, assessments are made for equipment which could result in a potentially risk significant configuration (above 1 E-6 ICDP or 1 E-7 ILERP) if removed from service and appropriate scheduling of such maintenance activities is made to preclude such configurations or implement RMAs. RMAs applicable to pre-planned or emergent RICT Program use will include consideration of equipment that should be protected and not removed from service as to avoid potentially risk significant configurations.

The RICT Program, using the CRMP Tool, calculates in real-time the RICT based on the actual configuration (including any changes which occur while the RICT is in effect) such that high risk configurations are promptly identified and managed consistent with the requirements of NEI 06-09, Rev. 0-A. High risk configurations (above 1 E-3 CDF or 1 E-4 LERF) are not permitted to be voluntarily entered using a RICT. This approach is presented in NEI 06-09, Rev. 0-A, and is consistent with the principle of Tier 2 of RG 1.177 to avoid risk-significant configurations, as specifically stated by the NRC in the NEI 06-09, Rev. 0-A, safety evaluation.

NRC PRA RAI23: TS 3.7.4 Atmospheric Relief Valves (ARVs) The RICT program in TS 5.5.22 and NEI 06-09, Revision 0, does not permit 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.

TS Conditions, which represent a loss of specified safety function have been modified by a note stating it is not applicable when the second [train] is intentionally made inoperable.

However, TS 3.7.4 Condition 8 did not add a note stating that it is not applicable when the third ARV line is intentionally made inoperable.

E1-10 Enclosure 1 to NL-14-1703 Response to NRC Questions Entering TS 3.7.4 Condition B intentionally due to three (or more) inoperable ARVs would not be allowed by TS Section 5.5.22 or NEI 06-09, Revision 0-A. Please explain how this will be prevented from occurring or provide a revision that adds the Condition note toTS 3.7.4 Condition B. SNC Response to Question 23 This loss of function condition will be treated the same as the loss of function conditions discussed in SNC's letter to the NRC dated August 2, 2013. A note will be added to indicating that voluntary entry is prohibited.

Enclosure 3 to this letter contains the revised LCOs discussed in the August 21etter as well as LCO 3.7.4 Condition B. NRC PRA RAI 24: Proposed License Changes for TS Administrative Controls Section 5.5.22 The NRC staff's review of the proposed license TS Section 5.5.22 in the LAR determined clarification was necessary for part c(3); Part c(3) states "Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT." This guidance, however, could result in a mismatch between the risk management actions (RMAs) and the plant configuration.

This is because the configuration risk management tool used to calculate the RICT is also used to help identify RMAs; therefore, when the plant configuration changes a new RICT would be calculated to identify RMAs which correspond to the new plant configuration.

Please provide clarification of part c(3) in the TS Bases to ensure that the RMAs match the current plant configuration.

SNC Response to Question 24 There is no Administrative Controls section in the TS Bases. Therefore, there is no place in the TS Bases to clarify section 5.5.22 of the TS. Consequently, clarifying guidance will be placed in plant procedures.

TS Section 5.5.22 was proposed by SNC in accordance with TSTF-505 with no deviation.

The quote presented above from Part c(3) of Section 5.5.22 was developed from NEI 06-09, Rev. 0-A guidance.

The purpose of the statement is to allow operators to remain in a RICT that is more conservative than allowed by the current plant configuration if they deem it necessary or desirable.

The operators could conceivably be in a situation that requires attention and is more pressing than increasing the RICT. Consequently, working through the procedures to revise the RICT could unnecessarily distract them from operating the plant safety. On the other hand, re-calculating the RICT may be prudent if, in the specific situation, it would not interfere with safe plant operation.

Remaining in the initial RICT would cause the faster accumulation of risk, which would in turn result in approaching the RG 1.17 4 risk limits sooner. Additionally, since the configuration risk management tool is, as the question points out, used to help identify RMAs, it may be advantageous to recover any resources used to implement those RMAs which may no longer be necessary.

From these points of view, it would be beneficial for E1-11 Enclosure 1 to NL-14-1703 Response to NRC Questions the site to modify the plant configuration logged in the configuration risk management tool and re-calculate the RICT, thus adjusting the risk worth of components listed in the configuration risk management tool as well as potentially releasing any resources being used for the RMAs. Also, since RMAs are not credited in the calculation of CDF and LERF, the return of an safety plant component to service will always results in a lower risk configuration, regardless of whether or not there may be an RMA or RMAs more consistent with the new configuration.

Therefore, because they are in the best position to determine the course of action for the plant, SNC chooses to allow the Control Room/Operations staff to determine when and if they choose to re-calculate the RICT. As previously mentioned, remaining in the initially calculated RICT is conservative with respect to plant risk and safety, as well as being completely consistent with TSTF-505 and NEI 06-09. Nonetheless, SNC will modify procedures to include guidance indicating that, if the plant configuration changes in such a manner as to lower risk, strong consideration should be given to calculating a revised RICT for the reasons given above. However, the procedure guidance will also point out that precedence should always be given to safe plant operation.

NRC PRA RAI 25: RICT Program Implementation Items Please provide implementation items to address for the following issues before implementation of the RICT program. 1. The LAR has identified items to be completed before using the RICT program: i. The LAR Table E 1.1 in Enclosure 1 to the LAR identifies that the disposition for TS LCO 3. 7.5 Condition A will be completed before application of the RICT program. ii. The LAR Table E2.2 in Enclosure 2 identifies F&Os that will be resolved prior to the implementation of the RICT program. 2. Draft plant procedures which are necessary for implementing the RICT program should be completed prior to implementation.

3. Propose an implementation item which updates the Fire PRA model to include guidance in NUREG/CR-7150," .Joint Assessment of Cable Damage and Quantification of Effects from Fire (JACQUE FIRE)," Volume 2, which is supported by a letter from the NRC to NEI, "Supplemental Interim Technical Guidance on Fire-induced Circuit Failure Mode Likelihood Analysis," (ADAMS Accession Nos. ML 14086A165 and ML 14017A135).

E1-12 Enclosure 1 to NL-14-1703 Response to NRC Questions

4. The NRC staff considered the use of the term "should" versus "shall" in NEI 06-09 for its importance to the RICT program since it is proposed to be incorporated into the TS Administrative Controls Section 5.5.22. The NRC staff has identified that the following "should" statements should be replaced with "shall." Please propose an implementation item that addresses the use of "shall" in place of "should" for the following NEI 06-09 guidance in the table below. NEI 06-09: Implementation of "Shall" versus "Should" Page 3-10 "Since the condition has been judged to warrant declaring a pump inoperable, it shoi:Jiel shall not be simultaneously considered PRA functional for the RICT calculations." ' Page 3-17 "Should preventive maintenance activities be anticipated to exceed the RMA T thresholds, appropriate RMAs shoi:Jiel shall be identified and, as appropriate, implemented before the condition is entered." Page 3-18 "To accomplish this goal, the* impact of RMTS implementation on the baseline risk metrics shoi:Jiel shall be periodically assessed and managed as appropriate to ensure there is no undue increase." E1-13 Enclosure 1 to NL-14-1703 Response to NRC Questions NEI 06-09: Implementation of "Shall" versus "Should" Page 3-19. 3-20. and 3-21 "This administrative process for cumulative risk management sho1:1lel shall include a requirement to document specific corrective actions and, if necessary, for ensuring operation remains within Regions II or Ill of Figures 3 and 4 of NRC Regulatory Guide 1.174 [4]." "The RMTS program implementing procedure sho1:1lel shall clearly describe how cumulative risk tracking and associated "triggers" for self-assessment and corrective action will be implemented within the station-specific RMTS program." "Regardless of the method used, the station must track the risk associated with all entries beyond the front-stop CT. This information sho1:1lel shall be evaluated periodically against the guidance of Regulatory Guide 1.17 4." "For stations without external events PRAs incorporated into their quantitative CRM Tools, or in cases where the existing external event PRA does not adequately address the situation, the station sho1:1lel shall apply the following criteria to support maintenance activities beyond the stop CT: 1. Provide a reasonable technical argument (to be documented prior to the implementation of the associated RICT) that the configuration risk of interest is dominated by internal events, and that external events, including internal fires, are not a significant contributor to configuration risk (i.e., they are not significant relative to a RICT calculation).

OR 2. Perform a reasonable bounding analysis of the external events, including internal fires, configuration risk (to be documented prior to the implementation of the associated RICT) and apply this upper bound external events risk contribution along with the internal events risk contribution in calculating the configuration risk and the associated RICT. OR 3. For limited scope RMTS applications, a licensee may use pre-analyzed external events internal fire analyses to restrict RMA thresholds and identify and implement compensatory risk management actions. For the duration of the configuration of interest, these actions should be supported by analyses and provide a reasonable technical argument (to be documented prior to the implementation of the associated RICT) that external events, including internal fires, are adequately controlled so as to be an insignificant contributor to the incremental configuration risk. Any RMAs credited in this manner shall be proceduralized and appropriate training provided." E1-14 Enclosure 1 to NL-14-1703 Response to NRC Questions NEI 06-09: Implementation of "Shall" versus "Should" Page 3-22 "In addition to a determination of operability on the affected component, the operator st:le1:11Ei shall make a judgment with regard to whether the operability of similar or redundant components might be affected." Page4-3 "In cases where the CRM tool directly performs PRA logic model reduction and/or risk calculations, quality assurance checks of the model and quantification results translation from the underlying approved PRA st:le1:11Ei shall be performed to validate model translation." "Training of personnel who apply or review the CRM tool st:le1:11Ei shall be performed." Page 4-4 "CRM tools st:le1:11Ei shall reflect as-built, as-operated plant conditions." SNC Response to Question 25 Items 1, 2. and 3 The items shown in the table below are noted as License Conditions and shall be completed prior to implementation of the RICT program. Description Source 1 The LAR Table E1.1 in Enclosure 1 to the LAR identifies that the LAR Open Item Q25(1)i disposition forTS LCO 3.7.5 Condition A will be completed before application of the RICT program 2 SNC shall ensure that all F&Os shown in Table E2.2 in LAR Open Item Q25(1 )ii Enclosure 2 of the LAR will be resolved prior to the implementation of the RICT program. 3 Draft plant procedures which are necessary for implementing LAR Open Item Q25(2) the RICT program shall be completed prior to implementation.

4 Propose an implementation item which updates the Fire PRA LAR Open Item Q25(3) model to include guidance in NUREG/CR-7150," Joint [Same as Assessment of Cable Damage and Quantification of Effects from Implementation Item 4 Fire (JACQUE FIRE)," Volume 2, which is supported by a letter in SNC letter NL-14-from the NRC to NEI, "Supplemental Interim Technical 0960, dated 07/22/14]

Guidance on Fire-induced Circuit Failure Mode Likelihood Analysis," (ADAMS Accession Nos. ML 14086A165 and ML 14017A135).

E1-15 Enclosure 1 to NL-14-1703 Response to NRC Questions SNC Response to Question 25 Item 4 SNC has reviewed each instance of the use of "should" instead of "shall" identified by the RAJ, and does not take any exception.

However, SNC does not believe that an implementation item is necessary because other portions of NEI 06-09 Rev. 0-A already provide the appropriate "shall" requirement.

Since NEI 06-09 Rev. 0-A already includes appropriate requirements with "shall" or equivalent term for each of the items addressed by the NRC, and since the Vogtle RICT Program is required by TS 5.5.22 to conform to NEI 06-09 Rev. 0-A, no implementation item is considered necessary to ensure the requirements are met. The following provides a specific review and disposition of each of the items identified by the NRC:

  • Page 3-10: "A pump is declared inoperable due to increasing bearing temperatures.

Although the temperature of the bearing is not immediately impacting on the pump success criteria (i.e., pump flow), the basis for declaring it inoperable is the anticipated degradation and loss of function.

Since the condition has been judged to warrant declaring a pump inoperable, it sheYiel shall not be simultaneously considered PRA functional for the RICT calculations." This paragraph is a specific example of implementation of a PRA Functionality assessment based on the requirements found in Section 2.3.1, Paragraph 11.1 of NEI 06-09. The example does not identify any program requirements, and is only applicable to the specific example being discussed.

Changing "should" to "shall" does not alter any aspect of the Vogtle RICT Program, which implements PRA Functionality assessments consistent with Section 2.3.1, Paragraph 11.1 of NEI 06-09.

  • Page 3-17: "Should preventive maintenance activities be anticipated to exceed the RMAT thresholds, appropriate RMAs sheYiel shall be identified and, as appropriate, implemented before the condition is entered." This paragraph is at the end of Section 3.2.4 in NEI 06-09 entitled "Examples Demonstrating Application of RMA T and RICT in RMTS Programs." This section has extensive examples showing how configuration risk varies when changes to the plant configuration occur, and how the risk thresholds applicable to RMTS are evaluated.

It identifies that if the RMAT thresholds are anticipated to be exceeded, then appropriate RMAs are put in place before entering the planned configuration for preventive maintenance.

This example implements Section 2.3.1, Paragraph 3 of NEI 06-09, which states in part: "For preplanned maintenance activities for which a RICT will be entered, RMAs shall be implemented at the earliest appropriate time." The example does not identify any program requirements, and changing "should" to "shall" does not alter any aspect of the Vogtle RICT Program, which implements RMAs for pre-planned activities consistent with Section 2.3.1, Paragraph 3 of NEI 06-09. E1-16 Enclosure 1 to NL-14-1703 Response to NRC Questions

  • Page 3-18: "One overall objective of RMTS is to provide plant configuration control consistent with Regulatory Guide 1.174 over long periods of implementation.

The purpose of this tracking is to demonstrate the risk accumulated as a result of SSC inoperability beyond the front-stop CT is appropriately managed. To accomplish this goal, the impact of RMTS implementation on the baseline risk metrics shall be periodically assessed and managed as appropriate to ensure there is no undue increase." This paragraph is the opening paragraph of Section 3.3, "Cumulative Risk Tracking." It introduces the basis for assessing the overall risk impact of using RMTS, and later provides examples of methods which may be used to implement this program requirement.

The requirement for assessing cumulative risk is found in Section 2.3.1, Paragraph 14, which states: "The as-occurred cumulative risk associated with the use of RMTS beyond the front-stop CT for equipment out of service shall be assessed and compared to the guidelines for small risk changes in Regulatory Guide 1.17 4 [4] and corrective actions applied as appropriate.

This assessment shall be conducted every refueling cycle on a periodicity not to exceed 24 months." Section 3.3, as implementation guidance, does not identify any unique program requirement, and the requirement for periodic risk assessment in Section 2.3.2, Paragraph

7.1 appropriately

uses "shall". Therefore, Section 3.3 as written does not alter any aspect of the Vogtle RICT Program, which implements periodic risk assessment and management consistent with Section 2.3.1, Paragraph 14 of NEI 06-09.

  • Page 3-19: "This administrative process for cumulative risk management shall include a requirement to document specific corrective actions and, if necessary, for ensuring operation remains within Regions II or Ill of Figures 3 and 4 of NRC Regulatory Guide 1.17 4 [4]. The RMTS program implementing procedure shall clearly describe how cumulative risk tracking and associated "triggers" for self-assessment and corrective action will be implemented within the station-specific RMTS program. Regardless of the method used, the station must track the risk associated with all entries beyond the front-stop CT. This information lEI shall be evaluated periodically against the guidance of Regulatory Guide 1.174." This excerpt is from Section 3.3, "Cumulative Risk Tracking." As noted above, the program requirement for assessing cumulative risk, comparing to RG 1.17 4 guidelines, and implementing necessary corrective actions, is already identified in Section 2.3.1, Paragraph 14 as a "shall" requirement.

Section 3.3, as implementation guidance, does not identify any unique program requirement.

Therefore, Section 3.3 as written does not alter any aspect of the Vogtle RICT Program, which implements periodic risk assessment and management consistent with Section 2.3.1, Paragraph 14 of NEI 06-09.

  • Page 3-20 and 3-21: "For stations without external events PRAs incorporated into their quantitative CRM Tools, or in cases where the existing external event PRA does not E1-17 Enclosure 1 to NL-14-1703 Response to NRC Questions adequately address the situation, the station should shall apply the following criteria to support maintenance activities beyond the front-stop CT: 1. Provide a reasonable technical argument (to be documented prior to the implementation of the associated RICT) that the configuration risk of interest is dominated by internal events, and that external events, including internal fires, are not a significant contributor to configuration risk (i.e., they are not significant relative to a RICT calculation).

OR 2. Perform a reasonable bounding analysis of the external events, including internal fires, configuration risk (to be documented prior to the implementation of the associated RICT) and apply this upper bound external events risk contribution along with the internal events risk contribution in calculating the configuration risk and the associated RICT. OR 3. For limited scope RMTS applications, a licensee may use pre-analyzed external events internal fire analyses to restrict RMA thresholds and identify and implement compensatory risk management actions. For the duration of the configuration of interest, these actions should be supported by analyses and provide a reasonable technical argument (to be documented prior to the implementation of the associated RICT) that external events, including internal fires, are adequately controlled so as to be an insignificant contributor to the incremental configuration risk. Any RMAs credited in this manner shall be proceduralized and appropriate training provided." The extracted text is from Section 3.3.5 entitled "External Events Consideration." The requirement addressing external hazards to support RICT calculations is identified in Section 2.3.1, Paragraph 7, which states: "The impact of other external events risks shall be addressed in the RMTS program." Further, the three options are again identified and are required to be documented prior to implementation of the RMTS Program. The NRC, in its safety evaluation of NEI 06-09 Rev. 0-A, requires licensees to provide a disposition of how external events are addressed for RMTS in their license amendment request. Section 2.3.1, paragraph 7 identifies acceptable methods for addressing these hazards outside of a plant-specific PRA model. SNC has included in its license amendment request a disposition of external hazards, consistent with the NRC safety evaluation, and the Vogtle RICT Program implementation will be consistent with its submittal once approved by the NRC. The use of "should" in Section 3.3.5 does not alter any aspect of the Vogtle RICT Program, since the license amendment request will govern how the program addresses external hazards consistent with Section 2.3.1, paragraph

7. E1-18 Enclosure 1 to NL-14-1703 Response to NRC Questions
  • Page 3-22: "For RICT assessments involving unplanned or emergent conditions, the potential for common cause failure is considered during the operability determination process. This assessment is more accurately described as an "extent of condition" assessment.

Licensed operators recognize that an emergent condition identified on a Technical Specifications component may have the potential to affect a redundant component or similar components.

In addition to a determination of operability on the affected component, the operator shoulel shall make a judgment with regard to whether the operability of similar or redundant components might be affected." The excerpt is from Section 3.3.6 entitled "Common Cause Failure Consideration." SNC agrees that when an emergent condition has caused inoperability of one of a redundant set of similar SSCs, an extent of condition assessment is required to determine the operability of the redundant components.

Further into Section 3.3.6, this assessment is identified as governed by Part 9900 of the NRC Inspection Manual which identifies such assessments are to be conducted promptly commensurate with the safety significance of the affected component.

Assessing extent of condition for emergent failures is applicable to all plants, not just those proposing to implement RMTS. SNC does not believe that a separate implementation item to consider NEI 06-09 Rev. 0-A as a "shall" is necessary to assure these assessments continue to be performed when RMTS are in effect.

  • Page 4-3: "In cases where the CRM tool directly performs PRA logic model reduction and/or risk calculations, quality assurance checks of the model and quantification results translation from the underlying approved PRA shoulel shall be performed to validate model translation." This sentence appears in Section 4.2, "CRM Tool Attributes".

It is under item #3, which states: "Model translation from the PRA to a separate CRM tool is appropriate; CRM fault trees are traceable to the PRA. Appropriate benchmarking of the CRM tool against the PRA model shall be performed to demonstrate consistency." Section 2.3.5, paragraph 3 also has the same identical wording. SNC agrees that when the CRM tool directly performs PRA logic model reduction and risk calculations, appropriate validation of results is required.

This is governed by 2.3.5, paragraph 3 which requires such benchmarking and uses "shall". Therefore, Section 4.2 as written does not alter any aspect of the Vogtle RICT Program, which implements CRM tool benchmarking consistent with Section 2.3.5, Paragraph 3 of NEI 06-09.

  • Page 4-3: "Training of personnel who apply or review the CRM tool shoulel shall be performed." This sentence is a bullet item in Section 4.2, item 5, which addresses mapping of the systems and components to CRM model parameters.

It is factually stating that the staff performing this task should have necessary training to assure they are capable of E1-19 Enclosure 1 to NL-14-1703 Response to NRC Questions correctly performing this task. SNC agrees that training is a requirement for staff who apply or review the CRM tool. Section 2.3.3 states that operators, work control, and PRA staff shall have training.

It further identifies training on operation of and interpretation of results obtained from the CRM tool. This requirement assures that the appropriate staff members are required to be trained. SNC does not believe a separate implementation item is required to assure training of staff is in place to support RMTS.

  • Page 4-4: "CRM tools should shall reflect as-built, as-operated plant conditions." SNC agrees that CRM tools must reflect as-built, as-operated plant conditions.

Notwithstanding the use of "should" on page 4-4:

  • Section 2.3.1, item 7 states: "The PRA shall be maintained and updated in accordance with approved station procedures to ensure it accurately reflects the built, as-operated plant.
  • Section 2.3.5, item 6 states: "Each CRM application tool is verified to adequately reflect the as-built, as-operated plant, ... "
  • Section 2.3.5, item 9 states: "The CRM tool shall be maintained and updated in accordance with approved station procedures to ensure it accurately reflects the built, as-operated plant."
  • Section 4.2, item 6 states: "Each CRM application tool is verified to adequately reflect the as-built, as-operated plant, ... "
  • Section 4.2, item 9 states: "The CRM tool shall be maintained and updated in accordance with approved station procedures to ensure it accurately reflects the built, as-operated plant." It further states: "CRM applications tools and associated software are verified to reflect the as-built, as-operated plant."
  • The NRC safety evaluation (page 17), included in NEI 06-09, Rev. 0-A, states: "Control of CRMP Assessment Tool. A process must be in place to monitor plant modifications and other changes which may impact the PRA model to assure that the CRMP correctly reflects the as-built, as-operated plant." Further, the safety evaluation requires the license amendment request include submittal of information (page 21): "The LARwill provide a discussion of the licensee's programs and procedures which assure the PRA models which support the RMTS are maintained consistent with the as-built, as-operated plant." Based on the other portions of NEI 06-09, Rev. 0-A which mandate maintaining PRA models and the CRM tool consistent with the as-built, as-operated plant, SNC does not E1-20 Enclosure 1 to NL-14-1703 Response to NRC Questions believe a separate implementation item is required to assure this requirement is satisfied.

E1-21 Vogtle Electric Generating Plant Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines" Enclosure 2 Revised Applicable Technical Specifications Limiting Conditions of Operation Enclosure 2 to NL-14-1703 Revised Applicable Technical Specifications Limiting Conditions of Operation Limiting Condition of Operation (LCO) Required Actions (RAs) that exist in the current Vogtle Electric Generating Plant (VEGP) Technical Specifications (TS) that are modified by the proposed amendment to be included in the RICT Program are identified below. LCO 3.4.10 LCO 3.4.11 LCO 3.5.1 LCO 3.5.2 LCO 3.5.4 LCO 3.6.2 Pressurizer Safety Valves

  • Required Action A.1 -Restore valve to OPERABLE status (Condition A: One pressurizer safety valve inoperable)

Reactor Coolant System (RCS)

  • Required Action C.2 -Restore block valve to OPERABLE status (Condition C: One block valve inoperable)
  • Required Action F.2 -Restore one block valve to OPERABLE status (Condition F: More than one block valve inoperable)
  • Required Action F.3 -Restore remaining block valve to OPERABLE status (Condition F: More than one block valve inoperable)

Accumulators

  • Required Action A.1 -Restore train(s) to OPERABLE status (Condition A: One or more trains inoperable AND At least 1 00% of the ECCS flow equivalent to a single OPERABLE ECCS train available)

Refueling Water Storage Tank (RWST)

  • Required Action A.1 -Restore RWST to OPERABLE status (Condition A: RWST boron concentration not within limits OR RWST borated water temperature not within limits)
  • Required Action B.1 -Restore the valve(s) to OPERABLE status (Condition B: One or more sludge mixing pump isolation valves inoperable)
  • Required Action 0.1 -Restore RWST to OPERABLE status (Condition D: RWST inoperable for reasons other than Condition A or B) Containment Air Locks
  • Required Action C.3 -Restore air lock to OPERABLE status (Condition C: One or more containment air locks inoperable for reasons other than Condition A or B) E2-1 Enclosure 2 to NL-14-1703 Revised Applicable Technical Specifications Limiting Conditions of Operation LCO 3.6.3 LCO 3.6.6 LCO 3.7.2 LCO 3.7.4 LCO 3.7.5 LCO 3.7.6 (Unit 1) LCO 3.7.6 (Unit 2) Containment Isolation Valves
  • Required Action A.1 -Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, blind flange, or check valve with flow through the valve secured (Condition A: One or more penetration flow paths with one containment isolation valve inoperable except for purge valve leakage not within limit)
  • Required Action B.1 -Isolate the affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange (Condition B: One or more penetration flow paths with two containment isolation valves inoperable except for purge valve leakage not within limit)
  • Required Action C.1 -Isolate tt)e affected penetration flow path by use of at least one closed and de-activated automatic valve, closed manual valve, or blind flange (Condition C: One or more penetration flow paths with one or more containment purge valves not within purge valve leakage limit) Containment Spray and Cooling Systems
  • Required Action B.1 -Restore containment cooling train to OPERABLE status (Condition B: One containment cooling train inoperable)

Main Steam Isolation Valves (MSIVs)

  • Required Action A.1 -Restore MSIV to OPERABLE status (Condition A: One or more steam line with one MSIV system inoperable in MODE 1)
  • Required Action B.1 -Restore one MSIV system to OPERABLE status in affected steam line (Condition B: One or more steam lines with two MSIV systems inoperable in MODE 1) Atmospheric Relief Valves (ARVs)
  • Required Action B.1 -Restore at least two ARV lines to OPERABLE status (Condition B: Two or more required ARV lines inoperable)

Auxiliary Feedwater (AFW) System

  • Required Action A.1 -Restore steam supply to OPERABLE status (Condition A: One steam supply to turbine driven AFW pump inoperable)
  • Required Action B.1 -Restore AFW train to OPERABLE status (Condition B: One AFW train inoperable for reasons other than Condition A) Condensate Storage Tank (CST)
  • Required Action A.1 -Restore volume(s) to within limit(s) (Condition A: CST volume(s) not within limit(s))

E2-2 Enclosure 2 to NL-14-1703 Revised Applicable Technical Specifications Limiting Conditions of Operation LCO 3.7.7 LCO 3.7.8 LCO 3.7.9 LCO 3.7.14 LCO 3.8.1 LCO 3.8.4 Component Cooling Water (CCW) System

Nuclear Service Cooling Water (NSCW) System

  • Required Action B.1 -Restore fan to OPERABLE status (Condition B: One NSCW cooling tower with one required fan/spray cell inoperable when operating in four fan/spray cell required region of Figure 3.7.9-1)
  • Required Action C.1 -Restore fan(s)/spray cell(s) to OPERABLE status (Condition B: One NSCW cooling tower with one or more required fans/spray cells inoperable for reasons other than Condition B) Engineered Safety Features (ESF) Room Cooler and Safety Related Chiller System
  • Required Action A.1 -Restore the ESF room cooler and safety-related chiller train to OPERABLE status (Condition A: One ESF room cooler and related chiller train inoperable)

AC Sources -Operating

  • Required Action C.1 -Restore DG to OPERABLE status (Condition C: Required Actions B.2, B.5.1, or B.5.2 and associated Completion Times not met)

One required offsite circuit inoperable AND One DG inoperable)

  • Required Action G.1 -Restore automatic load sequencer to OPERABLE Status (Condition G: One automatic load sequencer inoperable)

DC Sources -Operating

  • Required Action A.1 -Restore DC electrical power source to OPERABLE status (Condition A: One DC electrical power source inoperable due to inoperable battery A or B) (continued)

E2-3 Enclosure 2 to NL-14-1703 Revised Applicable Technical Specifications Limiting Conditions of Operation LCO 3.8.4 (continued)

LCO 3.8.7 LCO 3.8.9

  • Required Action B.2 -Restore DC electrical power source to OPERABLE status (Condition B: One DC electrical power source inoperable due to inoperable battery C or D)
  • Required Action C.1 -Restore DC electrical power source to OPERABLE status (Condition C: One DC electrical power source inoperable for reasons other than Condition A or B) Inverters-Operating
  • Required Action A.1 -Restore inverter to OPERABLE status (Condition A: One required inverter inoperable)

Distribution Systems -Operating

  • Required Action A.1 -Restore AC electrical power distribution subsystems to OPERABLE status (Condition A: One or more AC electrical power distribution subsystems inoperable)
  • Required Action B.1 -Restore AC vital bus electrical power distribution subsystems to OPERABLE status (Condition B: One or more AC vital bus electrical power distribution subsystems inoperable)
  • Required Action C.1 -Restore DC electrical power distribution subsystems to OPERABLE status (Condition C: One or more DC electrical power distribution subsystems inoperable)

E2-4 Enclosure 2 to NL-14-1703 Revised Applicable Technical Specifications Limiting Conditions of Operation LCO RAs that were included in the initial submittal (Reference

1) but were subsequently removed from the program via References 4 and 7 are listed below. LCO 3.5.5 LCO 3.7.1 LCO 3.7.2 LCO 3.7.3 LCO 3.7.13 LCO 3.8.3 Seal Injection Flow
  • Required Action A.1 -Reduce power to less than or equal to the applicable

% RTP listed in Table 3.7.1-1 (Condition A: One or more MSSVs inoperable)

  • Required Action A.2 -Reduce the Power Range Neutron Flux-High trip setpoint to less than or equal to the applicable

% RTP listed in Table 3. 7.1-1 (Condition A: One or more MSSVs inoperable)

Main Steam Isolation Valves (MSIVs)

  • Required Action D.1 -Verify one MSIV system closed in affected steam line (Condition D: One or more steam lines with one MSIV system inoperable in MODE 2 or3)
  • Required Action E.1 -Verify one MSIV system closed in affected steam line (Condition E: One or more steam lines with two MSIV systems inoperable in MODE 2 or3) Main Feedwater Isolation Valves (MFIVs) and Main Feedwater Regulation Valves (MFRVs) and Associated Bypass Valves
  • Required Action A.1 -Close or isolate MFIV (Condition A: One or more MFIVs inoperable)
  • Required Action C.1 -Close or isolate bypass valve (Condition C: One or more MFRVor MFIV bypass valves inoperable)
  • Required Action D.1 -Isolate affected feedwater line (Condition D: Both isolation systems inoperable in one or more feedwater lines) Piping Penetration Area Filtration and Exhaust System (PPAFES)
  • Required Action A.1 -Restore PPAFES train to OPERABLE status (Condition A: One PPAFES train inoperable)
  • Required Action B.1 -Restore PPAFES boundary to OPERABLE status (Condition B: Two PPAFES trains inoperable due to inoperable PPAFES boundary)

Diesel Fuel Oil, Lube Oil, Starting Air, and Ventilation

  • Required Action A.1 -Restore fuel oil level to within limits (Condition A: One or more DGs with fuel level < 68,000 gal and > 52,000 gal in storage tank)
  • Required Action F.1 -Restore ventilation supply fan to OPERABLE status (Condition F: One or more DGs with one ventilation supply fan inoperable per DG) E2-5 Vogtle Electric Generating Plant Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision O, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines" Enclosure 3 Revised Technical Specifications Mark-Ups Enclosure 3 to NL-14-1703 Revised Technical Specifications Mark-Ups Per References 4 and 7, Southern Nuclear Operating Company, Inc. proposed revisions to the Technical Specification (TS) mark-ups provided in the License Amendment Request submitted September 13, 2012 (Reference 1). The changes to the Reference 1 TS Mark-ups are described in References 4, 7, and Enclosure 1 of this letter. The table below lists the affected mark-ups and the reference in which the revision is discussed.

Some TS Mark-ups that are not different from Reference 1 were included for continuity purposes and are not listed in the table below because they were not revised. Revisions to Mark-Ups Revision Discussion/Basis 3.4.10.A Reference 4 (RAI 1) 3.4.11.E Reference 4 (RAI 1) 3.6.6.A, 3.6.6.8 Reference 9 3.7.2.8 Reference 4 (RAI 1) 3.7.4.8 Enclosure 1 (RAI 23) 3.7.5.A, 3.7.5.8 Reference 9 3.7.6.A Reference 4 (RAI 1) 3.7.9.8, 3.7.9.C Reference 7 (RAI 22) 3.8.1.A, 3.8.1.F Reference 4 (RAI 1) and Reference 9 3.8.9.A, 3.8.9.8, 3.8.9.C Reference 9 5.5 Reference 7 (RAis 4 and 5)

Pressurizer Safety Valves 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 0 Pressurizer Safety Valves LCO 3.4.10 APPLICABILITY

applicable when pressurizer safety valve intentionally made inoperable.

\ACTIONS Three pressurizer safety valves shall be OPERABLE with lift settings 2: 2410 psig and::::; 2510 psig. MODES 1 , 2, and 3. MODE 4 with all RCS cold leg temperatures

> the COPS arming temperature specified in the PTLR. -----------------------------------------NOTE--------------------------------

The lift settings are not required to be within the LCO limits during MODE 3 and MODE 4 with all RCS cold leg temperatures

> the COPS arming temperature specified in the PTLR for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. This exception is allowed for 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> following entry into MODE 3 provided a preliminary cold setting was made prior to heatup. \ CONDITION REQUIRED ACTION COMPLETION TIME A. One pressurizer safety A.1 valve inoperable.

B. Required Action and B.1 associated Completion Time not met. AND OR B.2 Two or more pressurizer safety valves inoperable. Vogtle Units 1 and 2 Restore valve to OPERABLE status. Be in MODE 3. Be in MODE 4 with any RCS cold leg temperatu r e ::::; the COPS arming temperature specified in the PTLR. 15 minutes 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours In accordance with the Risk Informed Competion Time Program 3.4.1 0-1 Amendment (Unit 1) Amendment No. +-+a (Unit 2)

3.4 REACTOR

COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) Pressurizer PORVs 3.4.11 LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE.

APPLICABILITY:

MODES 1 , 2 , and 3. ACTIONS ----------------

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

Separate Condition entry is allowed for each PORV. CONDITION A. One or more PORVs A.1 inoperable and capable of being manually cycled. B. One PORV inoperable B.1 and not capable of being manually cycled. AND B.2 AND B.3 Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Close and maintain power 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to associated block valve. Close associated block 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> valve. Remove power from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OR associated block valve. In accordance with the Risk Restore PORV to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Informed OPERABLE status. Completion Time Program (contmued) 3.4.11-1 Amendment No.I: (Unit 1) Amendment No. -t---+e (Unit 2)

ACTIONS (continued)

CONDITION

c. One block valve inoperable.

D. Required Action and associated Completion Time of Condition A, B, or C not met. E. Two PORVs inoperable and not capable of being manually cycled. ------NOTE -----------

applicable when ond PORV Not sec inte ino ntionally made perable. ---------------------------

Restore PORVs to OPERABLE status. F. More than one block valve inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION C.1 Place associated PORV in manual control. AND C.2 Restore block valve to OPERABLE status. D.1 Be in MODE 3. AND D.2 Be in MODE 4. E.1 Close associated block valves. AND E.2 Remove power from associated block valves. AND Pressurizer PORVs 3.4.11 COMPLETION TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> 72 hours OR .______ In accordance with the Risk 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Informed Completion Time Program 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 1 hour 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in MODE 3.-1 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />'--1 hour I lANDI IE.4 F.1 AND Be in MODE 4.,

OR In accordance Place associated PORVs 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> with the Risk in manual control. 3.4.11-2 Informed Completion Time Program (continued)

Amendment No.f"Wl (Unit 1) Amendment

2)

3.6 CONTAINMENT

SYSTEMS Containment Spray and Cooling Systems 3.6.6 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 train inoperable.

B. One containment B.1 cooling train inoperable. C. Required Action and C.1 associated Completion Time not met. AND C.2 \ Vogtle Units 1 and 2 Restore containment 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> I spray tra i n to OPERABLE "" status. Restore conta i nment cooling train to OPERABLE status. Be in MODE 3. Be in MODE 5. 3.6.6-1 I 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />""' OR In accordance 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> with the Risk Informed Completion 84 hours9.722222e-4 days <br />0.0233 hours <br />1.388889e-4 weeks <br />3.1962e-5 months <br /> Time Program Amendment No *I : I (U nit 1 ) Amendment No. +a+ (Unit 2)

3.7 PLANT

SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs) MSIVs 3.7.2 LCO 3.7.2 Two MSIV systems per steam line shall be OPERABLE. APPLICABILITY

MODE 1 , MODES 2 and 3 except when one MSIV system in each steam line is closed. ACTIONS -----------------------------------

NOTE--------

Separate Condition entry is allowed for each steam line. CONDITION REQUIRED ACTION A. One or more steam line A.1 Restore MSIV to with one MSIV system OPERABLE status. inoperable in MODE 1. B. One or more steam lines B.1 Restore one MSIV with two MSIV systems system to OPERABLE inoperable in MODE 1. status in affected steam line. C. Required Action and C.1 Be in MODE 2. associated Completion Time of Condition A or B not met. ------------

applicable when second steam line with two MSIV systems inoperable intentionally made inoperable.

Vogtle Units 1 and 2 3.7.2-1 COMPLETION TIME 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> with the Risk Informed Completion Time Program 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> (continued)

Amendment No f'Wl (Unit 1) Amendment . .J Unit 2)

3.7 PLANT

SYSTEMS 3.7.4 Atmospheric Relief Valves (ARVs) ARVs 3.7.4 LCO 3.7.4 Three ARV lines shall be OPERABLE.

APPLICABILITY:

MODES 1 , 2 , and 3 ACTIONS CONDITION A. One required ARV line A.1 inoperable. B. Two or more required B.1 ARV lines inoperable.

C. Required Action and C.1 associated Completion Time not met. AND ------------

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

C.2 Not applicable when third ARV line intentionally made inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore required ARV line 30 days I to OPERABLE status. Restore at least two ARV 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> lines to OPERABLE status. OR In accordance Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> with the Risk Informed Completion Time Program Be in MODE 4 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 3.7.4-1 Amendment No.I I (Unit t I Amendment No. ++e (Unit 2)

3. 7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System AFW System 3.7.5 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 A One steam supply to A1 tu r bine driven AFW pump inoperable. B. One AFW train B.1 inoperable for reasons other than Condition A Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore steam supply to 7 days OPERABLE status. I !/ Restore AFW train to L 72 hours OPERABLE status. OR In accordance (continued) with the Risk Informed Completion Time Program 3.7.5-1 Amendment No.I

1) Amendment No. 4-&+ (Unit 2)

THIS PAGE APPLICABLE TO U N IT 1 ONLY 3.7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST) CST 3.7.6 LCO 3.7.6 One CST shall be OPERABLE with a safety-related volume ::::: 340 , 000 gallons. APPLICABILITY:

MODES 1 , 2 , and 3 , ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. CST volume not within A.1 Align Auxiliary Feedwater 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> I limit. pumps to OPERABLE CST. /B Required Action and B.1 Be in MODE 3. associated Completion Time not met. AND ------------

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

B.2 Be in MODE 4 Not applicable when CST intentionally made inoperable.

SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.6.1 Verify the CST volume is within limit. Vogtle Units 1 and 2 3.7.6-1 OR In accordance with the Risk 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Informed Completion Time Program 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FREQUENCY In accordance w i th t h e Surveillance Frequency Control Program Amendment No.j1581 (Unit 1)

THIS PAGE APPLICABLE TO UNIT 2 ONLY 3. 7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST) LCO 3.7.6 Two CSTs shall be OPERABLE with: CST 3.7.6 a. A combined safety-related volume of:::: 378 , 000 gallons; and b. The CST aligned to supply the auxiliary feedwater pumps shall have a safety-related volume :::: 340 , 000 gallons. ------------

NOTE -----------APPLICABILITY

MODES 1 , 2 , and 3 , Not applicable when second CST intentionally made ACTIONS __..... inoperable.

REQUIRED ACTION A. CST volume(s) not A.1 Restore volume(s) to within limit(s). within limit(s). B. Required Action and B.1 Be in MODE 3. associated Completion Time not met. AND B.2 Be in MODE 4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.6.1 Verify CST volumes within limits. COMPLETION TIME 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> OR In accordance with the Risk 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Informed Completion Time Program 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> FREQUENCY In acco r dance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.7.6-2 Amendment No.j140j (Unit 2)

3. 7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS) UHS 3.7.9 LCO 3.7.9 The UHS shall be OPERABLE. The fans/spray cells shall be as specified in Figure 3.7.9-1. APPLICABILITY
MODES 1, 2, 3 , and 4. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A One or more Nuclear A.1 Service Cooling Water (NSCW) basins with water temperature and/or water level not with i n lim i ts. B. One NSCW cooling B.1 tower with one required ' fan/spray cell inoperable when operating i n four fan/spray cell required region of Figure 3.7.9-1. C. One NSCW cooling C.1 tower with one or more required fans/spray cells i noperable for reasons other than Condition B. Vogtle Units 1 and 2 Restore water 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> temperature(s) and water level(s) to within limits. Restore fan to OPERABLE status. Restore fan( s )/spray cell(s) to OPERABLE status. 3.7.9-1 7 days I OR In accordance with the Risk Informed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion Time Program I (continued)

Amendment No. !m"l (Unit 1) Amendment No.

2)

ACTIONS CONDITION A. (continued)

A.2 AND A.3 Vogtle Units 1 and 2 REQUIRED ACTION Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

Restore required offsite circuit to OPERABLE status. AC Sources -Operating

3.8.1 COMPLETION

TIME 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> \ \ (continued)

OR In accordance with the Risk Informed Completion Time Program 3.8.1-2 Amendment No.I: :; I ( Unit 1) Amendment No. +a+ (Unit 2)

ACTIONS CONDITION B. (continued)

C. Required Actions B.2, B.5.1, or B.5.2 and associated Completion Times not met. D. Two required offsite circuits inoperable.

E. One required offsite circuit inoperable.

AND One DG inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION B.6 Restore DG to OPERABLE status. C.1 Restore DG to OPERABLE status. D.1 Declare required feature(s) inoperable when its redundant feature(s) is inoperable. AND D.2 Restore one required offsite circuit to OPERABLE status --------------------NOTE-------------------

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems-Operating," when Condition E is entered wit h no AC power source to one or more trains. ------------------------------------------------

AC Sources -Operating

3.8.1 COMPLETION

TIME 14 days from discovery of failure to meet LCO OR I "" In accordance 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with the Risk Informed Completion Time Program 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from I discovery of I Condition D concurrent with inoperability of redundant required features 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> I t I I (continued) 3.8.1-5 Amendment No.I: :; I ( Unit 1) Amendment No. +a+ (Unit 2)

ACTIONS (continued)

CONDITION E. (continued)

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

Not applicable when second DG intentionally made inoperable.

'\. "" F. Two DGs inoperable.

G. One automatic load Insert 1 sequencer inoperable.

Fh Required Action and r-t: associated Completion Time of ition A, C , D , E , F, ef-G not met. OR G or HI 1/ Required Action B.1 , B.3 , B.4.1, B.4.2 , or B.6 and associated Completion Time not 1.1 met. II Vogtle Units 1 and 2 E.1 OR E.2 F.1 G.1 AND 11.1 REQUIRED ACTION Restore required offsite circuit to OPERABLE status. Restore DG to OPERABLE status. Restore one DG to OPERABLE status. Restore automatic load sequencer to OPERABLE status. Be in MODE 3. Be in MODE 5. Enter LGO 3.0.3.1 AC Sources -Operating

3.8.1 COMPLETION

TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> I 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> I OR 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> In accordance with the Risk Informed Completion 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Time Program ...----6 hours I I 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> I Immediately I I 3.8.1-6 Amendment No *I : Unit 1 I Amendment No. +a+ (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.

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 prefer r ed offsite power sources provided SR 3.8.1.1 is successfully performed within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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.

A. One or more AC A.1 electrical power distribution subsystems inoperable. B. One or more AC vital bus B.1 electr i cal power distribution subsystems inoperable. Vogtle Units 1 and 2 REQUIRED TIME Restore AC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution subsystems to OR OPERABLE status. In accordance with the Risk Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Informed electrical power Completion distribution subsystems to Time Program OPERABLE status. 3.8.9-1 (continued)

Amendment No *I : I (U nit 1) Amendment +a+ (Unit 2)

ACTIONS (continued)

Distribution Systems-Operating

3.8.9 CONDITION

REQUIRED ACTION COMPLETION TIME C. One or more DC C.1 Restore DC electrical electrical power power distribution distribution subsystems subsystems to inoperable. OPERABLE status. [g 1 Required Action and r Be in MODE 3. associated Completion Time not met. AND [9 2 v Be in MODE 5. E E. +we eF meFe eleetFieal I E.1 EnteF LCO 3.0.3.1 13eweF ine13eFasle tt:lat in a less ef SURVEILLANCE REQUIREMENTS SR 3.8.9.1 SURVEILLANCE Verify correct breaker alignments and voltage to required AC , DC , and AC vital bus electrical power distribution subsystems. 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> I OR In accordance with the Risk 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Informed Completion Time Program 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br /> I Immediately I FREQUENCY In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.9-2 Amendment No.I: :;I (Unit 1) Amendment No. +a+ (Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 5.5.21 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 measu r ing CRE pressure and assessing the CRE boundary as required by paragraphs c and d , respectively. 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 suff i cient to assure the associated Limiting Conditions for Operation are met. a. The Surveillance Frequency Control Program shall contain a list of Frequenc i es 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. Vogtle Units 1 and 2 5.5-20 Amendment (Unit 1) Amendment No . .:t4G (Unit 2)

Enclosure 3 to NL-14-1703 Revised Technical Specifications Mark-Ups INSERT 1 (for LCO 3.8.1) H. ------------

NOTE---------

H.1 Not applicable when three or more required AC sources intentionally made inoperable.

Three or more required AC sources inoperable.

INSERT 2 (for LCO 3.8.9) D. ------------

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

0.1 Not applicable when two or more electrical power distribution subsystems intentionally made inoperable.

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

Restore required inoperable AC sources to OPERABLE status. Restore electrical power distribution subsystems to OPERABLE status to restore safety function.

INSERT 3 (for Administrative Controls Section) 5.5.22 Risk Informed Completion Time Program 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 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> In accordance with the 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.

Enclosure 3 to NL-14-1703 Revised Technical Specifications Mark-Ups 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 or inoperability 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. 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 Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines" Enclosure 4 Revised Technical Specifications Clean-Typed Pages Pressurizer Safety Valves 3.4.10 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.1 0 Pressurizer Safety Valves LCO 3.4.1 0 Three pressurizer safety valves shall be OPERABLE with lift settings 2410 psig 2510 psig. APPLICABILITY:

MODES 1, 2, and 3. MODE 4 with all RCS cold leg temperatures

> the COPS arming temperature specified in the PTLR. -----------------------------------------NOTE--------------------------------------------------

The lift settings are not required to be within the LCO limits during MODE 3 and MODE 4 with all RCS cold leg temperatures

> the COPS arming temperature specified in the PTLR for the purpose of setting the pressurizer safety valves under ambient (hot) conditions.

This exception is allowed for 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> following entry into MODE 3 provided a preliminary cold setting was made prior to heatup. ACTIONS CONDITION A. ------------

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

A.1 Not applicable when pressurizer safety valve intentionally made inoperable.

One pressurizer safety valve inoperable.

B. Required Action and B.1 associated Completion Time not met. AND OR Vogtle Units 1 and 2 REQUIRED ACTION Restore valve to OPERABLE status. Be in MODE 3. 3.4.10-1 COMPLETION TIME 15 minutes OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Amendment No. Amendment No. (continued) (Unit 1) (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION Pressurizer Safety Valves 3.4.10 COMPLETION TIME B. (continued)

B.2 Be in MODE 4 with any 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> RCS cold leg temperature Two or more pressurizer safety valves inoperable.

s the COPS arming temperature specified in the PTLR. SURVEILLANCE REQUIREMENTS SR 3.4.10.1 SURVEILLANCE Verify each pressurizer safety valve is OPERABLE in accordance with the lnservice Testing Program. Following testing, lift settings shall be within +/- 1%. Vogtle Units 1 and 2 3.4.10-2 FREQUENCY In accordance with the I nservice Testing Program Amendment No. Amendment No. (Unit 1) (Unit 2)

/ 3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.11 Pressurizer Power Operated Relief Valves (PORVs) Pressurizer PORVs 3.4.11 LCO 3.4.11 Each PORV and associated block valve shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3. ACTIONS -----------------------------------------------------------NOTE------------------------------------------------------------

Separate Condition entry is allowed for each PORV. CONDITION A One or more PORVs A.1 inoperable and capable of being manually cycled. B. One PORV inoperable B.1 and not capable of being manually cycled. AND B.2 AND Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Close and maintain power 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to associated block valve. Close associated block 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> valve. Remove power from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> associated block valve. 3.4.11-1 Amendment No. Amendment No. (continued) (Unit 1) (Unit 2)

ACTIONS (continued)

CONDITION B. (continued) 8.3 C. One block valve C.1 inoperable.

AND C.2 D. Required Action and D.1 associated Completion Time of Condition A, B, AND or C not met. D.2 E. ------------

NOTE ---------E.1 Not applicable when second PORV intentionally made AND inoperable.

E.2 Two PORVs inoperable and not capable of AND being manually cycled. Vogtle Units 1 and 2 Pressurizer Power Operated Relief Valves (PORVs) 3.4.11 REQUIRED ACTION COMPLETION TIME Restore PORV to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status. OR In accordance with the Risk Informed Completion Time Program Place associated PORV 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in manual control. Restore block valve to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OPERABLE status. OR In accordance with the Risk Informed Completion Time Program Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Close associated block 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> valves. Remove power from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> associated block valves. (continued) 3.4.11-2 Amendment No. Amendment No. (Unit 1) (Unit 2)

ACTIONS (continued)

CONDITION E. (continued)

E.3 F. More than one block F.1 valve inoperable.

AND F.2 AND F.3 G. Required Action and G.1 associated Completion Time of Condition F not AND met. G.2 Vogtle Units 1 and 2 Pressurizer Power Operated Relief Valves (PORVs) 3.4.11 REQUIRED ACTION COMPLETION TIME Restore PORVs to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> OPERABLE status. OR In accordance with the Risk Informed Completion Time Program Place associated PORVs 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> in manual control. Restore one block valve 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to OPERABLE status. Restore remaining 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> block valve to OPERABLE status. Be in MODE3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 3.4.11-3 Amendment No. Amendment No. (Unit 1) (Unit 2)

Pressurizer Power Operated Relief Valves (PORVs) 3.4.11 SURVEILLANCE REQUIREMENTS SR 3.4.11.1 SR 3.4.11.2 SURVEILLANCE

NC>TE--------------------------------

Not required to be performed with block valve closed in accordance with the Required Action of Conditions A, B, or E. Perform a complete cycle of each block valve. Perform a complete cycle of each PORV. FREQUENCY In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.11-4 Amendment No. Amendment No. (Unit 1) (Unit 2)

3.6 CONTAINMENT

SYSTEMS Containment Spray and Cooling Systems 3.6.6 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 train inoperable.

B. One containment B.1 cooling train inoperable.

C. Required Action and C.1 associated Completion Time not met. AND C.2 Vogtle Units 1 and 2 Restore containment 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> spray train to OPERABLE status. Restore containment cooling train to OPERABLE status. Be in MODE 3. Be in MODE 5. 3.6.6-1 OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 84 hours Amendment No. Amendment No. (Unit 1) (Unit 2)

3. 7 PLANT SYSTEMS 3.7.2 Main Steam Isolation Valves (MSIVs) MSIVs 3.7.2 LCO 3.7.2 Two MSIV systems per steam line shall be OPERABLE.

APPLICABILITY:

MODE 1, MODES 2 and 3 except when one MSIV system in each steam line is closed. ACTIONS ------------------------------------------------------------NOTE-----------------------------------------------------------

Separate Condition entry is allowed for each steam line. CONDITION REQUIRED ACTION COMPLETION TIME A. One or more steam line A.1 Restore MSIV to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with one MSIV system OPERABLE status. inoperable in MODE 1. OR In accordance with the Risk Informed Completion Time Program B. ------------

NOTE ---------B.1 Restore one MSIV 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> Not applicable when system to OPERABLE second steam line with status in affected steam OR two MSIV systems line. inoperable intentionally In accordance with the made inoperable.

Risk Informed -------------------------------

Completion Time Program One or more steam lines with two MSIV systems inoperable in MODE 1. (continued)

Vogtle Units 1 and 2 3.7.2-1 Amendment No. (Unit 1) Amendment No. (Unit 2)

ACTIONS (continued)

CONDITION REQUIRED ACTION c. Required Action and C.1 Be in MODE 2. associated Completion Time of Condition A or B not met. D. One or more steam lines D.1 Verify one MSIV system with one MSIV system closed in affected steam inoperable in MODE 2 or line. 3. E. One or more steam lines E.1 Verify one MSIV system with two MSIV systems closed in affected steam inoperable in MODE 2 or line. 3. F. Required Action and F.1 Be in MODE 3. associated Completion Time of Condition D or AND E not met. F.2 Be in MODE4. SURVEILLANCE REQUIREMENTS SURVEILLANCE MSIVs 3.7.2 COMPLETION TIME 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 7 days AND Once per 7 days thereafter.

4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> AND Once per 7 days thereafter 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours FREQUENCY SR 3.7.2.1 ----------------------------NOTE-----------------------------

Only required to be performed in MODES 1 and 2. Verify closure time of each MSIV system is ::;; 5 seconds on an actual or simulated actuation signal. Vogtle Units 1 and 2 3.7.2-2 In accordance with the lnservice Testing Program Amendment No. (Unit 1) Amendment No. (Unit 2)

3. 7 PLANT SYSTEMS ARVs 3.7.4 3.7.4 Atmospheric Relief Valves (ARVs) LCO 3.7.4 Three ARV lines shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3 ACTIONS CONDITION A One required ARV line A.1 inoperable.

B. ------------

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

B.1 Not applicable when third ARV line intentionally made inoperable.

Two or more required ARV lines inoperable.

C. Required Action and C.1 associated Completion Time not met. AND C.2 Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore required ARV line 30 days to OPERABLE status. Restore at least two ARV 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> lines to OPERABLE status. OR In accordance with the Risk Informed Completion Time Program Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> Be in MODE4 18 hours2.083333e-4 days <br />0.005 hours <br />2.97619e-5 weeks <br />6.849e-6 months <br /> 3.7.4-1 Amendment No. Amendment No. (Unit 1) (Unit 2)

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 AFWSystem 3.7.5 ---------------------------------------------------------------NOTE--------------------------------------------------------

LCO 3.0.4b is not applicable.

CONDITION A. One steam supply to A.1 turbine driven AFW pump inoperable.

B. One AFW train B.1 inoperable for reasons other than Condition A. Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore steam supply to 7 days OPERABLE status. Restore AFW train to OPERABLE status. 3.7.5-1 OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program Amendment No. Amendment No. (continued) (Unit 1) (Unit 2)

THIS PAGE APPLICABLE TO UNIT 1 ONLY 3. 7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST) LCO 3.7.6 One CST shall be OPERABLE with a safety-related volume 340,000 gallons. APPLICABILITY:

MODES 1, 2, and 3, ACTIONS CST 3.7.6 CONDITION REQUIRED ACTION COMPLETION TIME A. ------------

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

A. 1 Align Auxiliary Feedwater 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Not applicable when CST pumps to OPERABLE intentionally made CST. inoperable.

CST volume not within limit. B. Required Action and B.1 Be in MODE3. associated Completion Time not met. AND B.2 Be in MODE4 SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.6.1 Verify the CST volume is within limit. Vogtle Units 1 and 2 3.7.6-1 OR In accordance with the Risk Informed Completion Time Program 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 12 hours FREQUENCY In accordance with the Surveillance Frequency Control Program Amendment No. (Unit 1) I CST 3.7.6 THIS PAGE APPLICABLE TO UNIT 2 ONLY 3. 7 PLANT SYSTEMS 3.7.6 Condensate Storage Tank (CST) LCO 3.7.6 Two CSTs shall be OPERABLE with: a. A combined safety-related volume of;;:: 378,000 gallons; and b. The CST aligned to supply the auxiliary feedwater pumps shall have a safety-related volume ;;:: 340,000 gallons. APPLICABILITY:

MODES 1, 2, and 3, ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ------------

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

A.1 Restore volume(s) to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> Not applicable when within limit(s).

second CST intentionally OR made inoperable.

In accordance with the Risk Informed CST volume(s) not within Completion Time limit(s).

Program 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 3.7.6-2 Amendment No. (Unit 2) I SURVEILLANCE REQUIREMENTS SURVEILLANCE SR 3.7.6.1 Verify CST volumes within limits. Vogtle Units 1 and 2 3.7.6-3 FREQUENCY CST 3.7.6 In accordance with the Surveillance Frequency Control Program Amendment No. (Unit 2) I

3. 7 PLANT SYSTEMS 3.7.9 Ultimate Heat Sink (UHS) UHS 3.7.9 LCO 3.7.9 The UHS shall be OPERABLE.

The fans/spray cells shall be as specified in Figure 3.7.9-1. APPLICABILITY:

MODES 1, 2, 3, and 4. ACTIONS CONDITION A. One or more Nuclear A.1 Service Cooling Water (NSCW) basins with water temperature and/or water level not within limits. B. One NSCW cooling B.1 tower with one required fan/spray cell inoperable when operating in four fan/spray cell required region of Figure 3.7.9-1. C. One NSCW cooling C.1 tower with one or more required fans/spray cells inoperable for reasons other than Condition B. Vogtle Units 1 and 2 REQUIRED ACTION COMPLETION TIME Restore water 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> temperature(s) and water level(s) to within limits. Restore fan to OPERABLE status. Restore fan(s)/spray cell(s) to OPERABLE status. 3.7.9-1 ?days OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program (continued)

Amendment No. Amendment No. (Unit 1) (Unit 2)

ACTIONS CONDITION A. (continued)

A.2 A.3 Vogtle Units 1 and 2 REQUIRED ACTION Declare required feature(s) with no offsite power available inoperable when its redundant required feature(s) is inoperable.

Restore required offsite circuit to OPERABLE status. AC Sources -Operating

3.8.1 COMPLETION

TIME 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> from discovery of no offsite power to one train concurrent with inoperability of redundant required feature(s) 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program (continued) 3.8.1-2 Amendment No. Amendment No. (Unit 1)1 (Unit 2)

ACTIONS (continued)

CONDITION B. (continued)

c. Required Actions B.2, B.5.1 , or B.5.2 and associated Completion Times not met. D. Two required offsite circuits inoperable.

E. One required offsite circuit inoperable.

AND One DG inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION B.6 Restore DG to OPERABLE status. C.1 Restore DG to OPERABLE status. D.1 Declare required feature(s) inoperable when its redundant feature(s) is inoperable.

AND D.2 Restore one required offsite circuit to OPERABLE status --------------------NOTE-------------------

Enter applicable Conditions and Required Actions of LCO 3.8.9, "Distribution Systems-Operating," when Condition E is entered with no AC power source to one or more trains. ------------------------------------------------

AC Sources -Operating

3.8.1 COMPLETION

TIME 14 days from discovery of failure to meet LCO OR In accordance with the Risk Informed Completion Time Program 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> OR In accordance with the Risk Informed Completion Time Program 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> from discovery of Condition D concurrent with inoperability of redundant required features 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program (continued) 3.8.1-5 Amendment No. Amendment No. (Unit 1) (Unit 2)

ACTIONS (continued)

CONDITION E. (continued)

E.1 OR E.2 F. ------------

NOTE ---------F.1 Not applicable when second DG intentionally made inoperable.

Two DGs inoperable.

G. One automatic load G.1 sequencer inoperable.

Vogtle Units 1 and 2 REQUIRED ACTION Restore required offsite circuit to OPERABLE status. Restore DG to OPERABLE status. Restore one DG to OPERABLE status. Restore automatic load sequencer to OPERABLE status. AC Sources -Operating

3.8.1 COMPLETION

TIME 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> OR In accordance with the Risk Informed Completion Time Program 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> OR In accordance with the Risk Informed Completion Time Program (contmued) 3.8.1-6 Amendment No. Amendment No. (Unit 1) (Unit 2)

ACTIONS (continued)

CONDITION H. ------------

NOTE---------

Not applicable when three or more required AC sources intentionally made inoperable.

Three or more required AC sources inoperable.

I. Required Action and associated Completion Time of Condition A, C, D, E, F, G, or H not met. OR Required Action B.1, B.3, B.4.1, B.4.2, or B.6 and associated Completion Time not met. Vogtle Units 1 and 2 H.1 1.1 AND 1.2 REQUIRED ACTION Restore required AC Sources -Operating

3.8.1 COMPLETION

TIME 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable AC sources to OPERABLE status. Be in MODE 3. Be in MODE 5. 3.8.1-7 OR In accordance with the Risk Informed Completion Time Program (continued) 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours Amendment No. Amendment No. (Unit 1) (Unit 2)

SURVEILLANCE REQUIREMENTS SR 3.8.1.1 SR 3.8.1.2 SURVEILLANCE Verify correct breaker alignment and indicated power availability for each required offsite circuit. ------------------------------NOTES--------------------------

1. Performance of SR 3.8.1. 7 satisfies this SR. 2. All DG starts may be preceded by an engine prelube period and followed by a warmup period prior to loading. 3. A modified DG start involving idling and gradual acceleration to synchronous speed may be used for this SR as recommended by the manufacturer.

When modified start procedures are not used, the time, voltage, and frequency tolerances of SR 3.8.1. 7 must be met. Verify each DG starts from standby conditions and achieves steady state voltage 4025 V and 4330 V, and 58.8 Hz and 61.2 Hz. AC Sources-Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-8 Amendment No. Amendment No. (Unit 1) (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.3 SR 3.8.1.4 SR 3.8.1.5 SR 3.8.1.6 SURVEILLANCE

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

1. DG loadings may include gradual loading as recommended by the manufacturer.
2. Momentary transients outside the load range do not invalidate this test. 3. This Surveillance shall be conducted on only one DG at a time. 4. This SR shall be preceded by and immediately follow without shutdown a successful performance of SR 3.8.1.2 or SR 3.8.1.7. Verify each DG is synchronized and loaded and operates for 60 minutes at a load 6500 kW and 7000 kW. Verify each day tank 650 gal of fuel oil. Check for and remove accumulated water from each day tank. Verify the fuel oil transfer system operates to automatically transfer fuel oil frqm storage tanks to the day tank. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-9 Amendment No. Amendment No. (Unit 1) (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.7 SR 3.8.1.8 SURVEILLANCE

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

All DG starts may be preceded by an engine prelube period. Verify each DG starts from standby condition and achieves in 11.4 seconds, voltage 4025 V and 4330 V, and 58.8 Hz and 61.2 Hz. -----------------------------NOTE-----------------------------

Credit may be taken for unplanned events that satisfy this SR. Verify each DG rejects a its associated single largest post accident load, and: a. Following load rejection, the frequency is 64.5 Hz; b. Within 3 seconds following load rejection, the voltage is 3750 V and 4330 V or 4550 V when performing the test synchronized with offsite power; and c. Within 3 seconds following load rejection, the frequency is 58.8 Hz and 61.2 Hz. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-10 Amendment No. Amendment No. (Unit 1) (Unit 2)

SR 3.8.1.9 SURVEILLANCE

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

Credit may be taken for unplanned events that satisfy this SR. Verify each DG operating as close as practicable to 3390 kVAR while maintaining voltage ::; 4330 V does not trip and voltage is maintained

5000 V during and following a load rejection of 6500 kW and
:; 7000 kW. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-11 Amendment No. Amendment No. (Unit 1) (Unit 2)

SR 3.8.1.10 SURVEILLANCE

NOlrES--------------------------1 . All DG starts may be preceded by an engine prelube period. 2. lrhis Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR. Verify on an actual or simulated loss of offsite power signal: a. De-energization of emergency buses; b. Load shedding from emergency buses; c. DG auto-starts from standby condition and: 1. energizes permanently connected loads in 11.5 seconds, 2. energizes auto-connected shutdown loads through automatic load sequencer, 3. maintains steady state voltage 3750 V and 4330 V, 4. maintains steady state frequency 58.8 Hz and 61.2 Hz, and 5. supplies permanently connected and auto-connected shutdown loads for 5 minutes. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-12 Amendment No. Amendment No. (Unit 1) (Unit 2)

SR 3.8.1.11 SURVEILLANCE

N()lrES--------------------------1 . All DG starts may be preceded by an engine prelube period. 2. lrhis Surveillance shall not be performed in M()DE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR. Verify on an actual or simulated Engineered Safety Feature (ESF) actuation signal each DG auto-starts from standby condition and: a. In $; 11.4 seconds after auto-start and during tests, achieves voltage 3750 V and $; 4330 V; b. In$; 11.4 seconds after auto-start and during tests, achieves frequency 58.8 Hz and$; 61.2 Hz; c. Operates for 5 minutes; d. Permanently connected loads remain energized from the offsite power system; and e. Emergency loads are energized or connected through the automatic load sequencer from the offsite power system. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-13 Amendment No. Amendment No. (Unit 1) (Unit 2)

SURVEILLANCE REQUIREMENTS (continued}

SR 3.8.1.12 SR 3.8.1.13 SURVEILLANCE

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

This Surveillance shall not be performed in MODE 1 or 2. However, credit may be taken for unplanned events that satisfy this SR. Verify each DG's automatic trips are bypassed on actual or simulated loss of voltage signal on the emergency bus concurrent with an actual or simulated ESF actuation signal except: a. Engine overspeed;

b. Generator differential current; and c. Low lube oil pressure;

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

1 . Momentary transients outside the kW and kVAR load ranges do not invalidate this test. 2. Credit may be taken for unplanned events that satisfy this SR. Verify each DG operates for;;::: 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while maintaining voltage ::;; 4330 V: a. For ;;::: 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded ;;::: 6900 kW and ::;; 7700 kW and operating as close as practicable to 3390 kVAR; and b. For the remaining hours of the test loaded ;;::: 6500 kW and ::;; 7000 kW and operating as close as practicable to 3390 kVAR. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued}

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

SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.14 SR 3.8.1.15 SURVEILLANCE

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

1. This Surveillance shall be performed within 5 minutes of shutting down the DG after the DG has operated ;::: 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded ;::: 6500 kW and 7000 kW. Momentary transients outside of load range do not invalidate this test. 2. All DG starts may be preceded by an engine prelube period. Verify each DG starts and achieves, in 11.4 seconds, voltage ;::: 4025 V, and 4330 V and frequency;:::

58.8 Hz 61.2 Hz. -----------------------------NOTE-----------------------------

This Surveillance shall not be performed in MODE 1 , 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR. Verify each DG: a. Synchronizes with offsite power source while loaded with emergency loads upon a simulated restoration of offsite power; b. Transfers loads to offsite power source; and c. Returns to ready-to-load operation.

AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-15 Amendment No. Amendment No. (Unit 1) (Unit 2)

SURVEILLANCE REQUIREMENTS (continuedl SR 3.8.1.16 SR 3.8.1.17 SURVEILLANCE

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

This Surveillance shall not be performed in MODE 1 , 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR. Verify, with a DG operating in test mode and connected to its bus, an actual or simulated ESF actuation signal overrides the test mode by: a. Returning DG to ready-to-load operation; and b. Automatically energizing the emergency load from offsite power. -----------------------------NOTE-----------------------------

This Surveillance shall not be performed in MODE 1 , 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR. Verify interval between each sequenced load block is within +/- 1 0% of design interval for each load sequencer.

AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-16 Amendment No. Amendment No. (Unit 1) (Unit 2)

SR 3.8.1.18 SURVEILLANCE

NOlrES---------------------------

1. All DG starts may be preceded by an engine prelube period. 2. lrhis Surveillance shall not be performed in MODE 1, 2, 3, or 4. However, credit may be taken for unplanned events that satisfy this SR. Verify on an actual or simulated loss of offsite power signal in conjunction with an actual or simulated ESF actuation signal: a. De-energization of emergency buses; b. Load shedding from emergency buses; and c. DG auto-starts from standby condition and: 1. energizes permanently connected loads in 11.5 seconds, 2. energizes auto-connected emergency loads through load sequencer, 3. achieves steady state voltage: ;::: 3750 V 4330 V, 4. achieves steady state frequency:
58.8 Hz 61.2 Hz, and 5. supplies permanently connected and auto-connected emergency loads for ;
:: 5 minutes. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program (continued)

Vogtle Units 1 and 2 3.8.1-17 Amendment No. Amendment No. (Unit 1) (Unit 2)

SURVEILLANCE REQUIREMENTS (continued)

SR 3.8.1.19 SR 3.8.1.20 SURVEILLANCE Verify fuel transfer pump transfers fuel from each fuel storage tank to the day tank of each diesel via the installed cross-connection lines. ------------------------------NOTE----------------------------

All DG starts may be preceded by an engine prelube period. Verify. when started simultaneously from standby condition, each DG achieves, 11.4 seconds, voltage;;::

4025 V 4330 V, and frequency

58.8 Hz and 61.2 Hz. AC Sources -Operating

3.8.1 FREQUENCY

In accordance with the Surveillance Frequency Control Program In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.1-18 Amendment No. Amendment No. (Unit 1) (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.

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 <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> 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.

A. One or more AC A.1 electrical power distribution subsystems inoperable.

B. One or more AC vital bus B.1 electrical power distribution subsystems inoperable.

Vogtle Units 1 and 2 REQUIRED TIME Restore AC electrical 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> power distribution subsystems to OR OPERABLE status. In accordance with the Risk Informed Completion Time Program Restore AC vital bus 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> electrical power distribution subsystems to OR OPERABLE status. 3.8.9-1 In accordance with the Risk Informed Completion Time Program Amendment Amendment (continued) (Unit 1) (Unit 2)

ACTIONS (continued)

CONDITION C. One or more DC C. 1 electrical power distribution subsystems inoperable.

D. ------------

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

D.1 Not applicable when two or more electrical power distribution subsystems intentionally made inoperable.

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

E. Required Action and E.1 associated Completion Time not met. AND. E.2 SURVEILLANCE REQUIREMENTS Distribution Systems -Operating

3.8.9 REQUIRED

ACTION COMPLETION TIME Restore DC electrical 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> power distribution subsystems to OR OPERABLE status. In accordance with the Risk Informed Completion Time Program I . Restore electrical power 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> distribution subsystems to OPERABLE status to OR restore safety function.

In accordance with the Risk Informed Completion Time Program Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 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 FREQUENCY SR 3.8.9.1 Verify correct breaker alignments and voltage to required AC, DC, and AC vital bus electrical power distribution subsystems.

In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.8.9-2 Amendment No. Amendment No. (Unit 1) (Unit 2)

Programs and Manuals 5.5 5.5 Programs and Manuals 5.5.20 5.5.21 5.5.22 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.

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. 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. (continued)

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

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

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 or inoperability 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. 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. Amendment No. (Unit 1) (Unit 2)

Retrieved from "https://kanterella.com/w/index.php?title=NL-14-1703,_Response_to_Request_for_Additional_Information_on_LAR_to_Revise_Technical_Specifications_to_Implement_NEI-06-09,_Rev_0,_Risk_Informed_Technical_Specifications_Initiative_4b,_Risk-Managed_Technical_Specifications_Guidelines.&oldid=1532586"