NEI 06-09, License Conditions for 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

License Conditions for 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

ML15075A479
Person / Time
Site:
Issue date:	03/16/2015
From:	Pierce C Southern Co, Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NEI 06-09, Rev. 0, NL-15-0381
Download: ML15075A479 (32)

Text

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

40 Inverness Center Parkway Post Office Box 1295 A

Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY March 16, 2015 Docket Nos.: 50-424 NL-15-0381 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant- Units 1 & 2 License Conditions for 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 letter dated September 13, 2012, 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 Risk Managed Technical Specifications per Nuclear Energy Institute (NEI) Topical Report 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines.

By letters dated May 16, 2013, June 9, 2014 (corrected by letter dated June 25, 2014), and October 14, 2014, the NRC requested additional information related to this license amendment request. SNC responded to those requests by letters dated August 2, 2013, July 17, 2014, and November 11, 2014 (further clarified via letter dated December 12, 2014).

On February 19, 2015, a conference call was held between SNC and the NRC staff to discuss implementation items provided in the RAI responses discussed above. Enclosure 1 to this letter provides a summary of these implementation items, Enclosure 2 provides a markup to the VEGP Operating License for documenting the implementation items in Enclosure 1, and Enclosure 3 provides clean-typed Operating License pages.

While confirming the TS pages affected by the aforementioned amendment with the NRC staff, SNC identified some affected pages that require resubmittal. contains the markups to the existing TS pages and Enclosure 5 contains the clean-typed TS pages. These pages incorporate the proposed changes discussed in the license amendment dated September 13, 2012, as amended by letters dated August 2, 2013, July 17, 2014, and November 11, 2014 (further clarified via letter dated December 12, 2014).

U. S. Nuclear Regulatory Commission NL-15-0381 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Mr. Chuck Pierce states he is the 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 submitted, G.li'. &ia C. R. Pierce Regulatory Affairs Director CAP/EGA

, 2015.

My commission expires: 1-z- Z.Dit

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, Revision 0-A, November, 2006, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS)

Guidelines

3. NRC Letter dated May 16, 2013, Vogtle Electric Generating Plant, Units 1 and 2 (VEGP) Request for Additional Information, (TAG Nos. ME9555 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)

U.S. Nuclear Regulatory Commission NL-15-0381 Page3

6. NRC Letter dated June 25, 2014, Vogtle Electric Generating Plant, Units 1 and 2 - Corrected - Request for Additional Information, (TAC Nos. ME9555 and ME 9556)

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)

10. Southern Nuclear Operating Company letter, NL-14-1703, dated November 11, 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"

11. Southern Nuclear Operating Company Letter, NL-14-1974, dated December 12, 2014, Vogtle Electric Generating Plant, Units 1 & 2, Clarification of 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"

Enclosures:

1. License Amendment Request Implementation Items

2. Operating Licenses Marked Up Pages

3. Operating Licenses Clean Typed Pages

4. Technical Specifications Limiting Conditions for Operation 3.4.11 and 3.7.5 Marked Up Pages

5. Technical Specifications Limiting Conditions for Operation 3.4.11 and 3.7.5 Clean Typed Pages

U.S. Nuclear Regulatory Commission NL-15-0381 Page4 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President- Fleet Operations Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. G. E. Miller, NRR Senior Project Manager- Vogtle 1 & 2, RMTS LAR 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- Units 1 & 2 License Conditions for 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 License Amendment Request Implementation Items

Implementation Items:

By letters dated August 2, 2013, July 17, 2014, and November 11, 2014 (further clarified via letter dated December 12, 2014), SNC provided responses to requests for additional information from the NRC staff regarding the 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. In some responses, SNC provided certain specific actions to address NRC Staff concerns or provided changes to meet current NRC Staff requirements for approval. These actions are considered implementation items required to receive NRC staff approval of the aforementioned License Amendment Request.

Specifically, these implementation items are as follows:

Description Source SNC shall modify the PRA success criteria to be consistent with the current design basis criteria for Technical Specifications Condition A of the Limiting 1 Conditions for Operation 3.7.5 that was identified in Table E1.1 of Enclosure 1 RAI25 to the license amendment request dated September 13, 2012 before implementation of the RICT program.

SNC shall resolve all F&Os identified as not resolved (IE-A4-01, IE-D1-01 , AS-A 11-01, SY-83-01, DA-C2-01, IF-C2a-01, and QU-F5-01) in Table E2.2 of 2 RAI25 Enclosure 2 to the license amendment request dated September 13, 2012 before implementation of the RICT program .

SNC shall have the necessary procedures for implementing the RICT program 3 RAI25 in place before implementation of the RICT program .

SNC shall update the fire PRA model to include the guidance in NUREG/CR-7150, Vol. 2 (JACQUE-FIRE) which is supported by the Supplemental Interim 4 RAI25 Technical Guidance on Fire-Induced Circuit Failure Mode Likelihood Analysis (ADAMS Accession No.: ML14086A165 and ML14017A135).

SNC shall implement procedural guidance that represents the use of "should" in the following sentence quoted from section 3.3.6, "Common Cause Failure Considerations," of NEI 06-09, Revision 0-A, to mean "shall" in the implementation of the RICT program:

5 RAI25 Page 3-22:

"In addition to a determination of operability on the affected component, the operator should (emphasis added) make a judgment with regard to whether the operability of similar or redundant components might be affected."

E1-1

Description Source SNC shall modify the Vogtle Configuration Risk Management Program Fire PRA model that supports implementation of the RICT Program to reflect one of the following two options:

Option A: Add bounding delta CDF and delta LERF values for the calculated delta CDF and delta LERF values when a TS inoperable SSC needed for remote shutdown, consistent with plant operating 6 procedures, is determined not to be PRA functional. These values RAI2.1 will bound the change in the core damage frequency and the large early release frequency for the main control room abandonment fire scenarios.

Option B: Expand the fire PRA model logic to estimate the conditional core damage probability (CCDP) from the main control room abandonment fire scenarios versus using a CCDP of 1.0.

E1-2

Vogtle Electric Generating Plant- Units 1 & 2 License Conditions for 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 Operating Licenses Marked Up Pages

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (11) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. [ffil are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required.

The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 5.

An exemption was previously granted pursuant to 10 CFR 70.24. The exemption was granted with NRC materials license No. SNM-1967, issued August 21, 1986, and relieved GPC from the requirement of having a criticality alarm system. GPC and Southern Nuclear are hereby exempted from the criticality alarm system provision of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The exemptions in items b and c above are granted pursuant to 10 CFR 50.12. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50 .90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 162.

F. GPC shall comply with the antitrust conditions delineated in Appendix C to this license.

Renewed Operating License No. NPF-68 Amendment No.l173l

Amendment Additional Condition Implementation Number Date 102 The licensee will implement all applicable crane, load path and Before and height, rigging and load testing guidelines of NUREG-0612 and during ANSI Standard 830.2, as described in the licensee's letters dated reracking September 4 , 1997, May 19 and June 12,1998, and evaluated in operations, as the staffs Safety Evaluation dated June 29 , 1998 appropriate.

154 Upon implementation of the Amendment adopting TSTF-448, Revision 3, As stated in the the determination of CRE unfiltered air inleakage as required by SR Additional 3.7.10.5, in accordance with TS 5.5.20.c.(i), and Condition the measurement of CFE pressure as required by Specification 5.5.20 .d, shall be considered met. Following implementation:

(a) The first performance of SR 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01 , or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, specification 5.5.20.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01 , or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

The first performance of the periodic measurement of CRE pressure, specification 5.5.20.d, shall be within 18 months, plus the 138 days allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

173 Southern Nuclear Operating Company (SNC) is approved to implement As stated in the 10 CFR 50.69 using the processes for categorization of Risk-Informed Additional Safety Class (RISC)-1 , RISC-2, RISC-3, and RISC-4 structures, systems, Condition and components (SSCs) specified in the licensee amendment request submittals dated August 31 , 2012, May 17, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11 , 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval, under 10 CFR 50.90 , is required for a change to a categorization process that is outside the bounds specified above (e.g.,

change from a seismic margins approach to a seismic probabilistic risk assessment approach).

I~ Unit 1 Operating Vogtle Umt 1 License Insert I 02- Amendment No. 173

successfully demonstrated prior to the time and condition specified below for each:

a) DELETED b) DELETED c) SR 3.8.1.20 shall be successfully demonstrated at the first regularly scheduled performance after implementation of this license amendment.

(3) Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (5) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No . ~ are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required. The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 8.

Renewed Operating License NPF-81 Amendment No.l166l

Amendment Additional Condition Implementation Number Date 155 Southern Nuclear Operating Company (SNC) is approved to implement As stated in the 10 CFR 50 .69 using the processes for categorization of Risk-Informed Additional Safety Class (RISC}-1 , RISC-2, RISC-3, and RISC-4 structures, systems, Condition and components (SSCs) specified in the licensee amendment request submittals dated August 31 , 2012, May 17, 2013, July 2, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11 , 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval , under 10 CFR 50.90 , is required for a change to a categorization process that is outside the bounds specified above (e.g .,

change from a seismic margins approach to a seismic probabilistic risk assessment approach .)

AI

('

Unit 2 Operating License Insert Vogtle Unit 2 D-2 Amendment No.b 5s l

Unit 1 Operating License Insert Southern Nuclear Operating Company (SNC) is approved to implement As stated in the The Risk Informed Completion Time Program using the as specified in Additional the licensee amendment request submittals dated August 2, 2013, July Condition 17, 2014, and November 11, 2014, and December 12, 2014 The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-15-0381 dated March 16, 2015, prior to the implementation of the Risk Informed Completion Time Program.

Unit 2 Operating License Insert Southern Nuclear Operating Company (SNC) is approved to implement As stated in the The Risk Informed Completion Time Program using the as specified in Additional the licensee amendment request submittals dated August 2, 2013, July Condition 17, 2014, and November 11, 2014, and December 12,2014 The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-15-0381 dated March 16, 2015, prior to the implementation of the Risk Informed Completion Time Program.

Vogtle Electric Generating Plant- Units 1 & 2 License Conditions for 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 3 Operating Licenses Clean Typed Pages

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (11) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. , are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required.

The special circumstances regarding exemption bare identified in Section 6.2.6 of SSER 5.

An exemption was previously granted pursuant to 10 CFR 70.24. The exemption was granted with NRC materials license No. SNM-1967, issued August 21, 1986, and relieved GPC from the requirement of having a criticality alarm system. GPC and Southern Nuclear are hereby exempted from the criticality alarm system provision of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The exemptions in items b and c above are granted pursuant to 10 CFR 50 .12. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 162.

F. GPC shall comply with the antitrust conditions delineated in Appendix C to this license.

Renewed Operating License No. NPF-68 Amendment No.

Amendment Additional Condition Implementation Number Date Southern Nuclear Operating Company (SNC) is approved to implement the As stated in the Risk Informed Completion Time Program using the as specified in the licensee Additional amendment request submittals dated August 2, 2013, July 17, 2014, and Condition November 11,2014, and December 12,2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-15-0381 dated March 16, 2015, prior to the implementation of the Risk Informed Completion Time Program.

Vogtle Unit 1 D-3 Amendment No.

successfully demonstrated prior to the time and condition specified below for each:

a) DELETED b) DELETED c) SR 3.8.1 .20 shall be successfully demonstrated at the first regularly scheduled performance after implementation of this license amendment.

(3) Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (5) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. , are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required. The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 8.

Renewed Operating License NPF-81 Amendment No.

Amendment Additional Condition Implementation Number Date 155 Southern Nuclear Operating Company (SNC) is approved to implement As stated in the 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Additional Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and Condition components (SSCs) specified in the licensee amendment request submittals dated August 31,2012, May 17,2013, July 2, 2013, September 13,2013, May 2, 2014, July 22,2014 and August 11,2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval, under 10 CFR 50.90, is required for a change to a categorization process that is outside the bounds specified above (e.g.,

change from a seismic margins approach to a seismic probabilistic risk assessment approach.)

Southern Nuclear Operating Company (SNC) is approved to implement the As stated in the Risk Informed Completion Time Program using the as specified in the licensee Additional amendment request submittals dated August 2, 2013, July 17, 2014, and Condition November 11,2014, and December 12,2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-15-0381 dated March 16, 2015, prior to the implementation of the Risk Informed Completion Time Program.

Vogtle Unit 2 D-2 Amendment No.

Vogtle Electric Generating Plant- Units 1 & 2 License Conditions for 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 Technical Specifications Limiting Conditions for Operation 3.4.11 and 3.7.5 Marked Up Pages

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

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

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

---

N0 T E-----------------------------------------------------------

Separate Condition entry is allowed for each PORV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 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 /> inoperable and capable to associated block valve.

of being manually cycled .

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

manually cycled.

AND B.2 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.

AND In accordance with the Risk B.3 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 (continued)

Vogtle Units 1 and 2 3.4.11-1 Amendment No. I: :~I (Unit 1)

Amendment No. +e (Unit 2)

Pressurizer PORVs 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

c. One block valve C.1 Place associated PORV 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. in manual control.

AND C.2 Restore block valve to OPERABLE status. ___

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 D. Required Action and D.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 /> Informed associated Completion Completion Time of Condition A, B, AND Time Program or C not met.

D.2 Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E. Two PORVs inoperable E.1 Close associated block 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> and not capable of being valves .

manually cycled.

AND

---

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

Not applicable when E.2 Remove power from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> sec ond PORV associated block valves.

inte ntionally made inoperable. AND

---

~IBe in MODE J.- 1 16 hour1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />sl..

Restore PORVs to ~ lANDI 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> I OPERABLE status.

IE.4 Be in MODE 4.1

~

1~2 hour~ OR In accordance F. More than one block F.1 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 valve inoperable. in manual control. Informed Completion AND Time Program (continued)

Vogtle Units 1 and 2 3.4.11-2 Amendment No.I991(Unit 1)

Amendment No. -74 (Unit 2)

Pressurizer PORVs 3.4.11 ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME

..._ ____

F. (continued) F.2 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 .

OR AND In accordance F.3 Restore remaining 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with the Risk block valve to OPERABLE status. .______ Informed Completion Time Program G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition F not AND met.

G.2 Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 --------------------------N0 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. In accordance with the Surveillance Frequency Control Program SR 3.4.11 .2 Perform a complete cycle of each PORV. In accordance with the Surveillance Frequency Control Program Vogtle Units 1 and 2 3.4.11-3 Amendment No.I: :~I (Unit 1)

Amendment No . .:J.4.G (Unit 2)

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

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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N0 TE--------------------------------------------------------

LCO 3.0.4b is not applicable.

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

~ In accordance with the Risk Informed B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Completion inoperable for reasons OPERABLE status. Time Program other than Condition A. I

.....

~ (continued)

c. ------------ NOTE ----------- C.1 Restore AFW trains to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Not applicable when OPERABLE status.

second AFW train OR intentionally made inoperable. In accordance with

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the Risk Informed Completion Time Two AFW trains Program inoperable.

Vogtle Units 1 and 2 3.7.5-1 Amendment No.,::~ ~Unit 1)

Amendment No. 4-§..t. (Unit 2)

AFWSystem 3.7.5 CONDITION REQUIRED ACTION COMPLETION TIME G Required Action and 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 for Condition A not met.

L...,_. . . . .

Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Three AFW trains -------------NOTE-------------

inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore Immediately one AFW train to OPERABLE status.

Vogtle Units 1 and 2 3.7.5-2 Amendment No. I.Q&I (Unit 1)

Amendment No. +4 (Unit 2)

Vogtle Electric Generating Plant- Units 1 & 2 License Conditions for 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 5 Technical Specifications Limiting Conditions for Operation 3.4.11 and 3.7.5 Clean Typed Pages

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

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

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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N0 TE------------------------------------------------------------

Separate Condition entry is allowed for each PORV.

CONDITION REQUIRED ACTION COMPLETION TIME A. One or more PORVs A.1 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 /> inoperable and capable to associated block valve.

of being manually cycled.

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

manually cycled.

AND B.2 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.

AND B.3 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 (continued)

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

Amendment No. (Unit 2)

Pressurizer Power Operated Relief Valves (PORVs) 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C. One block valve C.1 Place associated PORV 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> inoperable. in manual control.

AND C.2 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 D. Required Action and D.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, B, AND or C not met.

D.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E. ------------ NOTE --------- E.1 Close associated block 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Not applicable when valves.

second PORV intentionally made AND inoperable.

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E.2 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.

Two PORVs inoperable and not capable of AND being manually cycled .

E.3 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 (continued)

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

Amendment No. (Unit 2)

Pressurizer Power Operated Relief Valves (PORVs) 3.4.11 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F. More than one block F.1 Place associated PORVs 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> valve inoperable. in manual control.

AND F.2 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.

OR In accordance with the Risk Informed Completion Time Program AND F.3 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. OR In accordance with the Risk Informed Completion Time Program G. Required Action and G.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition F not AND met.

G.2 Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> Vogtle Units 1 and 2 3.4.11-3 Amendment No. (Unit 1)

Amendment No. (Unit 2)

Pressurizer Power Operated Relief Valves (PORVs) 3.4.11 SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.11.1 --------------------------NOTE-------------------------------

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. In accordance with the Surveillance Frequency Control Program SR 3.4.11.2 Perform a complete cycle of each PORV. In accordance with the Surveillance Frequency Control Program

• Vogtle Units 1 and 2 3.4.11-4 Amendment No. (Unit 1)

Amendment No. (Unit 2)

AFW System 3.7.5

3. 7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFWtrains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

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

LCO 3.0.4b is not applicable.

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

pump inoperable. OR In accordance with the Risk Informed Completion Time Program B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for reasons OPERABLE status.

other than Condition A. OR In accordance with the Risk Informed Completion Time Program (continued)

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

Amendment No. (Unit 2)

AFW System 3.7.5 ACTIONS (continued)

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

second AFW train OR intentionally made inoperable. In accordance with

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the Risk Informed Completion Time Two AFW trains Program inoperable.

D. Required Action and D.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 for Condition A, B, AND or C not met.

D.2 Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> E. Three AFW trains E.1 ------------NOTE-------------

inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

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Initiate action to restore Immediately one AFW train to OPERABLE status.

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

Amendment No. (Unit 2)