ND-18-0199, Supplement to Request for License Amendment and Exemption Regarding Technical Specifications for Reactor Coolant System Vacuum Fill and Inspections, Tests, Analyses, and Acceptance Criteria for Containment Floodup (LAR-17-027S3)

Supplement to Request for License Amendment and Exemption Regarding Technical Specifications for Reactor Coolant System Vacuum Fill and Inspections, Tests, Analyses, and Acceptance Criteria for Containment Floodup (LAR-17-027S3)

ML18045A082
Person / Time
Site:	Vogtle
Issue date:	02/14/2018
From:	Whitley B Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
LAR-17-027S3, ND-18-0199
Download: ML18045A082 (10)

Text

B. H. Whitley Southern Nuclear Director Operating Company, Inc.

Regulatory Affairs 42 Inverness Center Parkway Birmingham, AL 35242 Tel 205.992.7079 Fax 205.992.5296 February 14, 2018 Docket Nos.: 52-025 ND-18-0199 52-026 10 CFR 50.90 10 CFR 52.63 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Supplement to Request for License Amendment and Exemption Regarding Technical Specifications for Reactor Coolant System Vacuum Fill and Inspections, Tests, Analyses, and Acceptance Criteria for Containment Floodup (LAR-17-027S3)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) previously requested an amendment to the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 (License Nos. NPF-91 and NPF-92, respectively).

The requested amendment proposes changes to COL Appendix A, Technical Specifications (TS),

COL Appendix C (and plant-specific Design Control Document (DCD) Tier 1) information, and plant-specific DCD Tier 2 information.

SNC originally submitted this request by SNC letter ND-17-1558, dated September 25, 2017

[ADAMS Accession Number ML17268A188]. Supplement 1 to LAR-17-027 was submitted by SNC letter ND-17-1931, dated November 16, 2017 [ADAMS Accession Number ML17320A808]

to update certain instrumentation function names. Supplement 2 was submitted by SNC letter ND-17-2040, dated December 18, 2017 [ADAMS Accession Number ML17352B003] to provide additional conforming changes to TS Surveillance Requirements.

Four editorial oversights have been discovered in the markups provided in ND-17-1558 for Limiting Condition for Operation (LCO) 3.4.13 that require an additional supplement to correct.

First, the original LAR submittal Enclosure 3, page 12 of 17 shows LCO 3.4.13 A.1 stated as (emphasis added) Five flow paths in ADS stage 1, 2, and 3 shall be OPERABLE and LCO 3.4.13 B.1 stated as Three flow paths in ADS stage 1, 2, and 3, with a minimum of two flow paths in ADS stage 2 or 3, shall be OPERABLE. In each case, OPERABLE should be open. The use of open for the required Automatic Depressurization System (ADS) Stage 1, 2, and 3 flow paths, is consistent with the proposed definition of Vented (which references LCO 3.4.13) and further supported by the submitted LAR discussion (Enclosure 1 page 12 of 26) as well as the submitted Bases (Enclosure 4, page 15 of 20). The second editorial correction involves original LAR

U.S. Nuclear Regulatory Commission ND-18-0199 Page 2 of 5 submittal Enclosure 3, page 14 of 17, which shows the deletion of "while" in three locations. There is a fourth "while" to be deleted in the last Condition C statement on this page. These deletions are described and supported by the submitted LAR discussion (Enclosure 1 page 14 of 26) of editorial changes. The third correction involves original LAR submittal Enclosure 3, page 15 of 17 showing the proposed changes to the revised LCO 3.5.3, ConditionE, which includes adding the phrase "of Condition A, 8, or C." The phrase is revised to "of Condition A, 8, or D." The Condition C reference should have been revised to align with the renumbering of existing Condition "C" to "D." The fourth correction involves original LAR submittal Enclosure 3, page 16 of 17 showing the proposed change adding SR 3.5.3.2 and the Frequency of "In accordance with applicable SRs." Since only one SR is listed, the Frequency should be "In accordance with applicable SR." This supplement updates LAR-17-027 to reflect the necessary corrections as shown in Enclosure 10. 0 provides the applicable corrected markups.

Note that the original exemption request is not impacted by these changes.

The supplemental information provided in this letter, including Enclosure 10, does not change the scope of the original submittal, or alter the conclusions of the Significant Hazards Consideration Determination or Environmental Considerations submitted in LAR-17-027.

This letter, including the enclosure, has been reviewed and confirmed to not contain security-related information. This letter contains no regulatory commitments.

SNC requests approval of the license amendment, and granting of the associated exemption, no later than March 30, 2018 (as originally requested). Approval by this date will allow sufficient time to implement licensing basis changes necessary to support procedure development in relation to conducting the necessary operator training to support plant operations.

SNC expects to implement the proposed amendment within 30 days of approval of the requested changes.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this license amendment request supplement by transmitting a copy of this letter and its enclosure to the designated State Official.

Should you have any questions, please contact Mr. Wesley A. Sparkman at (205) 992-5061.

1 declare under penalty of perjury that the foregoing is true and correct. Executed on the 141h of February 2018.

Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company

U.S. Nuclear Regulatory Commission ND-18-0199 Page 3 of 5

Enclosures:

1) - 4)

(previously submitted with the original LAR, LAR-17-027, in SNC letter ND-17-1558)

5) - 6)

(previously submitted with Supplement 1 to LAR-17-027, in SNC letter ND-17-1931)

7) - 9)

(previously submitted with Supplement 2 to LAR-17-027, in SNC letter ND-17-2040)

10) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Proposed Changes to the Licensing Basis Documents (LAR-17-027S3)

U.S. Nuclear Regulatory Commission ND-18-0199 Page 4 of 5 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosure)

Mr. M. D. Rauckhorst Mr. D. G. Bost (w/o enclosure)

Mr. M. D. Meier (w/o enclosure)

Mr. D. H. Jones (w/o enclosure)

Mr. D. L. McKinney (w/o enclosure)

Mr. T. W. Yelverton (w/o enclosure)

Mr. B. H. Whitley Mr. J. J. Hutto Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. J. D. Williams Mr. F. J. Redwanz Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosure)

Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. T.E. Chandler Ms. P. Braxton Mr. T. Brimfield Mr. C. J. Even Mr. A. Lerch State of Georgia Mr. R. Dunn

U.S. Nuclear Regulatory Commission ND-18-0199 Page 5 of 5 Oglethorpe Power Corporation Mr. M. W. Price Mr. K. T. Haynes Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosure)

Mr. G. Koucheravy (w/o enclosure)

Mr. M. Corletti Mr. M. L. Clyde Ms. L. Iller Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham Mr. R. Grumbir, APOG NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-18-0199 0 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Proposed Changes to the Licensing Basis Documents (LAR-17-027S3)

Additions identified by blue underlined text.

Deletions Identified by red strikethrough of text.

Yellow Highlight indicates changes from original submittal

• *

• indicates omitted text that is not shown.

(This Enclosure consists of 5 pages, including this cover page.)

ND-18-0199 0 Supplement to Proposed Changes to the Licensing Basis Documents (LAR-17-027S3)

Page 2 of 5 This replaces the corresponding markup on ND-17-1558, Enclosure 3, page 12 of 17 COL Appendix A, Technical Specifications, Specification 3.4.13 LCO 3.4.13 ADS stage 1, 2, and 3 flow paths shall be open.

Two ADS stage 4 flow paths shall be OPERABLE.

A.

With reactor subcritical for < 28 hrs:

1.

Five flow paths in ADS stage 1, 2, and 3 shall be open; and

2.

Four flow paths in ADS stage 4 shall be OPERABLE B.

With reactor subcritical for 28 hrs:

1.

Three flow paths in ADS stage 1, 2, and 3, with a minimum of two flow paths in ADS stage 2 or 3, shall be open; and

2.

Three flow paths in ADS stage 4 shall be OPERABLE

ND-18-0199 0 Supplement to Proposed Changes to the Licensing Basis Documents (LAR-17-027S3)

Page 3 of 5 This replaces the corresponding markup on ND-17-1558, Enclosure 3, page 14 of 17 (for Specification 3.4.13)

ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

Required Action and associated Completion Time of Condition A or B not met while in MODE 5.

OR Condition A and Condition B entered concurrently in MODE 5.

OR LCO not met for reasons other than Condition A or B while in MODE 5.

C.1 Initiate action to fill the RCS to establish 20%

pressurizer level.

Immediately AND C.2 AND C.3 Suspend positive reactivity additions.

Initiate action to establish RCS VENTED condition.

Immediately Immediately D.

Required Action and associated Completion Time of Condition A or B not met while in MODE 6.

OR Condition A and Condition B entered concurrently in MODE 6.

OR LCO not met for reasons other than Condition A or B while in MODE 6.

D.1 Initiate action to remove the upper internals.

Immediately AND D.2 Suspend positive reactivity additions.

Immediately

ND-18-0199 0 Supplement to Proposed Changes to the Licensing Basis Documents (LAR-17-027S3)

Page 4 of 5 This replaces the corresponding markup on ND-17-1558, Enclosure 3, page 15 of 17 COL Appendix A, Technical Specifications, Specification 3.5.3 LCO 3.5.3 One CMT shall be OPERABLE.

APPLICABILITY:

MODE 4 with the RCS cooling provided by the Normal Residual Heat Removal System (RNS).

MODE 5 with the RCS not VENTEDpressure boundary intact.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME C.

Required CMT inlet line noncondensible gas volume not within limit in MODE 4.

C.1 OR C.2 Restore CMT inlet line noncondensible gas volume to within limit.

Be in MODE 5.

24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 24 hours D

C.

Required CMT inoperable for reasons other than Condition A, B, or CB.

DC.1 Restore required CMT to OPERABLE status.

8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> E

D.

Required Action and associated Completion Time of Condition A, B, or CD not met.

ED.1 Initiate action to be in MODE 5 with RCS VENTEDpressure boundary open.

Immediately

ND-18-0199 0 Supplement to Proposed Changes to the Licensing Basis Documents (LAR-17-027S3)

Page 5 of 5 This replaces the corresponding markup on ND-17-1558, Enclosure 3, page 16 of 17 (for Specification 3.5.3)

SR 3.5.3.2

- NOTE -

Only required to be met in MODE 4 with RCS cooling provided by the Normal Residual Heat Removal System (RNS).

For the CMT required to be OPERABLE, the following SR is applicable:

SR 3.5.2.4 In accordance with applicable SRs