ND-18-0342, Request for License Amendment and Exempt Equipment Survivability Assessment

Request for License Amendment and Exempt Equipment Survivability Assessment

ML18096B463
Person / Time
Site:	Vogtle
Issue date:	04/06/2018
From:	Whitley B Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
Shared Package
ML18096B462	List: ND-18-0342, Request for License Amendment and Exempt Equipment Survivability Assessment
References
ND-18-0342
Download: ML18096B463 (135)

Text

Southern Nuclear Operating Company, Inc.

42 Inverness Center Parkway Birmingham, AL 35242 April 6, 2018 Docket Nos.: 52-025 ND-18-0342 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 (VEGP) Units 3 and 4 Request for License Amendment and Exemption:

Equipment Survivability Assessment (LAR-18-001)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC), the licensee for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, requests an amendment to Combined License Numbers NPF-91 and NPF-92, for VEGP Units 3 and 4, respectively. The requested amendment includes changes to the Updated Final Safety Analysis Report (UFSAR) in the form of departures from the incorporated plant-specific Design Control Document (DCD) Tier 2 information and related changes to the VEGP Units 3 and 4 COL and COL Appendix C (and corresponding plant-specific DCD Tier 1) information.

Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design certified in the 10 CFR Part 52, Appendix D, Design Certification Rule, is also requested for the plant-specific Tier 1 material departures.

The requested amendment includes changes to the equipment survivability assessment requirements associated with hydrogen burns during beyond design basis accidents as described in the licensing basis documents, including COL Condition 2.D.(12)(g)9 and plant-specific Tier 1 sections 2.2.3 and 2.3.9. Because the proposed changes impact the Combined License and the plant-specific Tier 1 information, this activity has been determined to require prior NRC approval. provides the description, technical evaluation, regulatory evaluation (including the significant hazards consideration), and environmental considerations for the proposed changes. provides the background and supporting basis for the exemption request. provides a reviewers aid that compares the tables of equipment listings in the current licensing basis with the proposed new tables of equipment listings. provides the proposed changes to the licensing basis documents that are releasable to the general public.

U.S. Nuclear Regulatory Commission ND-18-0342 Page 2 of 4 contains portions of the LAR and proposed markups classified as security-related, also referred to as sensitive unclassified non-safeguards information (SUNSI),

which are protected and requested to be withheld under the provisions of 10 CFR 2.390( d).

This letter contains no regulatory commitments. This letter has been reviewed and confirmed to not contain security-related information (other than in the previously noted Enclosure 5).

SNC requests NRC staff review and approval of this license amendment request (LAR) no later than October 1, 2018. Approval by this date will allow sufficient time to implement licensing basis changes necessary to support closure of an Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) item and installation of the hydrogen igniters. SNC expects to implement the proposed amendment within thirty days of approval of the LAR.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this LAA by transmitting a copy of this letter and enclosures to the designated State Official.

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 6th of April 2018.

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

Enclosures:

1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Exemption Request:

Equipment Survivability Assessment (LAR-18-001)

3) Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Reviewer's Aid:

Differences in COL Referenced Tables (LAR-18-001)

4) Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

5) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to the Licensing Basis Documents - Withheld Information (LAR-18-001)

U.S. Nuclear Regulatory Commission ND-18-0342 Page 3 of 4 cc:

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

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

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

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

Mr. J. B. Klecha (w/o enclosure 5)

Mr. G. Chick (w/o enclosure 5)

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

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

Mr. B. H. Whitley Ms. C. A. Gayheart (w/o enclosure 5)

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. F. J. Redwanz Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

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 (w/o enclosure 5)

Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 5)

Mr. K. T. Haynes (w/o enclosure 5)

Ms. A. Whaley (w/o enclosure 5)

U.S. Nuclear Regulatory Commission ND-18-0342 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 5)

Mr. S. M. Jackson (w/o enclosure 5)

Dalton Utilities Mr. T. Bundros (w/o enclosure 5)

Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. G. Koucheravy (w/o enclosures)

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. (w/o enclosure 5)

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure 5)

Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure 5)

Ms. S. W. Kernizan, Georgia Public Service Commission (w/o enclosure 5)

Mr. K. C. Greene, Troutman Sanders (w/o enclosure 5)

Mr. S. Blanton, Balch Bingham Mr. R. Grumbir, APOG (w/o enclosure 5)

NDDocumentinBox@duke-energy.com, Duke Energy (w/o enclosure 5)

Mr. S. Franzone, Florida Power & Light (w/o enclosure 5)

\

Southern Nuclear Operating Company ND-18-0342 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Equipment Survivability Assessment (LAR-18-001)

(This Enclosure consists of 56 pages, including this cover page)

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION

3. TECHNICAL EVALUATION (Combined with Section 2)

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 4.2 Precedent 4.3 Significant Hazards Consideration 4.4 Conclusions

5. ENVIRONMENTAL CONSIDERATIONS

6. REFERENCES Page 2 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC, or the Licensee) hereby requests an amendment to Combined License (COL)

Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.

1.

SUMMARY

DESCRIPTION The requested amendment proposes to depart from approved AP1000 Design Control Document (DCD) Tier 2 information as incorporated into the Updated Final Safety Analysis Report (UFSAR) as plant-specific DCD information, which also involves changes to COL Appendix C (and associated plant-specific Tier 1) information. Changes are proposed to the locations of Hydrogen Igniters 30, 35, 36, 37, and 38 (to meet igniter location criteria specified in the UFSAR) to the location of Hydrogen Igniter 27 (for consistency), and some location details of Hydrogen Igniters 9, 10, 15, and 16 (for clarity). The requested amendment also proposes to consolidate COL Appendix C (and plant-specific Tier 1) Table 2.2.3-4, ITAAC 2.2.03.09c with COL Condition 2.D.(12)(g)9, and revise COL Condition 2.D.(12)(g)9 to replace the reference to APP-GW-GLR-069 with new UFSAR Tables 19D-8 and 19D-9 in UFSAR Appendix 19D. The changes revise and add to the equipment on which the equipment survivability assessment is performed to include equipment revised or added to the design since the issuance of the COL.

The requested amendment requires changes to the licensing basis documents in the form of departures from the plant-specific Design Control Document (DCD) Tier 2 information (as incorporated into the UFSAR and detailed in Section 2), changes to the associated COL Condition 2.D.(12)(g)9, and changes associated with plant-specific Tier 1 (and associated COL Appendix C) information. This enclosure requests approval of the license amendment necessary to implement these changes. Enclosure 2 requests the exemption necessary to implement the involved changes to the plant-specific Tier 1 information.

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION A. Hydrogen Igniter Relocation This portion of the license amendment request includes changes related to Hydrogen Igniters:

1) Relocation of Hydrogen Igniter 30;

2) Relocation of Hydrogen Igniters 35, 36, 37, and 38;

3) Changes to Hydrogen Igniter 27 Room Number and Elevation Details; and

4) Changes to Hydrogen Igniters 9, 10, 15, 16 Location Details.

A.1) Relocation of Hydrogen Igniter 30 The Igniter Location Criteria described in UFSAR Table 6.2.4-6 states:

• A sufficient number of igniters are placed in the major transport paths (including dominant natural circulation pathways) of hydrogen so that hydrogen can be burned continuously close to the release point. This prevents hydrogen from preferentially accumulating in a certain region of the containment.

• Igniters (minimum of 2) are located in major regions or compartments where hydrogen may be released, through which it may flow, or where it may accumulate.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

As described in UFSAR Table 6.2.4-7 and Figures 6.2.4-9 and 6.2.4-13 and COL Appendix C Table 2.3.9-2, Hydrogen Igniter 32 (tag number VLS-EH-32) is located at elevation 120-0" in the Lower Compartment Area (Room 11400) and is powered from Power Group 1. Hydrogen Igniter 32 is located near the Passive Residual Heat Removal (PRHR) inspection flange and Reactor Coolant System (RCS) pressurizer spray line, which are potential sources of hydrogen release.

Hydrogen Igniter 32 is the only igniter in the proximity of these two sources. If Power Group 1 failed, then there would not be any igniter coverage for these sources of hydrogen. This is not consistent with the Igniter Location Criteria described above.

In order to meet the Igniter Location Criteria, at least two igniters must be located near potential sources of hydrogen. A review of hydrogen igniter locations identified that Hydrogen Igniter 30 should be moved from Room 11401 to a location near the PRHR inspection flange and RCS pressurizer spray line, which are potential sources of hydrogen. Sufficient igniter coverage is already provided to Room 11401 by Hydrogen Igniter 11 powered from Power Group 2 and Hydrogen Igniter 13 powered from Power Group 1. The current location for Hydrogen Igniter 30 is redundant because Hydrogen Igniter 11 is located approximately 3 feet away and powered from the same Power Group. The hydrogen mixing/combustion analysis confirms that sufficient igniter coverage to Room 11401 is provided by Hydrogen Igniters 11 and 13 to meet the igniter location criteria; therefore, Hydrogen Igniter 30 can be moved out of this room.

Relocating Hydrogen Igniter 30 from Room 11401 to Room 11403 is proposed to provide sufficient igniter coverage for the PRHR inspection flange and RCS pressurizer spray line hydrogen sources. Hydrogen Igniter 30 will provide backup to Hydrogen Igniter 32 since they are powered by different power groups. Room 11403 and Room 11400 are both located in the Lower compartment area, and are only separated by two small walls that do not rise to the ceiling.

Hydrogen Igniters 30 and 32 will provide coverage for both rooms because the room volumes are connected. Hydrogen Igniter 30 is proposed to be installed above the RCS pressurizer spray line at an elevation of 132-8. The hydrogen mixing/combustion analysis confirms that sufficient igniter coverage to meet the igniter location criteria in the Lower compartment area is provided by Hydrogen Igniters 30 and 32.

Hydrogen Igniter 30 is relocated to provide sufficient igniter coverage for the PRHR inspection flange and RCS pressurizer spray line hydrogen sources.

Related Licensing Basis Document Change Descriptions The following changes are proposed to COL Appendix C for the relocation of Hydrogen Igniter 30:

• Table 2.3.9-2 is revised to change the Room Number for Hydrogen Igniter 30 from 11401 to Room 11403.

• Table 2.3.9-2 is revised to change the Location for Hydrogen Igniter 30 from Loop compartment 01 to Lower compartment area (CMT and valve area).

The following changes are proposed to the UFSAR for the relocation of Hydrogen Igniter 30:

• Table 6.2.4-7 is revised to change the elevation of Hydrogen Igniter 30 from 120 to 132-8.

• Figure 6.2.4-9 is revised to depict the relocation of Hydrogen Igniter 30 from Room 11401 to Room 11403.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

• Figure 6.2.4-13 is revised to add Hydrogen Igniter 30. The relocation of Hydrogen Igniter 30 makes it viewable in the figures sectional view.

(The technical evaluation for the relocation of Hydrogen Igniter 30 is provided together with the technical evaluation for the relocation of Hydrogen Igniters 35, 36, 37, and 38, provided below.)

A.2) Relocation of Hydrogen Igniters 35, 36, 37, and 38 As described in UFSAR Tables 6.2.4-6 and 6.2.4-7 and Figure 6.2.4-10 and COL Appendix C Table 2.3.9-2, Hydrogen Igniters 35, 36, 37, and 38 (tag numbers VLS-EH-35/36/37/38) are located at elevation 137-0 in the In-Containment Refueling Water Storage Tank (IRWST)

(Room 11305) vent outlets. The IRWST vent outlets have normally closed covers to prevent debris from the containment operating deck from entering the IRWST and to contain water vapor within the tank to minimize evaporation during plant operation. The vent covers open on a differential pressure between the IRWST and the containment atmosphere to provide steam venting to protect the IRWST from over-pressurization. As described in UFSAR Table 6.2.4-6, the IRWST can be steam inert (steam concentrations greater than 50 percent) or hydrogen rich, inhibiting ignition within the IRWST, including inside the exhaust vent, as hydrogen exhausts from the IRWST.

Relocating Hydrogen Igniters 35, 36, 37, and 38 from inside the IRWST (Room 11305) vent outlets to above the outside of the IRWST vent outlets is proposed to improve the Hydrogen Igniters performance of their design function. The proposed location of the Hydrogen Igniters is in the upper compartment lower region, Room 11500, at an elevation of 137-6, just outside of the IRWST hooded vents.

Igniter coverage is provided inside the IRWST by Hydrogen Igniters 9, 10, 15, and 16. Hydrogen Igniters 9 and 10 are located near the spargers, which are the potential source of hydrogen within the IRWST. Hydrogen Igniters 15 and 16 are located at the inlet vents to the IRWST to prevent hydrogen and oxygen mixtures that could become detonable if air is drawn into a hydrogen-rich IRWST. These four igniters provide sufficient igniter coverage within the IRWST and meet the Igniter Location Criteria in UFSAR Table 6.2.4-6. Hydrogen Igniters 35, 36, 37, and 38 are proposed to be located external to the IRWST hooded vents, rather than located within, or "fitted" inside of the IRWST vents.

Related Licensing Basis Document Change Descriptions The following changes are proposed to COL Appendix C for the relocation of Hydrogen Igniters 35, 36, 37, and 38:

• Table 2.3.9-2 is revised to change the location of Hydrogen Igniters 35, 36, 37, and 38 from IRWST to IRWST hooded vents.

• Table 2.3.9-2 is revised to change the room number for Hydrogen Igniters 35, 36, 37, and 38 from 11305 to 11500.

The following changes are proposed to the UFSAR for the relocation of Hydrogen Igniters 35, 36, 37, and 38:

• Table 6.2.4-6 is revised to change the IRWST description of the hydrogen igniter locations to include: IRWST sparger side, IRWST roof vents, IRWST vacuum breaker vents, and IRWST Page 5 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) hooded vents, and to indicate the igniters are near the vents rather than within the vents. Additionally, for the lower compartment area, the igniters are identified as near the mezzanine deck elevation rather that just above that elevation.

• Table 6.2.4-7 is revised to move Hydrogen Igniters 35, 36, 37, and 38 from subcompartment "IRWST Outlets" to the renamed IRWST Hooded Vents subcompartment.

• Table 6.2.4-7 is revised to change the elevation of Hydrogen Igniters 35, 36, 37, and 38 from 137 to 137-6.

• Figure 6.2.4-10 is revised to move Hydrogen Igniters 35, 36, 37, and 38 from inside the IRWST vents to above the outside of the IRWST vent outlets.

The following changes are proposed to the Technical Requirements Manual Table TR 3.6.2-1

[DCD Table 16.3-2, Table 2.8-1] for the relocation of Hydrogen Igniters 35, 36, 37, and 38:

• A new location is added to Table TR 3.6.2-1 to reflect Hydrogen Igniters 35, 36, 37, and 38 are now located near the IRWST hooded vents with three igniters required. The new location description for these igniters located just outside the IRWST hooded vents is added to Table TR 3.6.2-1, and the location description of other IRWST related igniters is revised, consistent with changes to Tier 1 Table 2.3.9-2 and UFSAR Tables 6.2.4-6 and 6.2.4-7.

Technical Evaluation for the Relocation of Hydrogen Igniters 30, 35, 36, 37, and 38 The assessment of the potential hydrogen diffusion flame locations and zones of influence identifies the locations where hydrogen may be released from the RCS into a subcompartment and postulated to produce a diffusion flame as the IRWST vents to the upper compartment, the Passive Core Cooling System (PXS) compartment vents to the Core Makeup Tank (CMT) room, the Chemical and Volume Control System (CVS) compartment vents to the CMT room, the Automatic Depressurization System (ADS) stage 4 discharge, and postulated RCS break locations in the loop compartments and pressurizer compartment. Diffusion flames are ignited by the igniters and burn from the location of the source of the hydrogen flow in the room where oxygen is available to support the combustion. The diffusion flame assessment conservatively assumes plume ignition as the plume exits the vents/compartment and enters an oxygen-rich volume, which is conservative because the hydrogen concentration is highest at this location and will result in higher thermal loads. As a result, the specific location of igniters does not impact the diffusion flame assessment. The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not adversely affect the assumptions or results of the diffusion flame assessment.

Therefore, results from the diffusion flame assessment remain valid with no changes to diffusion flame locations or zones of influence.

The hydrogen deflagration analysis conservatively assumes the adiabatic, isochoric, complete combustion (AICC) of hydrogen from 100% cladding oxidation to calculate a bounding peak pressure and temperature to demonstrate the containment vessel shell stresses resulting from all deflagration events are within American Society of Mechanical Engineers (ASME) Service Level C limits. Because AICC conditions are postulated to occur when the igniters are not operating to prevent the accumulation of global hydrogen in the containment, the specific location of igniters does not impact the hydrogen deflagration analysis. As a result, the proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not adversely affect the assumptions or results of the hydrogen deflagration analysis. Therefore, the results of the hydrogen deflagration analysis Page 6 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) remain valid and support the conclusion that the containment vessel ASME Service Level C allowable stress limits are met.

The probability of hydrogen deflagration-to-detonation-transition (DDT) is considered in the AP1000 containment probabilistic risk assessment (PRA) event tree assuming the igniters have failed. Therefore, the specific location of the hydrogen igniters does not impact the probability of DDT assumed in the PRA.

IRWST Hooded Vents- Igniters 35, 37, 36, 38 (total of four) are actually located near the IRWST Hooded Vents within the upper compartment - lower region location. Thus the IRWST Hooded Vents location contains a total of four igniters split evenly on two separate power groups. In order to maintain minimum availability of igniters at the new IRWST Hooded Vents location, the number of Required Igniters should be 3 (of 4). This maintains availability of at least one igniter on each power group, thus satisfying the igniter location criteria.

Three of four Required Igniters is consistent between UFSAR Table 6.2.4-7and TR 3.6.2-1 to allow for the loss of functionality of one igniter per location. Three Required Igniters for the IRWST Hooded Vents location within TR 3.6.2-1 bounds the analysis assumptions and is appropriate.

An equipment survivability assessment has been performed to evaluate the survivability of essential equipment for the most likely severe accident scenarios that produce a hydrogen burn inside containment. The purpose of the equipment survivability assessment is to evaluate the availability of essential equipment used during a severe accident to achieve a controlled, stable state after core damage under the unique containment environments associated with core damage. Hydrogen igniters are assumed in the equipment survivability assessment to control flammable gases released due to cladding oxidation during a severe accident. The igniter elevations assumed in the equipment survivability assessment are set to the elevation of the lowest igniters in the loop compartments, upper compartments, and CMT compartments in order to maximize the completeness of combustion (thermal effects) for the affected equipment. The locations of igniters in the smaller compartments (IRWST, PXS compartments) are not adjusted in the equipment survivability assessment. The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not adversely affect the assumptions or results of the equipment survivability assessment and therefore also do not adversely affect the ability of essential equipment (including the hydrogen igniters) to perform its intended function in a severe accident.

The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not adversely impact any functions associated with containing, controlling, channeling, monitoring, or processing radioactive or nonradioactive materials, nor do they diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. The types and quantities of expected plant effluents are not changed. No effluent release path is impacted by this change. Therefore, neither radioactive nor nonradioactive material effluents are affected by the proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38.

The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not adversely impact radiologically controlled zones. Plant radiation zones, radiation controls established to satisfy 10 CFR Part 20 requirements, and expected amounts and types of radioactive materials, are not affected by the proposed changes. Therefore, individual and cumulative radiation exposures are not significantly affected by the proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 meet the Igniter Location Criteria described in UFSAR Table 6.2.4-6 and therefore, do not alter the intended design function of the igniters to promote hydrogen burning at a low concentration and to burn hydrogen so that the uniformly distributed hydrogen concentration remains below 10 percent by volume in the containment.

The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 have no adverse effect on the analyses and assessments or the analysis and assessment methods, and do not adversely affect the performance or controls of hydrogen control functions. The PRA insights that informed UFSAR Section 16.3, "Investment Protection," are not affected by the proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38.

The hydrogen igniters are part of the containment hydrogen control system (VLS) hydrogen ignition subsystem, which does not interface with or affect safety-related equipment or a fission product barrier. The hydrogen ignition subsystem is provided to address the production of hydrogen following a beyond design basis accident in accordance with 10 CFR 50.44(c). The hydrogen ignition subsystem is a non-Class 1E subsystem and does not interface with any safety-related system; thus, no system or design function or equipment qualification is affected by the proposed changes. The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not result in a new failure mode, malfunction or sequence of events that could adversely affect a radioactive material barrier or safety-related equipment. The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures.

The VLS hydrogen ignition subsystem will continue to perform its beyond design basis function as defined in the UFSAR. The hydrogen ignition subsystem does not affect safety-related equipment or equipment whose failure could initiate an accident. The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not involve safety-related equipment or a radioactive material barrier. The proposed relocations of Hydrogen Igniters 30, 35, 36, 37, and 38 do not adversely affect any safety-related equipment, design code limit (allowable value), safety-related function or design analysis, nor do they adversely affect any safety analysis input or result, or design/safety margin.

A.3) Hydrogen Igniter 27 Room Number and Elevation Details COL Appendix C Table 2.3.9-2 states that Hydrogen Igniter 27 (tag number VLS-EH-27) is located in Room 11400. This is inconsistent with UFSAR Figure 6.2.4-5, which shows that Hydrogen Igniter 27 is located in Room 11300.

As described in UFSAR Subsection 6.2.4.2.3, the hydrogen igniter locations identified in UFSAR Table 6.2.4-7 are considered approximations (+/- 2.5 feet) with the final locations governed by the installation details. Although these elevations are approximate and not specified on the UFSAR figures, it is desirable to have a specific reference in the UFSAR for the elevation of Hydrogen Igniter 27.

UFSAR Figure 6.2.4-5 shows Hydrogen Igniter 27 below the maintenance floor mezzanine grating. The grating separates Room 11400 (above the grating) and 11300 (below the grating),

and therefore Hydrogen Igniter 27 is located in Room 11300, below the maintenance floor mezzanine grating. Changes are proposed to COL Appendix C Table 2.3.9-2 to change the room Page 8 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) number for Hydrogen Igniter 27 from 11400 to 11300. Changes are also proposed to UFSAR Table 6.2.4-6 to change the description of the igniter locations in the Lower Compartment Area from just above the mezzanine deck elevation or near the ceiling to near the mezzanine deck elevation or near the ceiling, because Hydrogen Igniter 27 is located below the mezzanine deck and other igniters in the Lower Compartment Area are located above the mezzanine deck.

The changes to the room number and location description for Hydrogen Igniter 27 in COL Appendix C Table 2.3.9-2 are consistency changes. Design documents for the location of hydrogen igniters in containment identify Hydrogen Igniter 27 in Room 11300 at elevation 117'-3".

Related Licensing Basis Document Change Descriptions The following changes are proposed to COL Appendix C for the changes to the room number (location) of Hydrogen Igniter 27:

• Table 2.3.9-2 is revised to change the Room Number for Hydrogen Igniter 27 from 11400 to 11300.

The following changes are proposed to the UFSAR for the changes to the room number, location description, and elevation of Hydrogen Igniter 27:

• Table 6.2.4-6 is revised to change the description of the igniter locations in the Lower Compartment Area from just above the mezzanine deck elevation or near the ceiling to near the mezzanine deck elevation or near the ceiling.

• Table 6.2.4-7 is revised to change the elevation of Hydrogen Igniter 27 from 120 to 117-3.

Technical Evaluation for Hydrogen Igniter 27 Room Number and Elevation Details The proposed changes to the room number, location description, and elevation of Hydrogen Igniter 27 are consistency changes within the licensing basis documents and do not adversely affect the design functions of the VLS hydrogen ignition subsystem or the analyses and assessments or the analysis and assessment methods.

A.4) Hydrogen Igniters 9, 10, 15, 16 Location Details The description of hydrogen igniters associated with the IRWST in UFSAR Table 6.2.4-6 is not sufficiently detailed to afford clear correlation with the hydrogen igniters described in UFSAR Table 6.2.4-7, TRM Table TR 3.6.2-1, and COL Appendix C Table 2.3.9-2. Locations are described at differing levels of detail.

The change activity is to make the descriptions of the hydrogen igniters used for coverage for the IRWST clear and consistent among UFSAR Table 6.2.4-6, 6.2.4-7, TRM Table TR 3.6.2-1 and COL Appendix C Table 2.3.9-2. Igniters 9, 10, 15, and 16 are located inside the IRWST. Igniters 9 and 10 are located inside the IRWST on the sparger side of the IRWST to ignite hydrogen released to the IRWST by the spargers. The description of igniter location for igniters 9 and 10 is changed to IRWST Sparger Side for igniters inside the IRWST, near the spargers, to delineate that these hydrogen igniters are near the spargers.

Igniters 15 and 16 are located inside the IRWST on the side opposite the spargers, near the IRWST inlet vents, to ignite hydrogen inside the IRWST as air is drawn through the inlet vents.

The description of the igniter location for igniters 15 and 16 is changed to IRWST Vacuum Breaker Page 9 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Vents to delineate that these hydrogen igniters are near the vacuum breaker vents.

Thus, the IRWST Sparger Side location contains igniters 9 and 10, both of which are on separate power groups, and the IRWST Vacuum Breaker Vents location contains igniters 15 and 16, both of which are also on separate power groups. The Modular Accident Analysis Programs (MAAP4) model only credits igniters from one power group for each location. For analysis, only one Power Group is assumed to be available thus only igniter 9 or igniter 10 and igniter 15 or igniter 16 is credited.

In addition to specifying the IRWST Sparger Side and IRWST Vacuum Breaker Vents locations in the IRWST, a location is added specifying the IRWST Roof Vents, to the sentences in the IRWST location describing the arrangement of hydrogen igniters located near the IRWST roof vents. As stated in UFSAR Table 6.2.4-6, hydrogen will be ignited as it exhausts from the IRWST at any of the vents with igniter assemblies. These are the IRWST roof vents and the change is made to improve clarity with regard to the location of the IRWST being discussed. The igniters are not actually moved. The change is an editorial change for clarity and to be consistent with the description in TRM Table TR 3.6.2-1 and UFSAR Table 6.2.4-7.

The change is an editorial change to the location description for Hydrogen Igniters 9, 10, 15, and 16 to describe where the igniters inside the IRWST are located. The locations of the igniters are not changed. The change to the location description does not adversely affect the design functions of the VLS hydrogen ignition subsystem.

Table TR 3.6.2-1 is revised to change the name of the IRWST location to IRWST Sparger Side and the number of required igniters for this location from 5 to 2. The hydrogen mixing/combustion analysis confirms that only 2 igniters are required in the IRWST. The analysis assumes the loss of 1 power group, and therefore only 2 of the 4 Hydrogen Igniters in the IRWST are credited.

Table TR 3.6.2-1 is also revised to rename the IRWST Inlet location to IRWST Vacuum Breaker Vents. The required number of hydrogen igniters is not changed for this location.

In summary, two Required Igniters for the IRWST Sparger Side and IRWST Vacuum Breaker Vents locations in TR 3.6.2-1 bound analysis and are appropriate. The loss of a power train reduces the available igniters by one-half. The two remaining igniters are shown to be sufficient to control the hydrogen mixtures inside the IRWST envelope by igniting the hydrogen released to the IRWST through the ADS spargers.

Related Licensing Basis Document Change Descriptions The following changes are proposed to COL Appendix C for the change to the location description for Hydrogen Igniters 9, 10, 15, and 16:

• Table 2.3.9-2 is revised to change the location description of Hydrogen Igniters 9 and 10 to add "sparger side" to the location description.

• Table 2.3.9-2 is revised to change the location description of Hydrogen Igniters 15 and 16 to add "vacuum breaker vents" to the location description.

The following changes are proposed to the UFSAR for the change to the location description of Hydrogen Igniters 9, 10, 15, and 16:

• Table 6.2.4-6 is revised to provide more detail for the location of hydrogen igniters providing Page 10 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) coverage for the IRWST. The description of the IRWST is divided into four descriptions. The proposed change to the description for Hydrogen Igniters 9, 10, 15, and 16 adds a description of the IRWST Sparger Side and IRWST Vacuum Breaker Vents. A description identifying the IRWST Roof Vents is added to the sentences in the IRWST location where the function of the IRWST roof vents and the igniters located at the vents are described.

• Table 6.2.4-7 is revised to change to Subcompartment name for Hydrogen Igniters 9 and 10 from IRWST Interior to IRWST Sparger Side.

• Table 6.2.4-7 is revised to change the Subcompartment name for Hydrogen Igniters 15 and 16 from IRWST Inlet to IRWST Vacuum Breaker Vents.

The following changes are proposed to the Technical Requirements Manual Table TR 3.6.2-1 for location description of Hydrogen Igniters 9, 10, 15, and 16:

• The row for the IRWST is renamed IRWST Sparger Side and the required number of igniters is changed from 5 to 2, as this row no longer includes the IRWST hydrogen igniters at other locations.

• The row for IRWST Inlet is renamed IRWST Vacuum Breaker Vents.

Technical Evaluation for Hydrogen Igniters 9, 10, 15, 16 Location Details The locations of the igniters are not changed. The change to the location description does not adversely affect the design functions of the VLS hydrogen ignition subsystem and does not affect the analyses and assessments or the analysis and assessment methods.

Conclusion of Technical Evaluations for Hydrogen Igniter Changes The proposed changes to the VLS hydrogen ignition subsystem do not affect its function to effectively reduce hydrogen build-up following the beyond design basis accident as postulated in accordance with 10 CFR 50.44(c). The changes do not affect any function or feature used for the prevention or mitigation of accidents or their safety analyses. No safety-related structure, system, component (SSC) or function is affected. The proposed changes do not involve nor interface with any SSC accident initiator or initiating sequence of events related to the accidents evaluated in the UFSAR. The proposed changes do not affect the radiological source terms (i.e., amounts and types of radioactive materials released, their release rates and release durations) used in the accident analyses.

The VLS hydrogen ignition subsystem does not interface with/affect safety-related equipment or a fission product barrier. The subsystem is provided to address the production of hydrogen following a beyond design basis accident in accordance with 10 CFR 50.44(c). The hydrogen ignition subsystem is a non-Class 1E subsystem and does not interface with any safety-related system; thus, no safety system or safety design function or safety-related equipment qualification is affected by the proposed changes. The changes do not result in a new failure mode, malfunction or sequence of events that could affect a radioactive material barrier or safety-related equipment. The proposed changes do not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures.

Page 11 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

The VLS hydrogen ignition subsystem will continue to perform its beyond design basis function as defined in the UFSAR. The hydrogen ignition subsystem does not affect safety-related equipment or equipment whose failure could initiate an accident. The changes do not involve safety-related equipment or a radioactive material barrier. The proposed changes do not affect any safety-related equipment, design code limit (allowable value), safety-related function or design analysis, nor do they adversely affect any safety analysis input or result, or design/safety margin.

The PRA insights that informed UFSAR Section 16.3, "Investment Protection," are not affected by the relocation of the Hydrogen Igniters and the clarification of their locations in the UFSAR.

B. Equipment Survivability, Thermal Lag Assessment This portion of the license amendment request includes changes related to the Equipment Survivability to:

1) Relocate and revise the referenced equipment lists in COL Condition 2.D.(12)(g)9; and

2) Consolidate Thermal Lag Assessment requirements of ITAAC 2.2.03.09c into COL Condition 2.D.(12)(g)9.

Safety-related equipment must perform its function within the environmental conditions associated with design basis accidents. Equipment qualification (EQ) demonstrates the availability of safety-related equipment within the design basis accident (DBA) environmental conditions. Some of the equipment in the containment may be used to mitigate a severe accident and establish a controlled, stable state. The environmental conditions resulting from severe accidents are more limiting than those associated with design basis events. Equipment survivability is the assessment of the equipment to perform its function in the severe accident environment.

During the burning of a combustible gas mixture, an SSC temperature will lag behind the gas temperature, such that the peak temperature of the SSC will be lower than the peak temperature of the burning gases. To demonstrate survivability of the SSC, the temperature peak can be compared to known acceptance criteria for the equipment, such as the equipment qualification peak and long-term temperatures. A thermal lag assessment calculates the peak SSC temperature compared to established acceptance criteria and is used to show reasonable assurance of survivability for essential equipment used in severe accident management.

Severe accident management guidance (SAMG) and emergency operating procedures (EOP) were reviewed to determine which SSCs were necessary to mitigate a severe accident and establish a controlled, stable state to protect the integrity of the containment pressure boundary.

The conditions for a controlled, stable state, defined by the SAMG are: 1) to return the core to a controlled, stable state, 2) to maintain or return the containment to a controlled, stable state, and

3) to terminate fission product releases from the plant.

A severe accident equipment survivability thermal lag analysis was performed on required equipment to close open items in Technical Report (TR-068), APP-GW-GLR-069, Attachment A.

Attachment A of APP-GW-GLR-069 is APP-GW-VP-025, Rev. 0. This analysis document was referenced in the approved Design Control Document (Revision 19) as part of a Combined License Information item in Subsection 19.59.10.5 which was the basis for the COL Condition 2.D.(12)(g)9. A recent revision of the equipment survivability assessment closes the Page 12 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) following open items listed in APP-GW-GLR-069:

Item Number Description Status Open Item 1 Two of the documents referenced in Closed. The open item identified that the AP1000 Equipment Reference 11, APP-GW-GJR-400, Survivability Assessment are not Rev. A, AP1000 Severe Accident final and are not of numerical Management Guidelines, Volume 1 revisions. Final assessment report and Reference 13, APP-GW-VPD-will only refer to references with 001, Rev. A, Equipment & Component numeric revisions and applicable at Qualification Datasheet, were not the time of issuing the final numeric (final) versions. The assessment report. This open item references used in the report are now will be removed upon completion of numeric (final) versions. The the equipment survivability equipment lists in the proposed Tables assessment in a new revision of this 19D-8 and 19D-9 reflect the use of final report. versions of references.

Open Item 2 Tables 6a, 6b and 6c in the AP1000 Closed. A review of the equipment Equipment Survivability tables was performed and reflected in Assessment report are compiled the revised APP-GW-VP-025.

based on the current AP1000 plant design. The equipment listed in these tables will be reviewed and revised to reflect the final AP1000 plant design prior to plants installation. This open item will be removed upon completion of the equipment survivability assessment in a new revision of this report.

Open Item 3 The thermal lag assessment of the Closed. The thermal lag analysis is as-built equipment required to provided in the revised APP-GW-VP-mitigate severe accident (hydrogen 025.

igniters and containment penetrations) that has not been tested to severe accident conditions will be performed prior to fuel load.

Open Item 4 Thermal hydraulic environments Closed. The conclusions of the included in AP1000 Equipment revised APP-GW-VP-025 did not Survivability Assessment will be change.

compared with environments included in PRA report to confirm that existing assessment continued to be valid.

In addition to the open items associated with the survivability assessment, there were two open items related to DCD Chapter 19 Appendix D markups in Attachment B of APP-GW-GLR-069.

Attachment B of APP-GW-GLR-069 is APP-GW-VPC-020, AP1000 DCD Chapter 19 Appendix D Markup, Rev. 0.

Page 13 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

This LAR closes the following Open Items associated with the DCD Chapter 19 Appendix D Markup:

Open Item 1. Identification of equipment and Closed. The equipment survivability instrumentation for prevention of assessment used the completed EOPs core damage (e.g., Time Frame 0 to identify and consider for equipment (T0) and Time Frame 1 (T1)) was survivability assessment. The not completed because the equipment lists in the proposed Tables Emergency Operating Procedures 19D-8 and 19D-9 reflect this (EOPs) are still in development. equipment.

Upon finalization of the EOPs, the equipment and instrumentation used in those procedures can be identified and considered for equipment survivability assessments. This open item will be removed upon completion of a review of the equipment and instrumentation following completion of the EOP development.

Open Item 2. The Structure, System and Closed. Specifying that the thermal lag Components (SSCs) required for assessment is performed on the hatch containment isolation are not seals and adding the hatch seals to the completely identified. It has been equipment list is the result of response determined that a survivability to OI-SRP19.0-SPLA-14 R1 [ADAMS assessment is required for Accession Number ML092530405]

environment electrical penetrations, as identified in the DCD mark-up.

However, it has not been determined whether mechanical penetrations and hatches (e.g.,

gasket materials) also need to be included in the environmental assessment to ensure containment integrity.

B.1) Relocate and revise the referenced equipment lists in COL Condition 2.D.(12)(g)9 COL Condition 2.D.(12)(g)9, currently refers to Tables 6b and 6c in Attachment A of APP-GW-GLR-069, Equipment Survivability Assessment. Attachment A of APP-GW-GLR-069 is APP-GW-VP-025, AP1000 Equipment Survivability Assessment, and is the basis for UFSAR Table 19D-8 and Table 19D-9 which are proposed to replace the referenced tables from APP-GW-GLR-069 in this License Condition. To complete License Condition 2.D.(12)(g)9, completion of the thermal lag assessment must be documented. This activity proposes to add UFSAR Tables 19D-8, "Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location," and 19D-9, "Equipment Located Inside Containment (Time Frames T2 and T3) Equipment, Action Time Frame, and Equipment Location,"

to UFSAR Appendix 19D. Tables 19D-8 and 19D-9 are derived from a recent revision of APP-GW-VP-025, Tables 6b and 6c. UFSAR Subsection 19.59.10.5, which describes the thermal Page 14 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) lag assessment, does not have a reference to the thermal lag assessment documentation.

APP-GW-GLR-069 is currently identified in UFSAR Subsection 19.59.11 as a reference but the reference is not used in the UFSAR. This activity deletes APP-GW-GLR-069 from the references in UFSAR Subsection 19.59.11.

The proposed addition of Tables 19D-8 and 19D-9 requires adding new subsections to Appendix 19D reflecting additional equipment categories for the containment hatch seals and the containment vessel, which were added to the equipment survivability assessment Tables 6b and 6c. The new Appendix 19D subsections require renumbering UFSAR Appendix 19D Subsection 19D.8.2.14. The proposed addition of the containment hatch seals requires adding containment hatches (gasket material only) to the equipment identified in UFSAR Tables 19D-3, 19D-4, and 19D-5 to reflect the addition of the hatches' gasket material to the list of equipment in operation in severe accident Time Frames 1, 2 and 3, respectively; and to maintain consistency with the revised equipment lists in the equipment survivability assessment in Tables 19D-8 and 19D-9 as well as the new Appendix 19D subsections.

It is also proposed to remove "as-built" from the License Condition and from UFSAR Subsection 19.59.10.5. The thermal lag assessment was performed and completed on the design locations of the equipment in the equipment list. Requiring the equipment to be in place, i.e.,

as-built, is not necessary for satisfactory completion of the thermal lag assessment.

B.1)a Replace COL Condition with UFSAR Appendix 19D Tables COL Condition 2.D.(12)(g)9, states, "Perform a thermal lag assessment of the as-built equipment listed in Tables 6b and 6c in Attachment A of APP-GW-GLR-069, Equipment Survivability Assessment, to provide additional assurance that this equipment can perform its severe accident functions during environmental conditions resulting from hydrogen burns associated with severe accidents." APP-GW-GLR-069 "Equipment Survivability Assessment" Attachment A, is APP-GW-VP-025 Rev. 0, "AP1000 Equipment Survivability Assessment." The proposed change is to replace APP-GW-GLR-069 in the License Condition with UFSAR Table 19D-8, "Equipment Located Inside Containment (Time Frames T0 and T1) Equipment, Action Time Frame, and Equipment Location," and UFSAR Table 19D-9, "Equipment Located Inside Containment (Time Frames T2 and T3) Equipment, Action Time Frame, and Equipment Location," proposed for addition to UFSAR Appendix 19D. UFSAR Tables 19D-8 and 19D-9 are derived from revised APP-GW-VP-025, Tables 6b and 6c. The revised APP-GW-VP-025 reflects changes to the equipment as design is made final and construction continues. This reference in the License Condition would be changed to state that the thermal lag assessment is performed on the equipment listed in UFSAR Tables 19D-8 and 19D-9. The change is necessary to reflect new equipment (added to Tables 6b and 6c of APP-GW-VP-025) on which the equipment survivability assessment is analyzed.

The performance of the thermal lag assessment is not changed by this amendment request. The change is to the list of equipment in Tables 6b and 6c of APP-GW-VP-025 and by derivation, the equipment listed in proposed UFSAR Tables 19D-8 and 19D-9. No design function of an SSC is changed and there are no adverse effects on any SSC.

B.1)b Add UFSAR Tables 19D-8 and 19D-9 to UFSAR Appendix 19D This amendment proposes to add UFSAR Tables 19D-8, "Equipment Located Inside Containment (Time Frames T0 and T1)," and 19D-9, "Equipment Located Inside Containment (Time Frames T2 and T3)," to UFSAR Appendix 19D. Tables 19D-8 and 19D-9 are derived from the revised APP-GW-VP-025 Tables 6b and 6c, respectively, and include the technical information from the tables. The proposed addition of UFSAR Tables 19D-8 and 19D-9 requires changing UFSAR Page 15 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Subsection 19D.8.2, to refer to Table 19D-8 for the specific equipment located inside containment which must survive a severe accident for Time Frames T0 and T1, and to Table 19D-9 for Time Frames T2 and T3.

Table 19D-8 lists the equipment located inside containment and the functions performed by this equipment during equipment survivability time frames T0 (Pre-Core Uncovery) and T1 (Core Heatup) of a severe accident. Equipment is identified by equipment tag number, description, the time frames and actions taken for severe accident management, the room number in which the equipment is located, minimum channels/divisions desired, and the severe accident management function of the equipment.

Table 19D-9 lists the equipment located inside containment and the functions performed by this equipment during equipment survivability time frames T2 (In-Vessel Core Melting and Relocation) and T3 (Ex-Vessel Core Relocation) of a severe accident. Equipment is identified by equipment tag number, description, the time frames and actions taken for severe accident management, the room number in which the equipment is located, minimum channels/divisions desired, and the severe accident management function of the equipment. Equipment survivability time frames and actions are further defined in UFSAR Subsections 19D.4 and 19D.6.

Adding UFSAR Tables 19D-8 and 19D-9 to UFSAR Appendix 19D incorporates changes to the containment sampling function on which the thermal lag assessment is performed. The description of the containment atmosphere sampling function is changed to reflect the design described in UFSAR subsection 9.3.3.1.2.2, to provide details of the design function, and to clarify the differentiation between the containment atmosphere sampling function and the containment liquid sampling function to UFSAR Subsections 19D.6.2.10, Accident Monitoring, and 19D.6.3.10, Accident Monitoring.

The containment atmosphere sampling function requires operating containment atmosphere sampling isolation valves and the containment liquid sampling function requires operating reactor coolant hot leg sample isolation valves. The containment sample isolation valves for liquid and atmosphere sampling are identified in UFSAR Tables 3.2-3 and Tier 1 Table 2.2.3-6 and shown in UFSAR Figure 9.3.3-1 and Tier 1 Figure 2.3.13-1. The change also adds the containment liquid sampling function and a description of the function.

UFSAR Subsection 19.D.6.2, Time Frame T2 - In-Vessel Core Melting and Relocation, provides details about equipment functions for the period of core melting, relocation and entry into the severe accident management guidance (SAMG). UFSAR Subsection 19D.6.2.10, Accident Monitoring, describes the equipment and functions used throughout Time Frame T2. The proposed change adds the containment liquid sampling function to UFSAR Subsection 19D.6.2.10 to clarify that the functions are containment atmosphere and containment liquid sampling used during accident monitoring of the containment environment. UFSAR Subsection 19D.6.3.10, Accident Monitoring, describes the equipment functions used during Time Frame T3, Ex-Vessel Core Relocation. The proposed change adds the containment liquid sampling function to UFSAR Subsection 19D.6.3.10 to clarify that the functions are containment atmosphere and containment liquid sampling used during accident monitoring of the containment environment.

UFSAR Table 19D-3 includes equipment and instrumentation operation during Time Frames T0 and T1 - pre-core uncovery and heatup, and is prior to the release of significant quantities of hydrogen. The containment liquid sampling function is available prior to the end of Time Frame T1 in the equipment survivability assessment and is added instrumentation to UFSAR Table 19D-3.

UFSAR Table 19D-4 includes equipment and instrumentation operation during Time Frame T2 -

In-Vessel Core Melting and Relocation. The containment liquid sampling function is available prior to the end of Time Frame T2 in the equipment survivability assessment and is added Page 16 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) instrumentation to UFSAR Table 19D-4. UFSAR Table 19D-5 includes equipment and instrumentation operation during Time Frame T3 - Ex-Vessel Core Relocation. The containment liquid sampling function is available prior to the end of Time Frame T3 in the equipment survivability assessment and is added instrumentation to UFSAR Table 19D-5.

The change also affects UFSAR Table 19D-7, which lists the equipment on which the survivability assessment is performed, to reflect that the containment liquid and containment atmosphere sampling are different sampling functions. The survivability assessment results and discussions for the two sampling functions are added to Table 19D-7, as well. The changes reflect defining the containment liquid sampling function and including the function in the assessment. The changes are not changes to the design function of the containment liquid or atmosphere sampling functions. The changes are to the descriptions of the functions on which the sustained hydrogen combustion survivability assessment is analyzed and the results of the assessment. There is no adverse effect on the ability to sample containment liquid or atmosphere, the change is to the assessment of the function.

Identification of Equipment for Equipment Survivability Analysis The severe accident management guidance (SAMG) was used as a basis to identify the equipment that would be used during and following a severe accident to mitigate the accident and monitor plant conditions. The identified equipment is listed in APP-GW-VP-025 Tables 6b and 6c and proposed UFSAR Tables 19D-8 and 19D-9.

The approach to this systematic evaluation of equipment, addressing its survivability for intervening in a severe accident, is by identification of the equipment type, equipment location, survival time required, and the use of design basis event qualification requirements and severe environment calculated conditions and experimental data.

The methodology used to demonstrate equipment survivability is to:

a) Identify the high-level actions from SAMGs used to achieve a controlled, stable state b) Define the accident Time Frames for each high-level action c) Determine the equipment used to diagnose, perform and verify SAMG high-level actions in each Time Frame d) Determine the severe accident environment within each Time Frame e) Demonstrate with reasonable assurance that the equipment will survive to perform its intended function within the severe environment.

Reasonable assurance of survivability can be demonstrated by one or more of the following:

• Showing the SSCs complete their function reasonably within their EQ envelope before they are challenged by the severe environment.

• Showing the SSC is redundant or diversely backed up by a SSC performing a similar function.

• Showing the SSC is designed for the severe conditions it will experience.

• Performing best estimate analysis showing that the SSC is able to withstand the severe conditions they will experience.

Thermal Lag Analyses for Equipment Survivability The Modular Accident Analysis Program (MAAP) 4.0.7 code is used to analyze severe accident Page 17 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) environments associated with hydrogen combustion during a severe accident in the AP1000 containment. Within the MAAP4 analyses, one-dimensional lumped capacity heat sink models of equipment are used to evaluate the thermal lag temperature response of the selected SSCs to the severe accident environments and to screen the equipment response for detailed equipment survivability analysis. The lumped heat sinks temperature response will bound the internal temperature of the equipment and provide reasonable assurance of survivability for equipment whose temperature does not exceed a specified acceptance criterion for survivability. If equipment surface temperatures exceed the temperature limit criterion in the MAAP4 analyses, the analyses can be used to identify equipment and conditions that need to be modeled in more detail (for example, a computational fluid dynamic analysis or a 3-dimensional heat transfer analysis) or need to be modified to assure survivability.

Tables 6b and 6c of APP-GW-VP-025 list the equipment on which the thermal lag assessment is performed to satisfy License Condition 2.D.(12)(g)9 for the equipment survivability analysis and required for closure of ITAAC 2.2.03.09c. The change from the referenced APP-GW-GLR-069 tables to UFSAR Tables 19D-8 and 19D-9 reconciles the list of equipment on which the thermal lag assessment is performed with the equipment required to mitigate severe accidents (hydrogen igniters and containment penetrations). The thermal lag assessment is performed to confirm that this equipment can perform its severe accident functions during environmental conditions resulting from hydrogen burns associated with severe accidents.

To complete the addition of Tables 19D-8 and 19D-9, the name of UFSAR Subsection 19D.8.2.6, Solenoid Valve, is changed to "Solenoid-Operated Valves (SOVs) and Air-Operated Valves (AOVs)." This change makes the subsection title consistent with the subject matter of the subsection and consistent with the category in Tables 19D-8 and 19D-9, as well as the category in APP-GW-VP-025, Tables 6b and 6c. New UFSAR Subsections 19D.8.2.14, Containment Hatches (Gasket Material Only), and 19D.8.2.15, Containment Shell, are proposed, to discuss the assessment of the hatch gasket material and containment shell, which are listed in proposed UFSAR Tables 19D-8 and 19D-9. Containment hatches (gasket material only) is proposed to be added to the equipment identified in UFSAR Tables 19D-3, 19D-4, and 19D-5 to reflect the addition of the hatches' gasket material to the list of equipment in operation in severe accident Time Frames 1, 2 and 3, respectively; and to maintain consistency with the equipment listed in the equipment survivability analysis in Tables 19D-8 and 19D-9 as well as new UFSAR Subsection 19D.8.2.14. Former UFSAR Subsection 19D.8.2.14, Assessment of Equipment for Sustained Burning, is renumbered to Subsection 19D.8.2.16.

These changes do not affect the design or design function of any SSC. The performance of the thermal lag assessment is not modified by these changes. The change is to the list of equipment in Tables 6b and 6c of APP-GW-VP-025 and reflected in UFSAR Tables 19D-8 and 19D-9. No design function of an SSC is changed as the tables reflect the current design and there are no adverse effects on an SSC.

B.1)c Removal of as-built to describe the equipment to be assessed It is also proposed to remove "as-built" from the License Condition and from UFSAR Subsection 19.59.10.5. The thermal lag assessment is performed on the design locations of the equipment in the equipment list. Requiring the equipment to be in place is not necessary for satisfactory completion of the thermal lag assessment. However, including the listing of the equipment and locations in the UFSAR (as Tables 19D-8 and 19D-9) requires that appropriate evaluations of impact on the completed assessment be performed should there be any future changes to equipment. Additionally, for hydrogen igniters, COL Appendix C Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) 2.3.09.03.i, Acceptance Criteria, requires that "at Page 18 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) least 66 hydrogen igniters are provided inside containment at the locations specified in Table 2.3.9-2." COL Appendix C Table 2.3.9-2 lists the 66 hydrogen igniters, their function, location, and room number.

B.1)d Revision of the list of equipment to be assessed To support the incorporation of proposed Tables 19D-8 and 19D-9 in UFSAR Appendix 19D, comparison of the changes to the information in APP-GW-VP-025, Tables 6b and 6c, Rev. 0 (cited in COL Condition 2.D.(12)(g)9) and proposed Tables 19D-8 and 19D-9 is also presented.

Significant changes to the Tables 6b and 6c lists of equipment in APP-GW-VP-025 Revision 0 are shown below in Table B-1 (Changes to VP-025 Rev. 0, Table 6b) and Table B-2 (Changes to VP-025 Rev. 0, Table 6c). Table B-1 lists equipment that performs prior to cladding oxidation and therefore, is within the design basis equipment qualification envelope. Table B-2 lists equipment subjected to the harsh environment following core damage.

As the design of the AP1000 progressed, equipment that was added to the design was evaluated and included in, or removed from, the equipment survivability and/or thermal lag assessments as determined using the AOPs and SAMGs. Additionally, APP-GW-VP-025 was revised and restructured. Other global changes (not addressed in the Tables B-1 and B-2 below on an individual change basis) to Tables 6b and 6c are:

• Section numbers were replaced with UFSAR section numbers that discuss the equipment type. Section numbers are shown in Tables B-1 and B-2, below, only where the section heading also changes to lessen the chance for confusion. Some section headings or subheadings are included to show changes in equipment types. These changes are administrative to reflect the format of the proposed tables. The changes to the section numbers do not involve a change to the design or design function of an SSC, or a change to the assessment methodology. These changes are shown on an individual basis in Enclosure 3.

• Required channels/divisions for the equipment listed was added to the proposed tables to specify to what extent equipment is needed for severe accident management. This information is derived from the licensing basis and the SAMG/AOP requirements. Table 6b (proposed Table 19D-8) lists equipment that performs prior to cladding oxidation and therefore is within the design basis equipment qualification envelope. Table 6c (proposed Table 19D-9) lists equipment that performs after cladding oxidation and fuel damage, which is beyond design basis. Therefore, only one channel of each instrumentation parameter is required to be available. However, it is preferred to have more than one channel of each parameter available to resolve information ambiguity. The required channels/divisions for core exit thermocouples (CETs) and hydrogen igniters are further described in notes for the proposed tables. Required channels/divisions reflect that which was modeled in the equipment survivability assessment and is not a change to the design or design function of any SSC required for design basis accident functions.

• The building location changed for CETs. CETs are located inside the reactor pressure vessel (RPV) which is in Room Number 11105 (reactor cavity). The building location designations were C-D0 and C-E0 for CETs which correspond to 11400 (maintenance floor mezzanine) and 11500 (operating floor). Note 2 is added to the proposed tables explaining the CET locations. The CETs are exposed to the reactor coolant system environment and not the environment of the reactor cavity. The change is not an actual relocation of the CETs.

• Other building locations listed using the "C-XY" format of APP-GW-VP-025, Rev. 0 were replaced with room numbers. The building location annotation required a key to understand, Page 19 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) and was only used in APP-GW-VP-025. Explanation is provided for instances where the equipment location is actually changed in addition to the designation. Hydrogen Igniter room numbers can now be readily identified as consistent with those provided in Tier 1 Table 2.3.9-7 and throughout the UFSAR.

The equipment on the equipment lists is inside containment. Because of the imprecise nature with respect to elevations annotated by building locations and room numbers, the following key is provided for reference:

APP-GW-VP-025 Format (C-XY) AP1000 Standard Nomenclature (BBLXX)

"X" Designation Elevation "L" Designation Elevation A 66'-6" 1 71'-6" B 82'-6" & 96'-6" 2 84'-6" C 107'-2" 3 107'-2" D 117'-6" 4 118'-6" E 135'-3" 5 135'-3" F 153' & 160'-6" 6 162'-1" G 160'-3" & 180' 7 226'-6" H 233' & 258' 8 N/A For example:

Building Location Comparison Equip. Tag No. Description VP-025 Rev. 0 (C-XY) VP-025 Rev. 3 (BBLXX)

PXS-PL-V014A CMT A Discharge Isolation C-B6 11206 The C-B6 designations translate to:

C = inside containment; B = elevation = 82'-6" & 96'-6"; and 6 = the last digit of the room number for the respective elevation The 11206 designations translate to:

The first two digits = Building number = 11 = Containment The third digit = Level = 2 = 84'-6" and the final two digits = Room No. = 06 Severe Accident Time frames shown or discussed in Tables B-1 and B-2 are:

Time Frame 0 (T0) - Pre-Core Uncovery Time Frame 1 (T1) - Core Heatup Time Frame 2 (T2) - In-Vessel Severe Time Frame 3 (T3) - Ex-Vessel Severe Accident Phase Accident Phase Exceptions to the above global change categories are explained in Tables B-1 and B-2 below using redline strikeout for deletions and blue underline for additions. Both the significant changes and the global changes are shown in Enclosure 3 as a Reviewers Aid.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Table B Description of Changes to APP-GW-VP-025 Table 6b: Equipment Located Inside Containment (Time Frames T0 and T1)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions Equipment Removed from Table 6b Differential Pressure and Pressure Transmitters The IRWST Wide Range Level Instruments only requires three channels to support PAMS requirements established in UFSAR Table 7.5-1. Two channels are required to monitor stable plant conditions, and the third IRWST Level Not applicable Not applicable (SSC channel is to resolve information ambiguity if necessary.

PXS-JE-LT045 Transmitter (SSC is removed) is removed) PXS-JE-LT046, 047, 048 provide the necessary function to sense IRWST water level for Time Frame 1 (T1) actions in UFSAR Table 19D-3. Therefore PXS-JE-LT045 (which is powered by PMS Division A) is not required and was removed from the design.

Equipment Revised or Added to Table 6b 8.1.1.2 RCS Pressure T0, T1-A1,A4,A10 C-B4,C-B6 RCS pressure transmitter's channels A & C are located RCS Wide Range RCS-JE-PT140A No change C- B4 11300 on the maintenance floor (11300). Designation C-B4 Pressure Trans. A corresponds to the vertical access (11204).

RCS pressure transmitter's channels A & C are located RCS Wide Range RCS-JE-PT140C No change C- B4 11300 on the maintenance floor (11300). Designation C-B4 Pressure Trans. C corresponds to the vertical access (11204).

Core-exit Temperature Core-exit Thermocouple IIS-JE-TE-042 was omitted from Core-exit Rev. 0 of Table 6b. TE-042 is a safety-related IIS-JE-TE042 Thermocouple No change 11105 thermocouple, qualified for T0 and T1 phases of the P09 severe accident by the equipment qualification criteria for the thermocouple.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions Resistance Temperature Detectors (RTDs)

IRWST Water PXS-JE-TE041 No change C-C0 11300, 11305 Temperature IRWST Water PXS-JE-TE042 No change C-C0 11300, 11305 IRWST temperature elements are located inside the Temperature IRWST (room 11305). Electronics of RTD are located in IRWST Water the maintenance floor Room 11300 (designation C-C0).

PXS-JE-TE043 No change C-C0 11300, 11305 Temperature IRWST Water PXS-JE-TE044 No change C-C0 11300, 11305 Temperature Hydrogen Monitors APP-Hydrogen Monitor No change C-H1 11500 VLS-JE-AE001 Tag numbers revised to be consistent with AP1000 equipment numbering nomenclature. Hydrogen sensors APP-Hydrogen Monitor No change C-H1 11500 are located in Room 11500 (upper compartment) at VLS-JE-AE002 258'-0". Designation C-H1 corresponds to elevation 233' APP- or 258' room 1 which does not exist.

Hydrogen Monitor No change C-H1 11500 VLS-JE-AE003 PXS Radiation Monitors Containment PXS-JE-RE160 Radiation No change C-G3 11500 Detector A Radiation monitors are located in Room 11500 Containment (operating deck). Designation C-G3 corresponds to an PXS-JE-RE161 Radiation No change C-G3 11500 area between elevations 160'-3" and 180'-0" Room 3 Detector B which are 11703 and 11603 (upper and lower ADS valve areas).

Containment PXS-JE-RE162 Radiation No change C-G3 11500 Detector C Page 22 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions Containment PXS-JE-RE163 Radiation No change C-G3 11500 Detector D Solenoid-Operated Valves (SOVs) and-Vent Air-Operated The section title was changed to clarify the valves are 8.1.6 Valves (AOVs) solenoid or air-operated valves, and not vent air valves.

Containment The section title was changed to include solenoid-8.1.6.3 Isolation AOVs T1-A7 C-B8,C-C0,C-D0,E0 operated valves.

and SOVs Large-scale hydrogen burning equipment testing conducted by EPRI (EPRI NP-4354) documents Containment successful solenoid valve performance during multiple Atmosphere PSS-PL-V024 11400 hydrogen burning temperature transients with acceptable Sample Return results and provides supplemental assurance of the Isolation survivability of this equipment. PPS-PL-V024 was added after review of SAMG/AOP.

Containment Sampling Function The section number was changed due to restructuring Containment APP-GW-VP-025. The section title was changed to Atmosphere 8.1.6.6 T0,T1-A8,A10 C-D0 clarify this section describes the containment sampling Sampling function, not only containment atmosphere sampling Function function.

Hot Leg Sample PSS-PL V001A/B A10 11300 Isol Valves Liquid Sample Action A8 is Hydrogen Control and Action 10 is Accident PSS-PL-V010A/B A10 11400 Monitoring.

Cont Isol Valves Large-scale hydrogen burning equipment testing Containment Air conducted by EPRI (EPRI NP-4354) documents PSS-PL-V008 Sample Cont. A8, A10 C-D0 11400 successful solenoid valve performance during multiple Isolation Valve hydrogen burning temperature transients with acceptable Page 23 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions results and provides supplemental assurance of the survivability of this equipment The containment sampling function requires use of these valves, is performed through Time Frame T3, and is used to back up other functions such as hydrogen monitoring. Thermal lag analysis is performed to justify reasonable assurance of survivability of these valves.

Containment The Containment Atmosphere Sampling Function is used Atmosphere for severe accident hydrogen control and accident PSS-PL-V024 A8, A10 11400 Sample Return monitoring.

Isolation Valve Throughout Time Frames T0 through T3, access to the containment environment from the hot leg and containment atmosphere sampling function is through solenoid valves located in the maintenance floor. During the early time frames of the accident scenario, they will not be energized, but they must survive through Time Frame T3 (ex-vessel conditions) to perform their function Action A10 is Accident Monitoring.

Containment The valve is not essential for an equipment survivability PSS-PL-V002 Sump Sample A10 11400 standpoint, but is considered a benefit as a backup to the Isolation Valve RCS hot leg sample points and included in the survivability thermal lag analysis.

Reactor Vessel Head Vent SOVs Reactor Vessel Head Vent SOVs T1-A4 Reactor Vessel The head vents appear in the severe accident guide for RCS-PL-V150A 11601 Head Vent RCS depressurization. This action is not specifically Reactor Vessel modelled in the PRA nor does it protect containment RCS-PL-V150B 11601 integrity. Therefore, they are beneficial, not essential.

Head Vent Reasonable assurance of survivability for beneficial Reactor Vessel SOVs is provided by the EPRI Hydrogen Burn RCS-PL-V150C 11601 Head Vent Equipment Testing (EPRI NP 4354) that demonstrated Page 24 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions that several types of similar SOVs survived multiple hydrogen burn tests.

The reactor vessel head vent SOVs do not require a detailed analysis as the SOVs are beneficial, but are not Reactor Vessel credited in the level 2 PRA nor are they essential for RCS-PL-V150D 11601 Head Vent maintaining containment integrity. In addition, from the results of EPRI NP 4354 it is sufficient to justify reasonable assurance of survivability. The RCS valves are added per review of severe accident management guidance for depressurizing the RCS.

ADS Stages 1, 2 C-D1,C-D2,C-F3,C-8.1.7.4 T1-A4 3, & 4 MOVs G3 Fourth Stage ADS RCS-PL-V014A No change C-D1 11301 MOV Fourth Stage ADS The ADS stage 4 MOVs are located in Rooms11301 and RCS-PL-V014B No change C-D2 11302 11302 (SG compt. lower manway areas). The MOV designations C-D1 and C-D2 correspond to 11401 and Fourth Stage ADS 11402, which is an elevation higher than 11301 and RCS-PL-V014C No change C-D1 11301 MOV 11302.

Fourth Stage ADS RCS-PL-V014D No change C-D2 11302 MOV RNS IRWST Removed "IRWST" from the section name as not all the 8.1.7.7 T1-A1 C-B6, C-B8 MOVs valves are associated with the IRWST.

RNS Suction Isol Meets design basis criteria. The RNS suction line MOVs RNS-PL-V001A/B No change 11208 from Hot Leg do not require a detailed analysis. The MOVs are located Page 25 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions in dead-ended compartment below Room 11300 floor that does not typically experience direct hydrogen burning. If there is a direct vessel injection line break in the PXS compartment, the compartment will flood with water when the PXS injection squib valves actuate and the valves are not qualified to be submerged. However, in this case, the RCS will reflood through the break and RNS Suction Isol the RNS valves will not be required to operate. The RNS-PL-V002A/B No change 11208 from Hot Leg MOVs are beneficial, but are not credited in the level 2 PRA nor are they essential for maintaining containment integrity. In addition, from the results of EPRI NP 4354 it is sufficient to justify reasonable assurance of survivability. The RNS valves are added per review of severe accident management guidance for injecting water into the RCS.

8.1.8.1 IRWST Injection T1-A2 C-B6, C-B7 IRWST Injection A PXS-PL-V123A Isolation Line A No change C-B6 11206 Squib Valve IRWST Injection A PXS-PL-V125A Isolation Line A No change C-B6 11206 Squib Valve Changed the equipment description from isolation to Squib to clarify the valve is a Squib valve as well as an IRWST Injection B isolation valve.

PXS-PL-V123B Isolation Line B No change C-B7 11207 Squib Valve IRWST Injection B PXS-PL-V125B Isolation Line B No change C-B7 11207 Squib Valve Page 26 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions PXS 8.1.8.2 Containment T1-A2 C-B6,C-B7 Recirculation Cont.

Recirculation A PXS-PL-V118A No change C-B6 11206 Isolation Squib Valve Cont.

Recirculation A PXS-PL-V120A No change C-B6 11206 Isolation Squib Valve Changed the equipment description from isolation to Squib to clarify the valve is a Squib valve as well as an Cont. isolation valve.

Recirculation B PXS-PL-V118B No change C-B7 11207 Isolation Squib Valve Cont.

Recirculation B PXS-PL-V120B No change C-B7 11207 Isolation Squib Valve Valve Position Sensors Meets design basis criteria. Position sensors are required to monitor the position of containment isolation valves that could lead directly to an atmospheric release.

Containment These isolation valves actuate early in the transient, so Atmosphere PSS-PL-V024-L 11400 verification is only required during Time Frame T1. The Sample Return position sensors are located in the maintenance floor and Isolation the environment in this Time Frame does not exceed the design basis event qualification environment of the position sensors.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions Hydrogen Igniters Note 3 added with the new Required Channels/Divisions column states: "There are two groups of igniters. Each Hydrogen containment compartment and hydrogen pathway is 8.1.10 Igniters, T1-A8 See below covered by at least one igniter in each group. The Power Group minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway."

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-27 No change C-D0 11300 27, 1 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-30 No change C-D0 11403 30, 2 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-35 No change C-C5 11500 35, 1 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-36 No change C-C5 11500 36, 2 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-37 No change C-C5 11500 37, 1 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-38 No change C-G1 11500 38, 2 Description" of this LAR.

Hydrogen Igniter Hydrogen igniters 65 and 66 were added to containment VLS-EH-65 No change 11500 65, 1 near the exit of the IRWST roof vents 1 and 4 to provide igniter coverage close to source of hydrogen (the IRWST). SNC LAR-15-003, approved as License Amendment number 61 for VEGP 3&4, added the Hydrogen Igniter igniters to the scope of equipment in COL Appendix C VLS-EH-66 No change 11500 66, 2 Table 2.2.3-6 and ITAAC No. 2.2.03.09.c. Hydrogen igniters 65 and 66 were included in the equipment survivability analysis to fulfill ITAAC No. 2.2.03.09c.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions Electrical Containment Penetration Assemblies Electrical Containment 8.1.11 T1-A7 C-C0,C-D0,C-C6 Penetration Assemblies Electrical The electrical containment penetrations are located in ECS-EY-P07X No change 11400 Penetration P07 the lower compartment and are required to perform both electrically (conduct current for sensors and igniters) and Electrical mechanically (including maintaining containment ECS-EY-P17X No change 11300 Penetration P17 pressure boundaries) throughout the severe accident.

Electrical Electrical Penetrations P07, P17, P19 and P20 are listed ECS-EY-P19Z No change 11300 Penetration P19 in COL Appendix C Tables 2.2.1-1 and 2.2.3-6 but were not in APP-GW-VP-025, Rev. 0 Tables 6b or 6c. They Electrical were added to Tables 6b and 6c to provide consistency ECS-EY-P20Z No change 11300 between the electrical penetrations listed in APP-GW-Penetration P20 VP-025 with COL Appendix C Tables.

This penetration is located on the maintenance floor mezzanine (11400). Designation C-C6 corresponds to ECS 1E Electrical No change C-C6 11400 the IDS Division B & D penetration room (11306). The IDSA-EY-P11Z Penetration P11 tag number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor mezzanine (11400). Designation C-C6 corresponds to ECS 1E Electrical No change C-C6 11400 the IDS Division B & D penetration room (11306). The IDSA-EY-P12Y Penetration P12 tag number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor mezzanine (11400). Designation C-C6 corresponds to ECS 1E Electrical No change C-C6 11400 the IDS Division B & D penetration room (11306). The IDSA-EY-P13Y Penetration P13 tag number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions ECS 1E Electrical The tag number change is made to be consistent with No change C-C6 11306 IDSD-EY-P14Z Penetration P14 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with No change C-C6 11306 IDSD-EY-P15Y Penetration P15 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with No change C-C6 11306 IDSD-EY-P16Y Penetration P16 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor (11300). Designation C-C6 corresponds to the IDS ECS 1E Electrical No change C-C6 11300 Division B & D penetration room (11306). The tag IDSC-EY-P27Z Penetration P27 number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor (11300). Designation C-C6 corresponds to the IDS ECS 1E Electrical No change C-C6 11300 Division B & D penetration room (11306). The tag IDSC-EY-P28Y Penetration P28 number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor (11300). Designation C-C6 corresponds to the IDS ECS 1E Electrical No change C-C6 11300 Division B & D penetration room (11306). The tag IDSC-EY-P29Y Penetration P29 number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with No change C-C6 11300 IDSB-EY-P30Z Penetration P30 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with No change C-C6 11300 IDSB-EY-P31Y Penetration P31 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with No change C-C6 11300 IDSB-EY-P32Y Penetration P32 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions Penetration tag is made consistent with the standard plant design. This penetration is located on the maintenance floor (11300). Designation C-C6 ECS 1E Electrical No change C-C6 11300 corresponds to the IDS Division B & D penetration room EDS-EY-P21Z Penetration P21 (11306). Note the "1E" designation is removed consistent with COL Appendix C Table 2.2.1-1. EDS is a non-1E system.

PXS Containment Water Level Containment Containment Floodup level instruments are level PXS-JE-LSLE050 No change C-A4 11104 Floodup Level transmitters not level switches and the change to the tag number is made to maintain consistency with the tag Containment PXS-JE-LSLE052 No change C-A4 11104 numbers used in UFSAR Tables 3.11-1 and 3I.6-2.

Floodup Level The level element (LE) is located in containment. The remote level transmitter (LT) is located in the auxiliary building. These transmitters are located in the RCDT Containment room (11104). The designation C-A5 for LE-051 PXS-JE-LSLE051 No change C-A5 11104 Floodup Level corresponds to the reactor cavity (11105). LE-051 is located in Room 11104.

Containment Hatches (Gasket Material Only)

Containment Hatches (Gasket T0,T1-A7 Material Only)

CNS-MY-Y01 Equipment Hatch 11500 The equipment hatch and a personnel hatch are located at the operating deck elevation. The maintenance hatch Maintenance CNS-MY-Y02 11300 and a second personnel hatch are located at the Hatch maintenance floor elevation.

Personnel Hatch Action A7 is containment isolation and venting. The CNS-MY-Y03 11500

- Upper gasket material of the hatches is required to perform Page 31 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T0,T1 and Building Location Discussion Tag No. Actions throughout the severe accident to maintain the containment pressure boundary.

Specifying that the thermal lag assessment is performed Personnel Hatch CNS-MY-Y04 11300 on the hatch seals and adding the hatch seals to APP-

- Lower GW-VP-025 Tables 6b and 6c is the result of response to OI-SRP19.0-SPLA-14 R1 [ADAMS accession number ML092530405]

Containment T0,T1-A7 Vessel The containment shell itself is part of the equipment survivability assessment and comprises the leak tight structure to which all containment penetrations seal.

Containment CNS-MV-01 Action A7 is "containment isolation and venting." The Shell containment shell is required to perform throughout the severe accident to maintain the containment pressure boundary.

Notes:

1. RTDs could fail as temperature exceeds the designed condition.

2. If device fails, monitoring can be made through the Cont. Atmosphere Sampling Function.

3. Valve is open and remains open.

4. See Section 8.1.7.8

5. Cables are located in most rooms inside containment Page 32 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Deletion of Notes in APP-GW-VP-025, Rev. 0 Table 6b Removed from Note Text Justification (6b Rev. 0, Section)

RTDs could fail as temperature exceeds the designed Redundant to information in UFSAR Note 1 8.1.3.1 condition. Subsection 19D.8.2.3.

If device fails, monitoring can be made through the Redundant to information in UFSAR Note 2 8.1.5 Cont. Atmosphere Sampling Function. Subsection 19D.8.2.5.

Redundant to information in UFSAR Note 3 Valve is open and remains open. 8.1.7.1; 8.1.7.3 Subsection 19D.8.2.7.

Redundant to information in UFSAR Note 4 See Section 8.1.7.8. 8.1.7.8 Subsection 19D.8.2.6.

Replaced by Note 1 in 19D.8.2.12, which Note 5 Cables are located in most rooms inside containment. 8.1.12 has the same information.

1. Cables are located in most rooms inside containment.

2. A channel consists of two thermocouples within a single division. Each quadrant contains two divisions. The minimum requirement is two OPERABLE thermocouples in each of the two divisions for each quadrant.

3. There are two groups of igniters. Each containment compartment and hydrogen pathway is covered by at least one igniter in each group. The minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway.

4. See Appendix 19D, Section 19D.4 for definitions of Equipment Survivability Time Frames T0 and T1.

5. See Appendix 19D, Section 19D.6 for Actions associated with Time Frames T0 and T1.

• A1 = Subsection 19D.6.1.1

• A2 = Subsection 19D.6.1.2

• A3 = Subsection 19D.6.1.3

• A4 = Subsection 19D.6.1.4

• A5 = Subsection 19D.6.1.5

• A6 = Subsection 19D.6.1.6

• A7 = Subsection 19D.6.1.7

• A8 = Subsection 19D.6.1.8

• A10 = Subsection 19D.6.1.9 Page 33 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Notes included with proposed Table 19D-8 Added to Note Text Justification Section Contains the same information as did Note 5 Note 1 Cables are located in most rooms inside containment 19D.8.2.12 in Section 8.1.12 of APP-GW-VP-025, Rev.

0 Table 6b. (Note was renumbered)

A channel consists of two thermocouples within a single Describe the required channels for core-exit division. Each quadrant contains two divisions. The thermocouples (CETs) in a manner Note 2 19D.8.2.2 minimum requirement is two OPERABLE thermocouples consistent with TS 3.3.17, Post Accident in each of the two divisions for each quadrant. Monitoring (PAM) Instrumentation.

There are two groups of igniters. Each containment Describe the required channels for hydrogen compartment and hydrogen pathway is covered by at igniters in a manner consistent with UFSAR Note 3 least one igniter in each group. The minimum 19D.8.2.10 Subsection 6.2.4.2.3, Hydrogen Ignition requirement is one igniter is OPERABLE in each Subsystem.

compartment and hydrogen pathway.

See Appendix 19D, Section 19D.4 for definitions of Time Frames Provides UFSAR reference for definitions of Note 4 Equipment Survivability Time Frames T0 and T1. column header note Equipment Survivability Time Frames.

See Appendix 19D, Section 19D.6 for Actions Actions column Provides UFSAR reference for discussions Note 5 associated with Time Frames T0 and T1. header note of related Actions.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Table B Description of Changes to APP-GW-VP-025 Table 6c: Equipment Located Inside Containment (Time Frames T2 and T3)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions 8.1.1 Differential Pressure and Pressure Transmitters 8.1.1.2 RCS Pressure T2-A1,A4,A10 C-B4,C-B6 RCS pressure transmitter's channels A & C are located RCS-JE- RCS Wide Range No change C- B4 11300 on the maintenance floor (11300). Designation C-B4 PT140A Pressure Trans. A corresponds to the vertical access (11204).

RCS pressure transmitter's channels A & C are located RCS-JE- RCS Wide Range No change C- B4 11300 on the maintenance floor (11300). Designation C-B4 PT140C Pressure Trans. C corresponds to the vertical access (11204).

Core-exit Temperature Time frame 3 (T3) is removed because the CET is Core-exit T2-A3,T2, T3- expected to survive into T2 for the duration required to 8.1.2 C-D0,C-E0 Temperature A10 perform its primary function and won't survive significant core relocation (T3).

Core-exit Thermocouple IIS-JE-TE-042 was omitted from Core-exit IIS-JE-TE042 No change 11105 Rev. 0 of Table 6b. TE-042 is a safety-related Thermocouple P09 thermocouple.

Hydrogen Monitors APP-Hydrogen Monitor No change C-H1 11500 VLS-JE-AE001 Tag numbers revised to be consistent with AP1000 equipment numbering nomenclature. Hydrogen sensors APP-Hydrogen Monitor No change C-H1 11500 are located in 11500 (upper compartment) at 258'-0".

VLS-JE-AE002 Designation C-H1 corresponds to elevation 258' room 1 APP- which does not exist.

Hydrogen Monitor No change C-H1 11500 VLS-JE-AE003 Page 35 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions PXS Radiation Monitors Containment PXS-JE-RE160 Radiation Detector No change C-G3 11500 A

Containment PXS-JE-RE161 Radiation Detector No change C-G3 11500 Radiation monitors are located in 11500 (operating B deck). Designation C-G3 corresponds to an area between elevations 160'-3" and 180'-0" Room 3 which Containment are 11703 and 11603 (upper and lower ADS valve PXS-JE-RE162 Radiation Detector No change C-G3 11500 areas).

C Containment PXS-JE-RE163 Radiation Detector No change C-G3 11500 D

Solenoid-Operated Valves (SOVs) and Vent Air-Operated The section title was changed to clarify the valves are 8.1.6 Valves (AOVs) solenoid or air-operated valves, and not vent air valves.

Containment 8.1.6.5 T2,T3-A2,A6,A9 Note 4 Note 3 Notes changes addressed at the end of this table.

Spray AOVs The containment spray AOV located in the maintenance floor is used for control of fission product release in Time Frames T2 and T3.

Containment Spray The containment spray AOV needs to be in the open FPS-PL-V701 No change 11500 position to perform its function. The containment spray Header AOVs AOV does not require a detailed analysis as the AOV fails-open. The AOV is added per review of severe accident management guidance for control of containment conditions.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions Containment Sampling Function Containment The section title was changed to clarify this section Atmosphere 8.1.6.6 T2,T3-A8,A10 C-D0, C-B1-C-B6 describes the containment sampling function, not only Sampling containment atmosphere sampling function.

Function PSS-PL Hot Leg Sample Action A8 is Hydrogen Control and Action 10 is Accident A10 11300 V001A/B Isol Valves Monitoring.

PSS-PL- Liquid Sample Cont Large scale hydrogen burning equipment testing A10 11400 conducted by EPRI (EPRI NP-4354) documents V010A/B Isol Valves successful solenoid valve performance during multiple Containment Air hydrogen burning temperature transients with acceptable PSS-PL-V008 Sample Cont. A8, A10 C-D0 11400 results and provides supplemental assurance of the Isolation survivability of this equipment The containment sampling function requires these valves, is performed through Time Frame T3, and is used to back up other functions such as hydrogen monitoring. Thermal lag analysis is performed to justify reasonable assurance of survivability of these valves.

Containment The Containment Atmosphere Sampling Function is used Atmosphere for severe accident hydrogen control and accident PSS-PL-V024 A8, A10 11400 monitoring.

Sample Return Isolation Throughout all Time Frames T0 through T3, access to the containment environment from the hot leg and containment atmosphere sampling function is through solenoid valves located in the maintenance floor. During the early time frames of the accident scenario, they will not be energized, but they must survive through Time Frame T3 (ex-vessel conditions) to perform their function Page 37 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions Action A10 is Accident Monitoring.

Containment Sump The valve is not essential for an equipment survivability PSS-PL-V002 Sample Isolation A10 11400 standpoint, but is considered a benefit as a backup to the Valve RCS hot leg sample points and included in the survivability thermal lag analysis.

Reactor Vessel Head Vent SOVs Reactor Vessel The section title was changed to clarify the valves are 8.1.6.7 Head Vent SOVs T2-A4 C-A5 solenoid-operated valves.

AOVs Reactor Vessel RCS-PL-V150A C-A5 11601 Head Vent Reactor Vessel RCS-PL-V150B C-A5 11601 Location C-A5 corresponds to the reactor vessel cavity Head Vent No change (Room 11105) at 66'-6". The RVH vents are located in Reactor Vessel steam generator 1 feedwater nozzle area, Room 11601.

RCS-PL-V150C C-A5 11601 Head Vent Reactor Vessel RCS-PL-V150D C-A5 11601 Head Vent Page 38 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions PXS AOV Not environmentally qualified for post-accident PXS AOV T2, T3-A2 performance.

CVS-PL-V089 PXS Makeup AOV No change 11300 The PXS and IRWST makeup AOVs are used to inject external water into the containment through overflowing the IRWST in the event that it has not drained. This action may be performed in Time Frames T2 and T3.

The AOVs require instrument air.

IRWST makeup The PXS makeup valves do not require detailed analysis.

PXS-PL-V234 No change 11400 The AOVs are beneficial, but not credited in the level 2 AOV PRA or essential for maintaining containment integrity.

The AOVs were added per review of severe accident management guidance for injecting water into containment.

Removed "IRWST" from the section name as not all the 8.1.7.7 RNS IRWST MOVs T2,T3-A2, A7 C-B6 valves are associated with the IRWST.

Action A2 is "Inject into Containment." The action is IRWST Discharge RNS-PL-V024 A2 C-B6 11206 unchanged from Rev. 0 but moved to indicate it is Isolation Valve specific to RNS-PL-V024.

RNS HL Suction 8.1.7.9 T3-A7 C-B8 Section was eliminated by restructuring the table.

to Spent Fuel Pool RNS HL Suction RNS-PL-V001A A2, A7 C-B8 11208 Isolation - Inner A Action A2 is "Inject into Containment."

RNS HL Suction Action A7 is "Containment isolation and venting." The RNS-PL-V001B A2, A7 C-B8 11208 Isolation - Inner B actions are unchanged, but moved to be specific to the RNS HL Suction & individual RNS valves.

RNS-PL-V002A A2, A7 C-B8 11208 Cont. Isolation - A These valves are not credited in the level 2 PRA or essential for maintaining containment integrity.

RNS HL Suction &

RNS-PL-V002B A2, A7 C-B8 11208 Cont. Isolation - B Page 39 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions Note 4, added to the Required Channels/Divisions states: "There are two groups of igniters. Each containment compartment and hydrogen pathway is 8.1.10 Hydrogen Igniters T2, T3-A8 See below covered by at least one igniter in each group. The minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway."

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-27 No change C-D0 11500 27, 1 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-30 No change C-D0 11500 30, 2 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-35 No change C-C5 11500 35, 1 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-36 No change C-C5 11500 36, 2 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-37 No change C-C5 11500 37, 1 Description" of this LAR.

Hydrogen Igniter Igniter relocation is discussed in Section 2, "Detailed VLS-EH-38 No change C-G1 11500 38, 2 Description" of this LAR.

Hydrogen Igniter Hydrogen igniters 65 and 66 were added to containment VLS-EH-65 No change 11500 65, 1 near the exit of the IRWST roof vents 1 and 4 to provide igniter coverage close to source of hydrogen (the IRWST). SNC LAR-15-003, approved as License Amendment number 61 for VEGP 3&4, added the Hydrogen Igniter igniters to the scope of equipment in COL Appendix C VLS-EH-66 No change 11500 66, 2 Table 2.2.3-6 and ITAAC No. 2.2.03.09.c. Hydrogen igniters 65 and 66 were included in the equipment survivability analysis to fulfill ITAAC No. 2.2.03.09c.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions Electrical Containment Penetration Assemblies Electrical Containment 8.1.11 T2,T3-A7 C-C0,C-D0,C-C6 Penetration Assemblies Electrical The electrical containment penetrations are located in DAS-EY-P03Z 11400 Penetration P03 the lower compartment and are required to perform both electrically (conduct current for sensors and igniters) and Electrical mechanically (including maintaining containment ECS-EY-P07X 11400 Penetration P07 pressure boundaries) throughout the severe accident.

Electrical Electrical Penetrations P03, P07, P17, P19 and P20 are ECS-EY-P17X 11300 Penetration P17 listed in COL Appendix C Tables 2.2.1-1 and 2.2.3-6 but Electrical were not in APP-GW-VP-025, Rev. 0 Tables 6b or 6c.

ECS-EY-P19Z 11300 They were added to Tables 6b and 6c to provide Penetration P19 consistency between the electrical penetrations listed in Electrical APP-GW-VP-025 with COL Appendix C Tables 2.2.1-1 ECS-EY-P20Z 11300 Penetration P20 and 2.2.3-6.

This penetration is located on the maintenance floor mezzanine (11400). Designation C-C6 corresponds to ECS 1E Electrical C-C6 11400 the IDS Division B & D penetration room (11306). The IDSA-EY-P11Z Penetration P11 tag number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor mezzanine (11400). Designation C-C6 corresponds to ECS 1E Electrical C-C6 11400 the IDS Division B & D penetration room (11306). The IDSA-EY-P12Y Penetration P12 tag number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor mezzanine (11400). Designation C-C6 corresponds to ECS 1E Electrical C-C6 11400 the IDS Division B & D penetration room (11306). The IDSA-EY-P13Y Penetration P13 tag number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions ECS 1E Electrical The tag number change is made to be consistent with C-C6 11306 IDSD-EY-P14Z Penetration P14 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with C-C6 11306 IDSD-EY-P15Y Penetration P15 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with C-C6 11306 IDSD-EY-P16Y Penetration P16 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor (11300). Designation C-C6 corresponds to the IDS ECS 1E Electrical C-C6 11300 Division B & D penetration room (11306). The tag IDSC-EY-P27Z Penetration P27 number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor (11300). Designation C-C6 corresponds to the IDS ECS 1E Electrical C-C6 11300 Division B & D penetration room (11306). The tag IDSC-EY-P28Y Penetration P28 number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

This penetration is located on the maintenance floor (11300). Designation C-C6 corresponds to the IDS ECS 1E Electrical C-C6 11300 Division B & D penetration room (11306). The tag IDSC-EY-P29Y Penetration P29 number change is made to be consistent with COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with C-C6 11306 IDSB-EY-P30Z Penetration P30 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with C-C6 11306 IDSB-EY-P31Y Penetration P31 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

ECS 1E Electrical The tag number change is made to be consistent with C-C6 11306 IDSB-EY-P32Y Penetration P32 COL Appendix C Table 2.2.1-1 and UFSAR Table 9A-2.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions Penetration tag is made consistent with the standard plant design. This penetration is located on the maintenance floor (11300). Designation C-C6 ECS 1E Electrical C-C6 11300 corresponds to the IDS Division B & D penetration room EDS-EY-P21Z Penetration P21 (11306). Note the "1E" designation is removed consistent with COL Appendix C Table 2.2.1-1. EDS is a non-1E system.

PXS Containment Water Level PXS-JE- Containment Containment Floodup level instruments are level C-A4 11104 LSLE050 Floodup Level transmitters not level switches and the change to the tag number is made to maintain consistency with the tag PXS-JE- Containment C-A4 11104 numbers used in UFSAR Tables 3.11-1 and 3I.6-2.

LSLE052 Floodup Level The level element (LE) is located in containment. The remote level transmitter (LT) is located in the auxiliary building. These transmitters are located in the RCDT PXS-JE- Containment C-A5 11104 room (11104). The designation C-A5 for LE-051 LSLE051 Floodup Level corresponds to the reactor cavity (11105). LE-051 is located in Room 11104.

Containment Hatches (Gasket Material Only)

Containment Hatches (Gasket T2,T3-A7 Material Only)

CNS-MY-Y01 Equipment Hatch 11500 The equipment hatch and a personnel hatch are located at the operating deck elevation. The maintenance hatch CNS-MY-Y02 Maintenance Hatch 11300 and a second personnel hatch are located at the Personnel Hatch - maintenance floor elevation.

CNS-MY-Y03 11500 Upper Action A7 is "containment isolation and venting." The Page 43 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Section and Time Frames Equipment Description T2,T3 and Building Location Discussion Tag No. Actions gasket material of the hatches is required to perform throughout the severe accident to maintain the containment pressure boundary.

Personnel Hatch - Specifying that the thermal lag assessment is performed CNS-MY-Y04 11300 Lower on the hatch seals and adding the hatch seals to APP-GW-VP-025 Tables 6b and 6c is the result of response to OI-SRP19.0-SPLA-14 R1 [ADAMS accession number ML092530405]

Containment T2,T3-A7 Vessel The containment shell itself is part of the equipment survivability assessment and comprises the leak tight structure to which all containment penetrations seal.

CNS-MV-01 Containment Shell Action A7 is "containment isolation and venting." The containment shell is required to perform throughout the severe accident to maintain the containment pressure boundary.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Notes:

1. Hot Leg RTDs could fail as temperature exceeds the designed condition.

2. If device fails, monitoring can be made through the Cont. Atmosphere Sampling Function.

3. Equipment is part of the fire protection system, on vertical pipe inside containment, feeding water to top rings, Room 11500.

4. Cables are located in most rooms inside containment.

Notes deleted from APP-GW-VP-025, Rev. 0 Table 6c Removed from Note Text Justification (6c Rev. 0, Section)

Hot Leg RTDs could fail as temperature exceeds Redundant to information in UFSAR Note 1 8.1.3.1 the designed condition. Subsection 19D.8.2.3.

8.1.4 - Hydrogen monitors can be used into Timeframe 3. Redundant to UFSAR If device fails, monitoring can be made through 8.1.4; Note 2 Subsection 19D.6.3.10.

the Cont. Atmosphere Sampling Function. 8.1.5 8.1.5 - Redundant to information in UFSAR Subsection 19D.8.2.5.

Equipment is part of the fire protection system, on Replaced by Note 4, which has the same Note 3 vertical pipe inside containment, feeding water to 8.1.6.5 information.

top rings, Room 11500 Cables are located in most rooms inside Replaced by Note 1, which has the same Note 4 8.1.12 containment. information.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

1. Cables are located in most rooms inside containment.

2. A channel consists of two thermocouples within a single division. Each quadrant contains two divisions. The minimum requirement is two OPERABLE thermocouples in each of the two divisions for each quadrant.

3. There are two groups of igniters. Each containment compartment and hydrogen pathway is covered by at least one igniter in each group. The minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway.

4. Equipment is part of the fire protection system, on vertical pipe inside containment, feeding water to top rings, Room 11500.

5. Time Frames T2 and T3 are beyond design basis, and therefore, only one channel of each instrumentation parameter is required to be OPERABLE. However, it is preferred to have more than one channel of each parameter available to resolve information ambiguity.

6. See Appendix 19D, Section 19D.4 for definitions of Equipment Survivability Time Frames T2 and T3.

7. See Appendix 19D, Section 19D.6 for Actions associated with Time Frames T2 and T3.

Time Frame T2 Time Frame T3

• A1 = Subsection 19D.6.2.1

• A1 = Subsection 19D.6.3.1

• A2 = Subsection 19D.6.2.2

• A2 = Subsection 19D.6.3.2

• A3 = Subsection 19D.6.2.3

• A3 = Subsection 19D.6.3.3

• A4 = Subsection 19D.6.2.4

• A4 = Subsection 19D.6.3.4

• A5 = Subsection 19D.6.2.5

• A5 = Subsection 19D.6.3.5

• A6 = Subsection 19D.6.2.6

• A6 = Subsection 19D.6.3.6

• A7 = Subsection 19D.6.2.7

• A7 = Subsection 19D.6.3.7

• A8 = Subsection 19D.6.2.8

• A8 = Subsection 19D.6.3.8

• A9 = Subsection 19D.6.2.9

• A9 = Subsection 19D.6.3.9

• A10 = Subsection 19D.6.2.10

• A10 = Subsection 19D.6.3.10 Page 46 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Notes included with proposed Table 19D-9 Note Text Added to Section Justification Equipment is part of the fire protection system, on Contains the same information as did Note 3 Note 4 (reorder) vertical pipe inside containment, feeding water to 19D.8.2.6 in Section 8.1.6.5 of APP-GW-VP-025, Rev.

top rings, Room 11500. 0 Table 6c. (Note was renumbered)

Contains the same information as did Note 4 Cables are located in most rooms inside Note 1 19D.8.2.12 in Section 8.1.12 of APP-GW-VP-025, Rev.

containment 0 Table 6c. (Note was renumbered)

A channel consists of two thermocouples within a Describe the required channels for core-exit single division. Each quadrant contains two thermocouples (CETs) in a manner Note 2 divisions. The minimum requirement is two 19D.8.2.2 consistent with TS 3.3.17, Post Accident OPERABLE thermocouples in each of the two Monitoring (PAM) Instrumentation.

divisions for each quadrant.

There are two groups of igniters. Each containment compartment and hydrogen pathway Describe the required channels for hydrogen is covered by at least one igniter in each group. igniters in a manner consistent with UFSAR Note 3 19D.8.2.10 The minimum requirement is one igniter is Subsection 6.2.4.2.3, Hydrogen Ignition OPERABLE in each compartment and hydrogen Subsystem.

pathway.

Time Frames T2 and T3 are beyond design basis, and therefore, only one channel of each Desired Explains the rationale for minimum channels instrumentation parameter is required to be Note 5 Channels/Divisions and divisions in beyond design-basis OPERABLE. However, it is preferred to have column header accidents.

more than one channel of each parameter available to resolve information ambiguity.

See Appendix 19D, Section 19D.4 for definitions Time Frames Provides UFSAR reference for definitions of Note 6 of Equipment Survivability Time Frames T0 and column header note Equipment Survivability Time Frames.

T1.

See Appendix 19D, Section 19D.6 for Actions Actions column Provides UFSAR reference for discussions Note 7 associated with Time Frames T0 and T1. header note of related Actions.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

B.2) Consolidate Thermal Lag Assessment requirements of ITAAC 2.2.03.09c into COL Condition 2.D.(12)(g)9.

The COL Appendix C ITAAC 2.2.03.09c design commitment currently requires a severe accident thermal lag analysis for equipment listed in Tier 1 Table 2.2.3-6. This ITAAC duplicates the thermal lag assessment required in COL Condition 2.D.(12)(g)9. The equipment and functions listed in ITAAC Table 2.2.3-6 are included in Tables 19D-8 and 19D-9, which are proposed to be added to UFSAR Appendix 19D.

Related Licensing Basis Document Change Descriptions

• COL Condition 2.D.(12)(g)9: Change reference in the License Condition from Attachment A of APP-GW-GLR-069, "Equipment Survivability Assessment" to UFSAR Tables 19D-8 and 19D-9. Delete "as-built" from the COL Condition.

• Tier 1 Subsection 2.2.3, Passive Core Cooling System:

a. Delete Item 9.c);

b. Delete ITAAC Number 2.2.03.09c from Table 2.2.3-4, Design Commitment; Inspections, Tests, Analyses, and Acceptance Criteria

c. Delete Table 2.2.3-6; replace with notation that the table is not used.

• UFSAR Subsection 19.59.10.5: remove as-built from the text discussion.

• UFSAR Subsection 19.59.11: delete APP-GW-GLR-069 from reference 19.59-5.

• UFSAR Appendix 19D:

a. Revise Subsections 19D.6.2.10 and 19D.6.3.10 to show the addition of the liquid sampling function.

b. Change the title of Subsection 19D.8.2.6 to, "Solenoid-Operated Valves (SOVs) and Air-Operated Valves (AOVs)."

c. Add Subsection 19D.8.2.14, "Containment Hatches (Gasket Material Only)," and discussion of the gasket material assessment.

d. Add Subsection 19D.8.2.15, "Containment Shell," and discussion of the containment shell assessment.

e. Renumber Subsection 19D.8.2.14, Assessment of Equipment for Sustained Burning," to Subsection 19D.8.2.16, and add references to Table 19D-8 and Table 19D-9 in the text.

f. Revise Tables 19D-3, 19D-4, and 19D-5 to add the containment hatches (gasket material only) as equipment in operation during Time Frames 1, 2, and 3, respectively.

g. Revise Tables 19D-3, 19D-4, 19D-5, and 19D-7 to show the addition of the liquid sampling function and to reflect that the containment liquid and containment atmosphere sampling are different sampling functions.

h. Add Table 19D-8 "Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location," and Table 19D-9, "Equipment Located Inside Containment (Time Frames T2 and T3) Equipment, Action Time Frame, and Equipment Location," following Table 19D-7.

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ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

Technical Evaluation for Consolidation of ITAAC 2.2.03.09c into COL Condition 2.D.(12)(g)9 The ITAAC is redundant to COL Condition 2.D.(12)(g)9. The equipment, tag numbers, and functions listed in Tier 1 Table 2.2.3-6 are included in proposed Appendix 19D Tables 19D-8 and 19D-9.

The equipment listed in Tier 1 Table 2.2.3-6 has sufficient thermal lag to withstand the effects of identified hydrogen burns associated with severe accidents. The proposed changes reconcile the as-built equipment with the list of equipment on which the equipment survivability assessment is performed to provide additional assurance containment penetrations and combustible gas control components will perform their design functions after a hydrogen burn in containment.

Conclusion of Technical Evaluation for Equipment Survivability The proposed changes to COL Condition 2.D.(12)(g)9, the list of equipment inside containment on which equipment survivability is assessed, and the involved UFSAR changes are not changes to the design or design function of an SSC. The plant-specific Tier 1 information is the design information and functions subject to verification by the Tier 1 ITAAC closure process. The proposed changes neither affect the ability to meet design criteria or functions, nor involve a decrease in the safety provided by the associated systems. Plant-specific Tier 1 information and ITAAC would continue to validate their corresponding UFSAR (Tier 2) design commitments.

Accordingly, application of the generic certified design information in Tier 1 as required by 10 CFR 52, Appendix D, Section III.B, in the particular circumstances discussed in the associated exemption request is not necessary to achieve the underlying purpose of the rule.

The proposed changes do not affect an SSC, function or feature used for the prevention or mitigation of accidents or their safety / design analyses. The changes do not affect any SSC accident initiator or initiating sequence of events, or involve any safety-related SSC or function used to mitigate an accident.

Conclusion of Technical Evaluation for all Changes in this LAR The proposed changes do not involve a change to a fission product barrier. The changes cannot result in a new failure mode, malfunction or sequence of events that could affect safety. The changes would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures.

The proposed changes do not affect any safety-related equipment, design code limit, safety-related function, safety-related design analysis, safety analysis input or result, or design or safety margin. No safety analysis or design basis acceptance limit or criterion would be challenged or exceeded.

In conclusion, the proposed changes do not involve a technical (design, analysis, function or qualification) change (e.g., there is no change to an associated calculation, design parameter or design requirement). Therefore, the changes would not result in a decrease in plant safety.

The proposed changes are unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents) or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or Page 49 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the proposed amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

The proposed changes do not adversely impact the emergency plan or the physical security plan implementation, because there are no changes to physical access to credited equipment inside the Nuclear Island (including containment or the auxiliary building) and no adverse impact to plant personnels ability to respond to any plant operations or security event.

The proposed changes in the requested amendment do not affect or alter any walls, floors, or other structures that provide shielding. Plant radiation zones and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure. Therefore, the proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

3. T ECHNICAL EVALUATION (Combined with Section 2)

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 52.98(c) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a Combined License (COL). This activity involves a departure from the conditions specified in the COL. Therefore, this activity requires a proposed amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this license amendment request.

10 CFR 52, Appendix D, Section VIII.B.5.a allows an applicant or licensee who references this appendix to depart from Tier 2 information, without prior NRC approval, unless the proposed departure involves a change to or departure from Tier 1 information, Tier 2* information, or the Technical Specifications, or requires a license amendment under paragraphs B.5.b or B.5.c of the section. This proposed amendment involves changes to Tier 1 information, COL Appendix C ITAACs, and involved changes to UFSAR Tier 2 information and thus requires NRC approval.

10 CFR 50.34(f)(2)(ix)(c) states that equipment necessary for achieving and maintaining safe shutdown of the plant and maintaining containment integrity will perform its safety function during and after being exposed to the environmental conditions attendant with the release of hydrogen generated by the equivalent of a 100 percent fuel-clad, metal-water reaction including the environmental conditions created by activation of the hydrogen control system. The proposed changes to add additional equipment on which the equipment survivability assessment is performed do not change the design function of a structure, system, or component (SSC) required for maintaining containment integrity or achieving and maintaining safe shutdown of the plant.

The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 are consistent with the hydrogen ignition subsystem design described in the UFSAR and are compliant with this criterion. Therefore, the requirements of 10 CFR 50.34(f)(2)(ix)(c) are met.

10 CFR 50.34(f)(2)(xvii) requires instrumentation to measure containment pressure, containment water level, containment hydrogen concentration, containment radiation intensity, and noble gas effluents at all potential accident release points. The proposed changes to add additional equipment on which the equipment survivability assessment is performed do not change the Page 50 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) design function or ability to perform its design function of an SSC required for measuring conditions inside containment and monitoring radioactive effluents from containment. The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 are consistent with the hydrogen ignition subsystem design described in the UFSAR, have no effect on measuring equipment, and are compliant with this criterion. Therefore, the requirements of 10 CFR 50.34(f)(2)(xvii) are met.

10 CFR 50.34(f)(2)(xix) requires instrumentation adequate for monitoring plant conditions following an accident that includes core damage. The proposed changes to add additional equipment on which the equipment survivability assessment is performed do not change the design function or ability of an SSC required for monitoring plant conditions following an accident that includes core damage. The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 are consistent with the hydrogen ignition subsystem design described in the UFSAR, have no effect on measuring equipment, and are compliant with this criterion. Therefore, the requirements of 10 CFR 50.34(f)(2)(xix) are met.

10 CFR 50.44(c) requires that all combined licenses under 10 CFR 52 must meet requirements to ensure a mixed containment atmosphere; provide means to limit hydrogen concentrations in containment during and following an accident that releases an equivalent amount of hydrogen as would be generated by 100 percent fuel clad-coolant reaction, uniformly distributed, to less than 10 percent by volume and maintain containment structural integrity and appropriate accident mitigating features; establish and ensure safe shutdown and containment integrity with systems and components capable of performing their functions during and after exposure to environmental conditions by burning of hydrogen; provide equipment for monitoring hydrogen in containment; and must perform an analysis to demonstrate containment structural integrity that addresses an accident that releases hydrogen generated from 100 percent fuel-cladding reaction accompanied by hydrogen burning. The proposed changes to add additional equipment on which the equipment survivability assessment is performed do not change the design function of a structure, system, or component (SSC) required for limiting hydrogen buildup in containment following an accident, maintaining containment integrity, or achieving and maintaining safe shutdown of the plant. The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 are consistent with the hydrogen ignition subsystem design described in the UFSAR and are compliant with this criterion. Therefore, the requirements of 10 CFR 50.44(c) are met.

10 CFR 50.44(c)(3) states that systems necessary to ensure containment integrity shall be demonstrated to perform their function under conditions associated with an accident that releases hydrogen generated from 100 percent fuel-clad metal-water reaction. The proposed changes to add additional equipment on which the equipment survivability assessment is performed provide additional assurance that the systems intended to provide containment integrity will perform their functions in a post-hydrogen burn containment environment. The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 are consistent with the hydrogen ignition subsystem design described in the UFSAR and are compliant with this criterion. The changes do not change the ability of an SSC required for maintaining containment integrity to perform its design function. Therefore, the requirements of 10 CFR 50.44(c)(3) are met.

10 CFR 50.44(c)(4) states that equipment must be provided for monitoring hydrogen in the containment that is functional, reliable, and capable of continuously measuring the concentration of hydrogen in the containment atmosphere following a significant beyond design basis accident for accident management, including emergency planning. The proposed changes to add Page 51 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) additional equipment on which the equipment survivability assessment is performed do not change the ability of an SSC required for monitoring hydrogen in the containment to perform its design function. The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 are consistent with the hydrogen ignition subsystem design described in the UFSAR and are compliant with this criterion. Therefore, the requirements of 10 CFR 50.44(c)(4) are met.

10 CFR 50 Appendix A, General Design Criterion (GDC) 41, Containment Atmosphere Cleanup, requires that systems to control fission products, hydrogen, oxygen, and other substances which may be released into the reactor containment shall be provided as necessary to reduce, consistent with the functioning of other associated systems, the concentration and quality of fission products released to the environment following postulated accidents, and to control the concentration of hydrogen or oxygen and other substances in the containment atmosphere following postulated accidents to assure that containment integrity is maintained. The proposed changes to add additional equipment on which the survivability assessment is performed do not affect the ability of an SSC required for controlling fission products and combustible gasses in containment. The survivability assessment provides additional assurance containment integrity is maintained. The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 are consistent with the hydrogen ignition subsystem design described in the UFSAR and are compliant with this criterion. Therefore, the requirements of GDC-41 are met.

10 CFR 50, Appendix A, GDC 42, Inspection of Containment Atmosphere Cleanup System, requires that the system shall be designed to permit appropriate periodic inspection of important components to assure the integrity and capability of the systems. The proposed changes to add additional equipment on which the survivability assessment is performed do not affect the ability to inspect equipment required for containment atmosphere cleanup. The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 maintain capability to inspect the hydrogen ignition subsystem. Therefore, the requirements of GDC-42 are met.

The proposed changes have been evaluated to determine whether applicable regulations continue to be met. It was determined that the proposed changes do not affect conformance with the GDC differently than described in the plant-specific DCD or UFSAR.

4.2 Precedent No precedent identified.

4.3 Significant Hazards Consideration The requested amendment would revise COL Condition 2.D.(12)(g)9 to replace APP-GW-GLR-069 with Updated Final Safety Analysis Report (UFSAR) Appendix 19D Tables containing the equipment listed in APP-GW-GLR-069 with revisions reflecting design completion.

The changes involve changing the COL reference from APP-GW-GLR-069 to tables in UFSAR Chapter 19 which incorporate the survivability and thermal lag assessment equipment lists. The changes reconcile the as-built equipment with the equipment on which the equipment survivability assessment is performed, to include equipment added to the design since the issuance of the Combined License. The requested amendment also proposes changes to Hydrogen Igniters 30, 35, 36, 37, and 38 to meet igniter location criteria. Changes are also proposed to the UFSAR and involve changes to COL Appendix C, to resolve inconsistencies related to the location of Hydrogen Igniter 27 Page 52 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001)

The changes include deleting COL Appendix C and plant-specific Tier 1 information in Subsection 2.2.3, Item 9.c); Table 2.2.3-6; and ITAAC No. 2.2.03.09c as the thermal lag assessment documented in the ITAAC duplicates the thermal lag assessment required by the COL Condition.

An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92(c), Issuance of amendment, as discussed below.

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

Response: No The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 do not adversely affect any safety-related structure, system or component (SSC) or function. The hydrogen ignition subsystem is designed to mitigate beyond design basis hydrogen generation in the containment. With the proposed changes, the hydrogen ignition subsystem continues to maintain the designed and analyzed beyond design basis functions. The hydrogen ignition subsystem maintains its design function to maintain containment integrity. The proposed changes also reconcile the as-built equipment with the list of equipment on which the equipment survivability assessment is performed to provide additional assurance containment penetrations and combustible gas control components will perform their design functions after a hydrogen burn in containment. The changes are to the equipment assessed, not to the design functions of the equipment. The changes do not involve an interface with any SSC accident initiator or initiating sequence of events, and thus, the probabilities of the accidents evaluated in the plant-specific UFSAR are not affected. The proposed changes do not involve a change to any mitigation sequence or the predicted radiological releases due to postulated accident conditions, thus, the consequences of the accidents evaluated in the UFSAR are not affected.

The maximum allowable containment vessel leakage rate specified in the Technical Specifications is unchanged, and radiological material release source terms are not affected; thus, the radiological releases in the accident analyses are not affected. The proposed changes do not affect the prevention and mitigation of other abnormal events (e.g. anticipated operational occurrences, earthquakes, floods and turbine missiles), or their safety or design analyses.

Therefore, the consequences of the accidents evaluated in the UFSAR are not affected.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

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

Response: No The proposed changes do not affect the operation of any systems or equipment that may initiate a new or different kind of accident, or alter any SSC such that a new accident initiator or initiating sequence of events is created. The proposed changes reconcile the as-built equipment with the list of equipment on which the equipment survivability assessment is performed to provide additional assurance that containment penetrations and combustible gas control components will perform their design functions after a hydrogen burn in containment. The equipment survivability assessment changes are to the equipment assessed, not to the design functions of the Page 53 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) equipment. The VLS Hydrogen Ignition subsystem does not interface with/affect safety-related equipment or a fission product barrier. The subsystem is provided to address the production of hydrogen following a beyond design basis accident in accordance with 10 CFR 50.44(c). The hydrogen ignition subsystem is a non-Class 1E subsystem and does not interface with any safety-related system; thus, no system or design function or equipment qualification is affected by the proposed changes. The changes to the hydrogen ignition subsystem do not result in a new failure mode, malfunction or sequence of events that could affect a radioactive material barrier or safety-related equipment. The proposed changes do not adversely affect any system or design function or equipment qualification as the changes do not modify any SSCs that prevent safety functions from being performed. The changes do not introduce a new failure mode, malfunction or sequence of events that could adversely affect safety or safety-related equipment Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed changes and clarifications to the locations of Hydrogen Igniters 27, 30, 35, 36, 37, and 38 maintain the beyond design basis function of the hydrogen ignition subsystem. The proposed changes also reconcile the as-built equipment with the list of equipment on which the equipment survivability assessment is performed to provide additional assurance containment penetrations and combustible gas control components will perform their design functions after a hydrogen burn in containment. The equipment survivability assessment changes are to the equipment assessed, not to the design functions of the equipment. The proposed changes would not affect any safety-related design code, function, design analysis, safety analysis input or result, or existing design/safety margin. No safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the requested changes.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Therefore, it is concluded that the requested amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

5. ENVIRONMENTAL CONSIDERATIONS The proposed changes would revise COL Condition 2.D.(12)(g)9 to replace APP-GW-GLR-069 with Updated Final Safety Analysis Report (UFSAR) Appendix 19D Tables containing the equipment listed in APP-GW-GLR-069 with revisions reflecting design completion. The change involves changing the COL reference from APP-GW-GLR-069 to tables in UFSAR Chapter 19 Page 54 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) which incorporate the survivability and thermal lag assessment equipment lists. The changes reconcile the as-built equipment with the equipment on which the equipment survivability assessment is performed, to include equipment added to the design since the issuance of the Combined License. The requested amendment also proposes changes to Hydrogen Igniters 30, 35, 36, 37, and 38 to meet igniter location criteria. Changes are also proposed to resolve inconsistencies related to the location of Hydrogen Igniter 27.

A review has determined that facility construction and operation following implementation of the requested amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:

(i) There is no significant hazards consideration.

As documented in Section 4.3, Significant Hazards Consideration, of this license amendment request, an evaluation was completed to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment. The Significant Hazards Consideration determined that (1) the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the proposed amendment does not involve a significant reduction in a margin of safety. Therefore, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed changes are unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents) or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the proposed amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed change in the requested amendment to the thermal lag assessment does not affect or alter any walls, floors, or other structures that provide shielding. Plant radiation zones and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure.

Therefore, the proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above review of the proposed amendment, it has been determined that anticipated construction and operational effects of the proposed amendment do not involve (i) a significant Page 55 of 56

ND-18-0342 Request for License Amendment: Equipment Survivability Assessment (LAR-18-001) hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6. REFERENCES

1. AP1000 COL Standard Technical Report Submittal of APP-GW-GLR-069, (TR 68).

Westinghouse Electric Company. June 11, 2007. [ADAMS Accession number ML071660111].

2. Westinghouse Electric Company Letter DCP-NRC-002615, AP1000 Response to Proposed Open Item (Chapter 19). September 8, 2009. [ADAMS Accession number ML092530405].

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Southern Nuclear Operating Company ND-18-0342 Enclosure 2 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Exemption Request:

Equipment Survivability Assessment (LAR-18-001)

(This Enclosure consists of 8 pages, including this cover page)

ND-18-0342 Exemption Request: Equipment Survivability Assessment (LAR-18-001) 1.0 Purpose Southern Nuclear Operating Company (SNC, the Licensee) requests a permanent exemption from the provisions of 10 CFR 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, to allow a departure from elements of the certification information in Tier 1 of the generic AP1000 Design Control Document (DCD). The regulation, 10 CFR 52, Appendix D, Section III.B, requires an applicant or licensee referencing Appendix D to 10 CFR Part 52 to incorporate by reference and comply with the requirements of Appendix D, including certified information in DCD Tier 1. The Tier 1 information for which a plant-specific departure and exemption is being requested includes revisions and clarifications related to assessments of equipment survivability during beyond design basis events.

This request for exemption provides the technical and regulatory basis to demonstrate that 10 CFR 52.63, §52.7, and §50.12 requirements are met and will apply the requirements of 10 CFR 52, Appendix D, Section VIII.A.4 to allow departures from generic Tier 1 information that clarify In-containment Refueling Water Storage Tank (IRWST) hydrogen igniters in Table 2.3.9-2, revise hydrogen igniter locations in Table 2.3.9-2, and consolidate Section 2.2.3 thermal lag assessment requirements into a more encompassing COL Condition 2.D.(12)(g)9.

2.0 Background The Licensee is the holder of Combined License Nos. NPF-91 and NPF-92, which authorize construction and operation of two Westinghouse Electric Company AP1000 nuclear plants, named Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.

The hydrogen ignition subsystem is provided to address the possibility of an event that would result in a rapid production of large amounts of hydrogen such that the rate of production exceeds the capacity of the recombiners. The hydrogen ignition subsystem consists of hydrogen igniters strategically distributed throughout the containment. The igniter coverage, distribution and power supply has been designed to minimize the potential loss of igniter protection globally for containment and locally for individual compartments.

The locations of the igniters are based on evaluation of hydrogen transport in the containment and the hydrogen combustion characteristics. Locations include compartmented areas in the containment and various locations throughout the free volume, including the upper dome. The number of hydrogen igniters and their locations are selected considering the behavior of hydrogen in the containment during severe accidents. The likely hydrogen transport paths in the containment and hydrogen burn physics are the two important aspects influencing the choice of igniter location.

The primary objective of installing an igniter system is to promote hydrogen burning at a low concentration and, to the extent possible, to burn hydrogen as it is generated and concentrated so that the hydrogen concentration does not build up in the containment. To achieve this goal, igniters are placed in the major regions of the containment where hydrogen may be released, through which it may flow, or where it may accumulate. The criteria utilized in the evaluation and the application of the criteria to specific compartments is provided in Updated Final Safety Analysis Report (UFSAR) Table 6.2.4-6. The location of igniters throughout containment is shown in UFSAR Figures 6.2.4-5 through 6.2.4-13.

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ND-18-0342 Exemption Request: Equipment Survivability Assessment (LAR-18-001)

The location of igniters is also summarized in UFSAR Table 6.2.4-7 identifying subcompartment/regions by name and elevation along with identifying the igniters by power group. The locations identified are considered approximations (+/- 2.5 feet) with the final locations governed by the installation details.

As described in UFSAR Subsection 19.59.10.5, it is also necessary to determine that equipment can perform its severe accident functions during environmental conditions resulting from hydrogen burns associated with severe accidents. Thus, a thermal lag assessment of the equipment required to mitigate severe accidents (e.g., hydrogen igniters and containment penetrations) is required. Currently, this assessment is required (for a comprehensive list of equipment) by COL Condition 2.D.(12)(g)9 and (for a subset of the comprehensive list of equipment) by Tier 1 Section 2.2.3, item 9.c, Table 2.2.3-4, item 9.c, and Table 2.2.3-6.

3.0 Technical Justification of Acceptability A. Changes to Hydrogen Igniter Locations Relocating Hydrogen Igniter 30 from Room 11401 to Room 11403 is proposed to provide sufficient igniter coverage for the PRHR inspection flange and RCS pressurizer spray line hydrogen sources. Hydrogen Igniter 30 will provide backup to Hydrogen Igniter 32 since they are powered by different power groups. Room 11403 and Room 11400 are both located in the Lower compartment area, and are only separated by two small walls that do not rise to the ceiling. Hydrogen Igniter 30 and 32 will provide coverage for both rooms because the room volumes are connected. Hydrogen Igniter 30 is proposed to be installed above the RCS pressurizer spray line at an elevation of 132-8. The hydrogen mixing/combustion analysis confirms that sufficient igniter coverage to the Lower compartment area is provided by Hydrogen Igniters 30 and 32.

Relocating Hydrogen Igniters 35, 36, 37, and 38 from inside the IRWST (Room 11305) vents to above the outside of the IRWST vent outlets is proposed to allow the Hydrogen Igniters to perform their design function. The proposed location of the Hydrogen Igniters is in the upper compartment lower region, Room 11500, at an elevation of 137-6, just outside of the IRWST hooded vents. Igniter coverage is provided inside the IRWST by Hydrogen Igniters 9, 10, 15, and 16. These four igniters provide sufficient igniter coverage within the IRWST and meet the Igniter Location Criteria in UFSAR Table 6.2.4-6.

Hydrogen Igniters 35, 36, 37, and 38 are no longer located within, or "fitted" inside of the IRWST vents. Hydrogen Igniters 35, 36, 37, and 38 are proposed to be located external to the IRWST hooded vents.

Changes are proposed to plant-specific Tier 1 Table 2.3.9-2 to change the room number for Hydrogen Igniter 27 from 11400 to 11300. Design documents for location of hydrogen igniters in containment identify Hydrogen Igniter 27 in Room 11300 at 117'-3".

The change to the location description for Hydrogen Igniters 9, 10, 15, and 16 is an editorial change to describe where the igniters inside the IRWST are located. The locations of the igniters are not changed. The change to improve the location description does not adversely affect the design functions of the hydrogen ignition subsystem.

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ND-18-0342 Exemption Request: Equipment Survivability Assessment (LAR-18-001)

B. Equipment Survivability: Thermal Lag Assessment Tables 6b and 6c of APP-GW-VP-025 (Attachment A of APP-GW-GLR-069) lists the equipment on which the thermal lag assessment is performed to satisfy License Condition 2.D.(12)(g)9 for the equipment survivability analysis and required for closure of Tier 1 Table 2.2.3-4, item 9.c. The change from the referenced APP-GW-GLR-069 tables to UFSAR Tables 19D-8 and 19D-9 reconciles the list of equipment on which the thermal lag assessment is performed with the equipment required to mitigate severe accidents (hydrogen igniters and containment penetrations). The thermal lag assessment is performed to confirm that this equipment can perform its severe accident functions during environmental conditions resulting from hydrogen burns associated with severe accidents.

The Tier 1 Table 2.2.3-4, item 9.c design commitment currently requires a severe accident thermal lag analysis for equipment listed in Tier 1 Table 2.2.3-6 which is a subset of the equipment for which a thermal lag assessment is required in COL Condition 2.D.(12)(g)9.

The equipment and functions listed in Tier 1 Table 2.2.3-6 are included in the tables proposed to be added to UFSAR Appendix 19D.

Detailed technical justification supporting this request for exemption is provided in Section 2 of the associated License Amendment Request in Enclosure 1 of this letter.

4.0 Justification of Exemption 10 CFR Part 52, Appendix D, Section VIII.A.4 and 10 CFR 52.63(b)(1) govern the issuance of exemptions from elements of the certified design information for AP1000 nuclear power plants. Since SNC has identified changes to the Tier 1 information as discussed in Enclosure 1 of the accompanying License Amendment Request, an exemption from the certified design information in Tier 1 is needed.

10 CFR Part 52, Appendix D, and 10 CFR 50.12, §52.7, and §52.63 state that the NRC may grant exemptions from the requirements of the regulations provided six conditions are met: 1) the exemption is authorized by law [§50.12(a)(1)]; 2) the exemption will not present an undue risk to the health and safety of the public [§50.12(a)(1)]; 3) the exemption is consistent with the common defense and security [§50.12(a)(1)]; 4) special circumstances are present [§50.12(a)(2)]; 5) the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption [§52.63(b)(1)]; and 6) the design change will not result in a significant decrease in the level of safety [Part 52, App. D, VIII.A.4].

The requested exemption satisfies the criteria for granting specific exemptions, as described below.

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ND-18-0342 Exemption Request: Equipment Survivability Assessment (LAR-18-001)

1) This exemption is authorized by law The NRC has authority under 10 CFR 52.63, §52.7, and §50.12 to grant exemptions from the requirements of NRC regulations. Specifically, 10 CFR 50.12 and §52.7 state that the NRC may grant exemptions from the requirements of 10 CFR Part 52 upon a proper showing. No law exists that would preclude the changes covered by this exemption request. Additionally, granting of the proposed exemption does not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commissions regulations.

Accordingly, this requested exemption is authorized by law, as required by 10 CFR 50.12(a)(1).

2) This exemption will not present an undue risk to the health and safety of the public The proposed exemption from the requirements of 10 CFR 52, Appendix D, Section III.B would allow changes to elements of the plant-specific Tier 1 DCD to depart from the AP1000 certified (Tier 1) design information. The plant-specific DCD Tier 1 will continue to reflect the approved licensing basis, and will maintain a consistent level of detail with that which is currently provided elsewhere in Tier 1 of the DCD. Therefore, the affected plant-specific DCD Tier 1 ITAAC will continue to serve its required purpose.

The revisions and clarifications related to assessments of equipment survivability during beyond design basis events do not represent an adverse impact to the design functions supported by the equipment, or the associated systems, structures and components and will continue to protect the health and safety of the public in the same manner. The clarifications and additional exceptions do not introduce any new industrial, chemical, or radiological hazards that would represent a public health or safety risk, nor do they modify or remove any design or operational controls or safeguards intended to mitigate any existing on-site hazards. Furthermore, the proposed change would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in fuel cladding failures. Accordingly, this change does not present an undue risk from any existing or proposed equipment or systems.

Therefore, the requested exemption from 10 CFR 52, Appendix D, Section III.B would not present an undue risk to the health and safety of the public.

3) The exemption is consistent with the common defense and security The requested exemption from the requirements of 10 CFR 52, Appendix D, Section III.B would allow the licensee to depart from elements of the plant-specific Tier 1 design information. The proposed exemption does not alter the design, function, or operation of any structures or plant equipment that is necessary to maintain a safe and secure status of the plant. The proposed exemption has no impact on plant security or safeguards procedures.

Therefore, the requested exemption is consistent with the common defense and security.

4) Special circumstances are present 10 CFR 50.12(a)(2) lists six special circumstances for which an exemption may be granted. Pursuant to the regulation, it is necessary for one of these special circumstances to be present in order for the NRC to consider granting an exemption request. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That Page 5 of 8

ND-18-0342 Exemption Request: Equipment Survivability Assessment (LAR-18-001) subsection defines special circumstances as when Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.

The rule under consideration in this request for exemption is 10 CFR 52, Appendix D, Section III.B, which requires that a licensee referencing the AP1000 Design Certification Rule (10 CFR Part 52, Appendix D) shall incorporate by reference and comply with the requirements of Appendix D, including Tier 1 information. The VEGP Units 3 and 4 COLs reference the AP1000 Design Certification Rule and incorporate by reference the requirements of 10 CFR Part 52, Appendix D, including Tier 1 information. The underlying purpose of Appendix D,Section III.B is to describe and define the scope and contents of the AP1000 design certification, and to require compliance with the design certification information in Appendix D.

The proposed exemption would provide revisions and clarifications related to assessments of equipment survivability during beyond design basis events. The proposed revisions and clarifications reflect the design functions of the associated systems and components as described in the licensing basis documents. Accordingly, this exemption from the certification information enables the Licensee to safely construct and operate the facility consistent with the design certified by the NRC in 10 CFR Part 52, Appendix D.

Therefore, special circumstances are present, because application of the current generic certified design information in Tier 1 as required by 10 CFR Part 52, Appendix D, Section III.B, in the particular circumstances discussed in this request is not necessary to achieve the underlying purpose of the rule.

5) The special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.

Based on the nature of the changes to the plant-specific Tier 1 information and the understanding that these changes support the design function of the supported equipment, it is expected that this exemption may be requested by other AP1000 licensees and applicants. However, a review of the reduction in standardization resulting from the departure from the standard DCD determined that even if other AP1000 licensees and applicants do not request this same departure, the special circumstances will continue to outweigh any decrease in safety from the reduction in standardization because the key design functions of the equipment associated with this request will continue to be maintained. Furthermore, the justification provided in the license amendment request and this exemption request and the associated mark-ups demonstrate that there is a limited change from the standard information provided in the generic AP1000 DCD, which is offset by the special circumstances identified above.

Therefore, the special circumstances associated with the requested exemption outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.

6) The design change will not result in a significant decrease in the level of safety.

The exemption revises the plant-specific DCD Tier 1 information by revising and clarifying the locations of hydrogen igniters and consolidating Section 2.2.3 thermal lag assessment requirements into a more encompassing COL Condition 2.D.(12)(g)9. The clarifications and revisions do not change the design requirements of the associated equipment.

Because these functions continue to be met, there is no reduction in the level of safety.

Page 6 of 8

ND-18-0342 Exemption Request: Equipment Survivability Assessment (LAR-18-001) 5.0 Risk Assessment A risk assessment was not determined to be applicable to address the acceptability of this proposal.

6.0 Precedent Exemptions None 7.0 Environmental Consideration The Licensee requests a departure from elements of the certified information in Tier 1 of the generic AP1000 DCD. The Licensee has determined that the proposed departure would require a permanent exemption from the requirements of 10 CFR 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, with respect to installation or use of facility components located within the restricted area, as defined in 10 CFR Part 20, or which changes an inspection or a surveillance requirement; however, the Licensee evaluation of the proposed exemption has determined that the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Based on the above review of the proposed exemption, the Licensee has determined that the proposed activity does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed exemption is not required.

Specific details of the environmental considerations supporting this request for exemption are provided in Section 5 of the associated License Amendment Request provided in Enclosure 1 of this letter.

8.0 Conclusion The proposed changes to Tier 1 are necessary to revise and clarify the assessments of equipment survivability during beyond design basis events. The exemption request meets the requirements of 10 CFR 52.63, Finality of design certifications, 10 CFR 52.7, Specific exemptions, 10 CFR 50.12, Specific exemptions, and 10 CFR 52 Appendix D, Design Certification Rule for the AP1000. Specifically, the exemption request meets the criteria of 10 CFR 50.12(a)(1) in that the request is authorized by law, presents no undue risk to public health and safety, and is consistent with the common defense and security.

Furthermore, approval of this request does not result in a significant decrease in the level of safety, satisfies the underlying purpose of the AP1000 Design Certification Rule, and does not present a significant decrease in safety as a result of a reduction in standardization.

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ND-18-0342 Exemption Request: Equipment Survivability Assessment (LAR-18-001) 9.0 References None Page 8 of 8

Southern Nuclear Operating Company ND-18-0342 Enclosure 3 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Reviewers Aid:

Differences in COL Referenced Tables (LAR-18-001)

(This Enclosure consists of 30 pages, including this cover page)

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 6b: List of Equipment Located Inside Containment (T0 and T1)

(Subjected to Severe Accident Environment, Assessment Required)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number 8.1 Equipment Located in Containment 8.1.1 19D.8.2.1 Differential Pressure and Pressure Transmitters 8.1.1.1 PXS - IRWST Water Level T0,T1-A1,A2,A3,A4,A10 C-C0 2 Sense level PXS-JE-LT045 IRWST Level Transmitter C-C0 PXS-JE-LT046 IRWST Level Transmitter C-C0 11300 PXS-JE-LT047 IRWST Level Transmitter C-C0 11300 PXS-JE-LT048 IRWST Level Transmitter C-C0 11300 8.1.1.2 RCS Pressure T0,T1-A1,A4,A5,A10 C-B4,C-B6 2 Sense pressure RCS-JE-PT140A RCS Wide Range Pressure Trans. A C- B411300 RCS Wide Range Pressure Trans.

RCS-JE-PT140C C- B411300 C

RCS-JE-PT140B RCS Wide Range Pressure Trans. B C- B611306 RCS Wide Range Pressure Trans.

RCS-JE-PT140D C- B611306 D

8.1.1.3 SG Wide Range Water Level T0,T1-A3,A5 C-B1,C-C0 2 per SG Sense level SGS-JE-LT012 SG 1 Wide Range Level Transmitter C-B1 11201 SGS-JE-LT016 SG 1 Wide Range Level Transmitter C-B1 11201 SGS-JE-LT011 SG 1 Wide Range Level Transmitter C-C0 11300 SGS-JE-LT015 SG 1 Wide Range Level Transmitter C-C0 11300 SGS-JE-LT013 SG 2 Wide Range Level Transmitter C-C0 11300 SGS-JE-LT014 SG 2 Wide Range Level Transmitter C-C0 11300 SGS-JE-LT017 SG 2 Wide Range Level Transmitter C-C0 11300 SGS-JE-LT018 SG 2 Wide Range Level Transmitter C-C0 11300 Page 2 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number 8.1.1.4 Containment Pressure T0,T1-A6,A7,A8,A10 C-D0 2 Sense pressure PCS-JE-PT012 Extended Range Cont. Pressure 1 C-D0 11400 PCS-JE-PT013 Extended Range Cont. Pressure 2 C-D0 11400 PCS-JE-PT014 Extended Range Cont. Pressure 3 C-D0 11400 19D.8.2.2 Thermocouples 8.1.2 Core-exit Temperature T0,T1-A1,A2,A3,A10 C-D0,C-E0 2 (Note 2) Sense temperature IIS-JE-TE002 Core-exit Thermocouple, B09 C-D0 11105 IIS-JE-TE003 Core-exit Thermocouple, C04 C-D0 11105 IIS-JE-TE005 Core-exit Thermocouple, C08 C-D0 11105 IIS-JE-TE008 Core-exit Thermocouple, E02 C-D0 11105 IIS-JE-TE010 Core-exit Thermocouple, E06 C-D0 11105 IIS-JE-TE012 Core-exit Thermocouple, E10 C-D0 11105 IIS-JE-TE015 Core-exit Thermocouple, G02 C-D0 11105 IIS-JE-TE016 Core-exit Thermocouple, G04 C-D0 11105 IIS-JE-TE017 Core-exit Thermocouple, G06 C-D0 11105 IIS-JE-TE020 Core-exit Thermocouple, G12 C-D0 11105 IIS-JE-TE021 Core-exit Thermocouple, G14 C-D0 11105 IIS-JE-TE025 Core-exit Thermocouple, J08 C-D0 11105 IIS-JE-TE026 Core-exit Thermocouple, J10 C-D0 11105 IIS-JE-TE030 Core-exit Thermocouple, L04 C-D0 11105 IIS-JE-TE033 Core-exit Thermocouple, L10 C-D0 11105 IIS-JE-TE035 Core-exit Thermocouple, L14 C-D0 11105 IIS-JE-TE038 Core-exit Thermocouple, N08 C-D0 11105 IIS-JE-TE039 Core-exit Thermocouple, N10 C-D0 11105 IIS-JE-TE040 Core-exit Thermocouple, N12 C-D0 11105 Page 3 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number IIS-JE-TE041 Core-exit Thermocouple, P07 C-D0 11105 IIS-JE-TE001 Core-exit Thermocouple, B07 C-D0 11105 IIS-JE-TE004 Core-exit Thermocouple, C06 C-E0 11105 IIS-JE-TE006 Core-exit Thermocouple, C10 C-E0 11105 IIS-JE-TE009 Core-exit Thermocouple, E04 C-E0 11105 IIS-JE-TE013 Core-exit Thermocouple, E12 C-E0 11105 IIS-JE-TE014 Core-exit Thermocouple, E14 C-E0 11105 IIS-JE-TE018 Core-exit Thermocouple, G08 C-E0 11105 IIS-JE-TE019 Core-exit Thermocouple, G10 C-E0 11105 IIS-JE-TE022 Core-exit Thermocouple, J02 C-E0 11105 IIS-JE-TE023 Core-exit Thermocouple, J04 C-E0 11105 IIS-JE-TE024 Core-exit Thermocouple, J06 C-E0 11105 IIS-JE-TE027 Core-exit Thermocouple, J12 C-E0 11105 IIS-JE-TE029 Core-exit Thermocouple, L02 C-E0 11105 IIS-JE-TE031 Core-exit Thermocouple, L06 C-E0 11105 IIS-JE-TE034 Core-exit Thermocouple, L12 C-E0 11105 IIS-JE-TE036 Core-exit Thermocouple, N04 C-E0 11105 IIS-JE-TE037 Core-exit Thermocouple, N06 C-E0 11105 Cont. Bldg IIS-JE-TE007 Core-exit Thermocouple, C12 11105 Cont. Bldg IIS-JE-TE011 Core-exit Thermocouple, E08 11105 Cont. Bldg IIS-JE-TE028 Core-exit Thermocouple, K14 11105 Cont. Bldg IIS-JE-TE032 Core-exit Thermocouple, L08 11105 Page 4 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number IIS-JE-TE042 Core-exit Thermocouple, P09 11105 8.1.3 19D.8.2.3 Resistance Temperature Detectors (RTDs)

T0,T1-A1,A3 C-B1,C-B2 8.1.3.1 Hot Leg RTDs 2 Sense temperature (Note 1) (Note 1)

RCS-JE-TE135A RCS Hot Leg 1 Wide Range RTD C-B1 11201 RCS-JE-TE135B RCS Hot Leg 2 Wide Range RTD C-B2 11202 C-B1,C-B2 8.1.3.2 Cold Leg RTDs T0,T1-A1,A3 2 Sense temperature (Note 1)

RCS-JE-TE125A RCS Cold Leg 1A Wide Range RTD C-B1 11201 RCS-JE-TE125C RCS Cold Leg 1B Wide Range RTD C-B1 11201 RCS-JE-TE125B RCS Cold Leg 2A Wide Range RTD C-B2 11202 RCS-JE-TE125D RCS Cold Leg 2B Wide Range RTD C-B2 11202 8.1.3.3 Containment Temperature T0,T1-A10 C-E0 2 Sense temperature Operating Floor Area Temperature VCS-JE-TE053A C-E0 11500 A

Operating Floor Area Temperature VCS-JE-TE053B C-E0 11500 B

8.1.3.4 IRWST Water Temperature T0,T1-A3,A4 C-C0 2 Sense temperature C-C0 PXS-JE-TE041 IRWST Water Temperature 11300, 11305 C-C0 PXS-JE-TE042 IRWST Water Temperature 11300, 11305 C-C0 PXS-JE-TE043 IRWST Water Temperature 11300, 11305 Page 5 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number C-C0 PXS-JE-TE044 IRWST Water Temperature 11300, 11305 19D.8.2.4 Hydrogen Monitors 8.1.4 Hydrogen Monitors T0,T1-A8,A10 C-H1 2 Sense concentration APP-VLS-JE-Hydrogen Monitor C-H1 11500 AE001 APP-VLS-JE-Hydrogen Monitor C-H1 11500 AE002 APP-VLS-JE-Hydrogen Monitor C-H1 11500 AE003 19D.8.2.5 Radiation Monitors 8.1.5 PXS Radiation Monitors T0,T1-A10 (Note 2) C-G3 2 Sense radiation PXS-JE-RE160 Containment Radiation Detector A C-G3 11500 PXS-JE-RE161 Containment Radiation Detector B C-G3 11500 PXS-JE-RE162 Containment Radiation Detector C C-G3 11500 PXS-JE-RE163 Containment Radiation Detector D C-G3 11500 8.1.6 19D.8.2.6 Solenoid-Operated Valves (SOVs) and - Vent Air-Operated Valves (AOVs) 8.1.6.1 PXS Core Makeup Tank AOVs T0,T1-A1 C-B,C-B7 1 per CMT Transfer open PXS-PL-V014A CMT A Discharge Isolation C-B6 11206 PXS-PL-V015A CMT A Discharge Isolation C-B6 11206 PXS-PL-V014B CMT B Discharge Isolation C-B7 11207 PXS-PL-V015B CMT B Discharge Isolation C-B7 11207 8.1.6.2 PXS PRHR AOVs T0,T1-A3,A4 C-C0 1 Transfer open PXS-PL-V108A PRHR HX Control A C-C0 11300 PXS-PL-V108B PRHR HX Control B C-C0 11300 Page 6 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number Containment Isolation AOVs and C-B8,C-C0, 8.1.6.3 T1-A7 All Varies, see below SOVs C-D0,E0 CVS-PL-V045 Letdown Containment Isolation C-C0 11300 Transfer close PSS-PL-V008 Cont. Air Sample Cont. Isolation C-D0 11400 Transfer open and close PSS-PL-V010A Liquid Sample Line Cont. Isolation A C-D0 11400 Transfer open and close PSS-PL-V010B Liquid Sample Line Cont. Isolation B C-D0 11400 Transfer open and close Containment Atmosphere Sample PSS-PL-V024 11400 Transfer open and close Return Isolation RNS Return from CVS Cont.

RNS-PL-V061 C-B8 11208 Transfer close Isolation VFS-PL-V004 Cont. Purge Inlet Cont. Isolation C-D0 11400 Transfer open and close Cont. Purge Discharge Cont.

VFS-PL-V009 C-D0 11400 Transfer open and close Isolation VWS-PL-V082 Fan Coolers Return Cont. Isolation C-E0 11500 Transfer close WLS-PL-V055 Sump Discharge Cont. Isolation C-C0 11300 Transfer close WLS-PL-V067 RCDT Gas Outlet Cont. Isolation C-C0 11300 Transfer close 8.1.6.4 CVS RCS Boundary AOVs T0,T1-A1 C-C4 All Transfer open and close RCS Purification Return Line Stop CVS-PL-V081 C-C4 11304 Valve Auxiliary Pressurizer Spray Line CVS-PL-V084 C-C4 11304 Isolation Containment Atmosphere 8.1.6.6 T0,T1-A8,A10 C-D0 All Transfer open and close Sampling Function PSS-PL-V001A/B Hot Leg Sample Isol Valves A10 11300 PSS-PL-V010A/B Liquid Sample Cont Isol Valves A10 11400 Containment Air Sample Cont.

PSS-PL-V008 A8, A10 C-D0 11400 Isolation Page 7 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number Containment Atmosphere Sample PSS-PL-V024 A8, A10 11400 Return Isolation Containment Sump Sample Isolation PSS-PL-V002 A10 11400 Valve 2 valves in the Reactor Vessel Head Vent SOVs T1-A4 Transfer open and close same flowpath RCS-PL-V150A Reactor Vessel Head Vent 11601 RCS-PL-V150B Reactor Vessel Head Vent 11601 RCS-PL-V150C Reactor Vessel Head Vent 11601 RCS-PL-V150D Reactor Vessel Head Vent 11601 8.1.7 19D.8.2.7 Motor Operated Valves (MOVs) 8.1.7.1 PXS Accumulator MOVs T1-A1 (Note 3) C-B6,C-B7 1 per Accum Transfer open PXS-PL-V027A Accumulator A Discharge Isolation C-B6 11206 PXS-PL-V027B Accumulator B Discharge Isolation C-B7 11207 8.1.7.2 PXS Core Makeup Tank MOVs T0,T1-A1 (Note 3) C-D0 1 per CMT Transfer open PXS-PL-V002A CMT A Inlet Isolation C-D0 11400 PXS-PL-V002B CMT B Inlet Isolation C-D0 11400 8.1.7.3 PXS Recirculation MOVs T1-A2 C-B6,C-B7 1 Transfer open PXS-PL-V117A Cont. Recirculation. A Isolation C-B6 11206 PXS-PL-V117B Cont. Recirculation. B Isolation C-B7 11207 C-D1, 1 flowpath 8.1.7.4 ADS Stages 1, 2, 3, & 4 MOVs T1-A4 C-D2,C-F3, Transfer open per stage C-G3 RCS-PL-V001A First Stage ADS A C-G3 11703 RCS-PL-V011A First Stage ADS Isolation A C-G3 11703 RCS-PL-V002A Second Stage ADS A C-G3 11703 Page 8 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number RCS-PL-V012A Second Stage ADS Isolation A C-G3 11703 RCS-PL-V003A Third Stage ADS A C-G3 11703 RCS-PL-V013A Third Stage ADS Isolation A C-G3 11703 RCS-PL-V001B First Stage ADS B C-F3 11603 RCS-PL-V011B First Stage ADS Isolation B C-F3 11603 RCS-PL-V002B Second Stage ADS B C-F3 11603 RCS-PL-V012B Second Stage ADS Isolation B C-F3 11603 RCS-PL-V003B Third Stage ADS B C-F3 11603 RCS-PL-V013B Third Stage ADS Isolation B C-F3 11603 RCS-PL-V014A Fourth Stage ADS MOV C-D1 11301 RCS-PL-V014B Fourth Stage ADS MOV C-D2 11302 RCS-PL-V014C Fourth Stage ADS MOV C-D1 11301 RCS-PL-V014D Fourth Stage ADS MOV C-D2 11302 C-B6,C-B8, 8.1.7.5 Containment Isolation MOVs T1-A7 All Varies, see below C-C0,C-D0 CCS-PL-V207 CCS Containment Isolation Valve C-D0 11400 Transfer close CVS-PL-V091 Makeup Line Cont. Isolation C-C0 11300 Transfer open and close RNS HL Suction & Cont. Isolation -

RNS-PL-V002A C-B8 11208 Transfer open and close A

RNS HL Suction & Cont. Isolation -

RNS-PL-V002B C-B8 11208 Transfer open and close B

RNS Suction from IRWST - Cont.

RNS-PL-V023 C-B8 11208 Transfer open and close Isolation SFS-PL-V034 SFS Suction Line Cont. Isolation. C-B6 11206 Transfer close CVS Charging and Injection 8.1.7.6 T0,T1-A1 C-C0 1 Transfer open and close MOVs Page 9 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number CVS-PL-V091 Makeup Line Cont. Isolation C-C0 11300 8.1.7.7 RNS IRWST MOVs T1-A1 C-B6,C-B8 2 Transfer open and close RNS-PL-V001A/B RNS Suction Isol from Hot Leg 11208 RNS-PL-V002A/B RNS Suction Isol from Hot Leg 11208 RNS Suction from IRWST - Cont.

RNS-PL-V023 C-B8 11208 Isolation RNS-PL-V024 IRWST Discharge Isolation Valve C-B6 11206 8.1.7.8 PXS PRHR MOV (Note 4) T0,T1-A3,A4 C-E0 1 Transfer open PXS-PL-V101 PRHR HX Inlet Isolation C-E0 11500 8.1.8 19D.8.2.8 Squib Valves 8.1.8.1 IRWST Injection T1-A2 C-B6,C-B7 2 Transfer open IRWST Injection A Isolation Line A PXS-PL-V123A C-B6 11206 Squib Valve IRWST Injection A Isolation Line A PXS-PL-V125A C-B6 11206 Squib Valve IRWST Injection B Isolation Line B PXS-PL-V123B C-B7 11207 Squib Valve IRWST Injection B Isolation Line B PXS-PL-V125B C-B7 11207 Squib Valve 8.1.8.2 PXS Containment Recirculation T1-A2 C-B6,C-B7 2 Transfer open Cont. Recirculation A Isolation Squib PXS-PL-V118A C-B6 11206 Valve Cont. Recirculation A Isolation Squib PXS-PL-V120A C-B6 11206 Valve Cont. Recirculation B Isolation Squib PXS-PL-V118B C-B7 11207 Valve Cont. Recirculation B Isolation Squib PXS-PL-V120B C-B7 11207 Valve Page 10 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number 8.1.8.3 Fourth Stage ADS T1-A4 C-D1,C-D2 3 Transfer open RCS-PL-V004A Fourth Stage ADS A C-D1 11301 RCS-PL-V004C Fourth Stage ADS C C-D1 11301 RCS-PL-V004B Fourth Stage ADS B C-D2 11302 RCS-PL-V004D Fourth Stage ADS D C-D2 11302 8.1.9 19D.8.2.9 Position Sensors C-B6,C-8.1.9 Valve Position Sensors T1-A7 B8,C-C0,C- All Sense valve position D0, C-E0 CCS-PL-V207-L CCS Containment Isolation Valve C-D0 11400 CVS-PL-V045-L Letdown Containment Isolation C-C0 11300 CVS-PL-V091-L Makeup Line Cont. Isolation C-C0 11300 Containment Air Sample Cont.

PSS-PL-V008-L C-D0 11400 Isolation Liquid Sample Cont. Isolation Valve PSS-PL-V010A-L C-D0 11400 A

Liquid Sample Cont. Isolation Valve PSS-PL-V010B-L C-D0 11400 B

Containment Atmosphere Sample PSS-PL-V024-L 11400 Return Isolation RNS HL Suction & Cont. Isolation -

RNS-PL-V002A-L C-B8 11208 A

RNS HL Suction & Cont. Isolation -

RNS-PL-V002B-L C-B8 11208 B

RNS Suction from IRWST - Cont.

RNS-PL-V023-L C-B8 11208 Isolation RNS Return from CVS - Cont.

RNS-PL-V061-L C-B8 11208 Isolation Page 11 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number SFS-PL-V034-L SFS Suction Line Cont. Isolation. C-B6 11206 Containment Purge Inlet Cont.

VFS-PL-V004-L C-D0 11400 Isolation Containment Discharge Cont.

VFS-PL-V009-L C-D0 11400 Isolation Fan Coolers Return Cont. Isolation VWS-PL-V082-L C-E0 11500 Valve WLS-PL-V055-L Sump Discharge Cont. Isolation C-C0 11300 WLS-PL-V067-L RCDT Gas Outlet Cont. Isolation C-C0 11300 19D.8.2.10 Hydrogen Igniters 8.1.10 Hydrogen Igniters T1-A8 See below Note 3 Ignite hydrogen VLS-EH-01 Hydrogen Igniter 01, 1 C-B4 11204 VLS-EH-02 Hydrogen Igniter 02, 2 C-B4 11204 VLS-EH-03 Hydrogen Igniter 03, 1 C-B4 11204 VLS-EH-04 Hydrogen Igniter 04, 2 C-B4 11204 VLS-EH-05 Hydrogen Igniter 05, 1 C-D2 11402 VLS-EH-06 Hydrogen Igniter 06, 2 C-E2 11502 VLS-EH-07 Hydrogen Igniter 07, 2 C-D2 11402 VLS-EH-08 Hydrogen Igniter 08, 1 C-E2 11502 VLS-EH-09 Hydrogen Igniter 09, 1 C-C5 11305 VLS-EH-10 Hydrogen Igniter 10, 2 C-C5 11305 VLS-EH-11 Hydrogen Igniter 11, 2 C-D1 11401 VLS-EH-12 Hydrogen Igniter 12, 1 C-E1 11501 VLS-EH-13 Hydrogen Igniter 13, 1 C-D1 11401 VLS-EH-14 Hydrogen Igniter 14, 2 C-E1 11501 VLS-EH-15 Hydrogen Igniter 15, 2 C-C5 11305 Page 12 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number VLS-EH-16 Hydrogen Igniter 16, 1 C-C5 11305 VLS-EH-17 Hydrogen Igniter 17, 2 C-B7 11207 VLS-EH-18 Hydrogen Igniter 18, 1 C-B7 11207 VLS-EH-19 Hydrogen Igniter 19, 2 C-B8 11208 VLS-EH-20 Hydrogen Igniter 20, 2 C-B6 11206 VLS-EH-21 Hydrogen Igniter 21, 1 C-B6 11206 VLS-EH-22 Hydrogen Igniter 22, 1 T0, T1-A8 C-D0 11400 VLS-EH-23 Hydrogen Igniter 23, 2 C-D0 11400 VLS-EH-24 Hydrogen Igniter 24, 2 C-D0 11400 VLS-EH-25 Hydrogen Igniter 25, 2 C-D0 11400 VLS-EH-26 Hydrogen Igniter 26, 2 C-D0 11400 VLS-EH-27 Hydrogen Igniter 27, 1 C-D0 11300 VLS-EH-28 Hydrogen Igniter 28, 1 C-D0 11400 VLS-EH-29 Hydrogen Igniter 29, 1 C-D0 11400 VLS-EH-30 Hydrogen Igniter 30, 2 C-D0 11403 VLS-EH-31 Hydrogen Igniter 31, 1 C-D0 11400 VLS-EH-32 Hydrogen Igniter 32, 1 C-D0 11400 VLS-EH-33 Hydrogen Igniter 33, 2 C-B9 11209 VLS-EH-34 Hydrogen Igniter 34, 1 C-B9 11209 VLS-EH-35 Hydrogen Igniter 35, 1 C-C5 11500 VLS-EH-36 Hydrogen Igniter 36, 2 C-C5 11500 VLS-EH-37 Hydrogen Igniter 37, 1 C-C5 11500 VLS-EH-38 Hydrogen Igniter 38, 2 C-C5 11500 VLS-EH-39 Hydrogen Igniter 39, 1 C-G1 11500 VLS-EH-40 Hydrogen Igniter 40, 2 C-G3 11500 Page 13 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number VLS-EH-41 Hydrogen Igniter 41, 2 C-G2 11500 VLS-EH-42 Hydrogen Igniter 42, 1 C-G2 11500 VLS-EH-43 Hydrogen Igniter 43, 1 C-E0 11500 VLS-EH-44 Hydrogen Igniter 44, 1 C-G1 11500 VLS-EH-45 Hydrogen Igniter 45, 2 C-E0 11500 VLS-EH-46 Hydrogen Igniter 46, 2 C-G2 11500 VLS-EH-47 Hydrogen Igniter 47, 1 C-G2 11500 VLS-EH-48 Hydrogen Igniter 48, 2 C-G1 11500 VLS-EH-49 Hydrogen Igniter 49, 1 C-E3 11503 VLS-EH-50 Hydrogen Igniter 50, 2 C-E3 11503 VLS-EH-51 Hydrogen Igniter 51, 1 C-H0 11500 VLS-EH-52 Hydrogen Igniter 52, 2 C-H0 11500 VLS-EH-53 Hydrogen Igniter 53, 2 C-H0 11500 VLS-EH-54 Hydrogen Igniter 54, 1 C-H0 11500 VLS-EH-55 Hydrogen Igniter 55, 1 C-E4 11504 VLS-EH-56 Hydrogen Igniter 56, 2 C-E4 11504 VLS-EH-57 Hydrogen Igniter 57, 2 C-E4 11504 VLS-EH-58 Hydrogen Igniter 58, 1 C-E4 11504 VLS-EH-59 Hydrogen Igniter 59, 2 C-E3 11503 VLS-EH-60 Hydrogen Igniter 60, 1 C-E3 11503 VLS-EH-61 Hydrogen Igniter 61, 1 C-H0 11500 VLS-EH-62 Hydrogen Igniter 62, 2 C-H0 11500 VLS-EH-63 Hydrogen Igniter 63, 1 C-H0 11500 VLS-EH-64 Hydrogen Igniter 64, 2 C-H0 11500 VLS-EH-65 Hydrogen Igniter 65, 1 11500 Page 14 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number VLS-EH-66 Hydrogen Igniter 66, 2 11500 19D.8.2.11 Electrical Containment Penetration Assemblies Maintain containment Electrical Containment C-C0, 8.1.11 T1-A7 All boundary; Conduct electricity Penetration Assemblies C-D0,C-C6 for sensors and igniters ECS-EY-P01X Electrical Penetration P01 C-D0 11400 ECS-EY-P02X Electrical Penetration P02 C-D0 11400 DAS-EY-P03Z Electrical Penetration P03 C-D0 11400 ECS-EY-P06Y Electrical Penetration P06 C-D0 11400 ECS-EY-P07X Electrical Penetration P07 11400 ECS-EY-P09W Electrical Penetration P09 C-D0 11400 ECS-EY-P10W Electrical Penetration P10 C-D0 11400 ECS IDSA-EY-1E Electrical Penetration P11 C-C6 11400 P11Z ECS IDSA-EY-1E Electrical Penetration P12 C-C6 11400 P12Y ECS IDSA-EY-1E Electrical Penetration P13 C-C6 11400 P13Y ECS IDSD-EY-1E Electrical Penetration P14 C-C6 11306 P14Z ECS IDSD-EY-1E Electrical Penetration P15 C-C6 11306 P15Y ECS IDSD-EY-1E Electrical Penetration P16 C-C6 11306 P16Y ECS-EY-P17X Electrical Penetration P17 11300 ECS-EY-P18X Electrical Penetration P18 C-C0 11300 ECS-EY-P19Z Electrical Penetration P19 11300 Page 15 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number ECS-EY-P20Z Electrical Penetration P20 11300 ECS EDS-EY-1E Electrical Penetration P21 C-C6 11300 P21Z ECS-EY-P22X Electrical Penetration P22 C-C0 11300 ECS-EY-P23X Electrical Penetration P23 C-C0 11300 ECS-EY-P24 Spare Electrical Penetration C-C0 11300 ECS-EY-P25W Electrical Penetration P25 C-C0 11300 ECS-EY-P26W Electrical Penetration P26 C-C0 11300 ECS IDSC-EY-1E Electrical Penetration P27 C-C6 11300 P27Z ECS IDSC-EY-1E Electrical Penetration P28 C-C6 11300 P28Y ECS IDSC-EY-1E Electrical Penetration P29 C-C6 11300 P29Y ECS IDSB-EY-1E Electrical Penetration P30 C-C6 11306 P30Z ECS IDSB-EY-1E Electrical Penetration P31 C-C6 11306 P31Y ECS IDSB-EY-1E Electrical Penetration P32 C-C6 11306 P32Y 19D.8.2.12 Cables Note 5 Conduct electricity for valves, 8.1.12 Cables T0,T1-A10 All Note 1 sensors and igniters 19D.8.2.13 Float Level Sensors 8.1.13 PXS Containment Water Level T0,T1-A2,A10 C-A4,C-A5 2 Sense level PXS-JE-LSLE050 Containment Floodup Level C-A4 11104 PXS-JE-LSLE052 Containment Floodup Level C-A4 11104 Page 16 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Equipment, Action Time Frame, and Equipment Location Building Required Section and Time Frames T0,T1 and Location Description Channels/ Function Equip Tag No Actions (Notes 4, 5) Room Divisions Number PXS-JE-LSLE051 Containment Floodup Level C-A5 11104 19D.8.2.14 Containment Hatches (Gasket Material Only)

Containment Hatches Maintain containment T0,T1-A7 All (Gasket Material Only) boundary CNS-MY-Y01 Equipment Hatch 11500 CNS-MY-Y02 Maintenance Hatch 11300 CNS-MY-Y03 Personnel Hatch - Upper 11500 CNS-MY-Y04 Personnel Hatch - Lower 11300 19D.8.2.15 Containment Vessel Maintain containment Containment Vessel T0,T1-A7 All boundary CNS-MV-01 Containment Shell Page 17 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Notes:

1. RTDs could fail as temperature exceeds the designed condition.

2. If device fails, monitoring can be made through the Cont. Atmosphere Sampling Function.

3. Valve is open and remains open.

4. See Section 8.1.7.8

5. Cables are located in most rooms inside containment

1. Cables are located in most rooms inside containment.

2. A channel consists of two thermocouples within a single division. Each quadrant contains two divisions. The minimum requirement is two OPERABLE thermocouples in each of the two divisions for each quadrant. All Core Exit Thermocouples are located inside the Reactor Pressure Vessel which is in Room 11105 (reactor cavity).

3. There are two groups of igniters. Each containment compartment and hydrogen pathway is covered by at least one igniter in each group. The minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway.

4. See Appendix 19D, Section 19D.4 for definitions of Equipment Survivability Time Frames T0 and T1.

5. See Appendix 19D, Section 19D.6 for Actions associated with Time Frames T0 and T1.

• A1 = Subsection 19D.6.1.1

• A2 = Subsection 19D.6.1.2

• A3 = Subsection 19D.6.1.3

• A4 = Subsection 19D.6.1.4

• A5 = Subsection 19D.6.1.5

• A6 = Subsection 19D.6.1.6

• A7 = Subsection 19D.6.1.7

• A8 = Subsection 19D.6.1.8

• A10 = Subsection 19D.6.1.9 Page 18 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 6c: List of Equipment Located Inside Containment (T2 and T3)

(Subjected to Severe Accident Environment, Assessment Required)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number 8.1.1 19D.8.2.1 Differential Pressure and Pressure Transmitters 8.1.1.2 RCS Pressure T2-A1,A4,A10 C-B4,C-B6 2 Sense pressure RCS Wide Range Pressure Trans.

RCS-JE-PT140A C- B411300 A

RCS Wide Range Pressure Trans.

RCS-JE-PT140C C- B411300 C

RCS Wide Range Pressure Trans.

RCS-JE-PT140B C- B611306 B

RCS Wide Range Pressure Trans.

RCS-JE-PT140D C- B611306 D

8.1.1.3 SG Wide Range Water Level T2-A3 C-B1,C-C0 2 per SG Sense level SG 1 Wide Range Level SGS-JE-LT012 C-B1 11201 Transmitter SG 1 Wide Range Level SGS-JE-LT016 C-B1 11201 Transmitter SG 1 Wide Range Level SGS-JE-LT011 C-C0 11300 Transmitter SG 1 Wide Range Level SGS-JE-LT015 C-C0 11300 Transmitter SG 2 Wide Range Level SGS-JE-LT013 C-C0 11300 Transmitter SG 2 Wide Range Level SGS-JE-LT014 C-C0 11300 Transmitter SG 2 Wide Range Level SGS-JE-LT017 C-C0 11300 Transmitter Page 19 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number SG 2 Wide Range Level SGS-JE-LT018 C-C0 11300 Transmitter T2-A1,T2,T3-8.1.1.4 Containment Pressure C-D0 2 Sense pressure A6,A7,A8,A10 PCS-JE-PT012 Extended Range Cont. Pressure 1 C-D0 11400 PCS-JE-PT013 Extended Range Cont. Pressure 2 C-D0 11400 PCS-JE-PT014 Extended Range Cont. Pressure 3 C-D0 11400 19D.8.2.2 Thermocouples 8.1.2 Core-exit Temperature T2-A3,T2, T3-A10 C-D0,C-E0 2 (Note 2) Sense temperature IIS-JE-TE002 Core-exit Thermocouple, B09 C-D0 11105 IIS-JE-TE003 Core-exit Thermocouple, C04 C-D0 11105 IIS-JE-TE005 Core-exit Thermocouple, C08 C-D0 11105 IIS-JE-TE008 Core-exit Thermocouple, E02 C-D0 11105 IIS-JE-TE010 Core-exit Thermocouple, E06 C-D0 11105 IIS-JE-TE012 Core-exit Thermocouple, E10 C-D0 11105 IIS-JE-TE015 Core-exit Thermocouple, G02 C-D0 11105 IIS-JE-TE016 Core-exit Thermocouple, G04 C-D0 11105 IIS-JE-TE017 Core-exit Thermocouple, G06 C-D0 11105 IIS-JE-TE020 Core-exit Thermocouple, G12 C-D0 11105 IIS-JE-TE021 Core-exit Thermocouple, G14 C-D0 11105 IIS-JE-TE025 Core-exit Thermocouple, J08 C-D0 11105 IIS-JE-TE026 Core-exit Thermocouple, J10 C-D0 11105 IIS-JE-TE030 Core-exit Thermocouple, L04 C-D0 11105 IIS-JE-TE033 Core-exit Thermocouple, L10 C-D0 11105 IIS-JE-TE035 Core-exit Thermocouple, L14 C-D0 11105 Page 20 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number IIS-JE-TE038 Core-exit Thermocouple, N08 C-D0 11105 IIS-JE-TE039 Core-exit Thermocouple, N10 C-D0 11105 IIS-JE-TE040 Core-exit Thermocouple, N12 C-D0 11105 IIS-JE-TE041 Core-exit Thermocouple, P07 C-D0 11105 IIS-JE-TE001 Core-exit Thermocouple, B07 C-E0 11105 IIS-JE-TE004 Core-exit Thermocouple, C06 C-E0 11105 IIS-JE-TE006 Core-exit Thermocouple, C10 C-E0 11105 IIS-JE-TE009 Core-exit Thermocouple, E04 C-E0 11105 IIS-JE-TE013 Core-exit Thermocouple, E12 C-E0 11105 IIS-JE-TE014 Core-exit Thermocouple, E14 C-E0 11105 IIS-JE-TE018 Core-exit Thermocouple, G08 C-E0 11105 IIS-JE-TE019 Core-exit Thermocouple, G10 C-E0 11105 IIS-JE-TE022 Core-exit Thermocouple, J02 C-E0 11105 IIS-JE-TE023 Core-exit Thermocouple, J04 C-E0 11105 IIS-JE-TE024 Core-exit Thermocouple, J06 C-E0 11105 IIS-JE-TE027 Core-exit Thermocouple, J12 C-E0 11105 IIS-JE-TE029 Core-exit Thermocouple, L02 C-E0 11105 IIS-JE-TE031 Core-exit Thermocouple, L06 C-E0 11105 IIS-JE-TE034 Core-exit Thermocouple, L12 C-E0 11105 IIS-JE-TE036 Core-exit Thermocouple, N04 C-E0 11105 IIS-JE-TE037 Core-exit Thermocouple, N06 C-E0 11105 Cont. Bldg IIS-JE-TE007 Core-exit Thermocouple, C12 11105 Cont. Bldg IIS-JE-TE011 Core-exit Thermocouple, E08 11105 Page 21 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number Cont. Bldg IIS-JE-TE028 Core-exit Thermocouple, K14 11105 IIS-JE-TE042 Core-exit Thermocouple, P09 11105 8.1.3 19D.8.2.3 Resistance Temperature Detectors (RTDs) 8.1.3.1 Hot Leg RTDs T2-A1,A3 (Note 1) C-B1,C-B2 2 Sense temperature RCS-JE-TE135A RCS Hot Leg 1 Wide Range RTD C-B1 11201 RCS-JE-TE135B RCS Hot Leg 2 Wide Range RTD C-B2 11202 8.1.3.2 Cold Leg RTDs T2-A1,A3 C-B1,C-B2 2 Sense temperature RCS Cold Leg 1A Wide Range RCS-JE-TE125A C-B1 11201 RTD RCS Cold Leg 1B Wide Range RCS-JE-TE125C C-B1 11201 RTD RCS Cold Leg 2A Wide Range RCS-JE-TE125B C-B2 11202 RTD RCS Cold Leg 2B Wide Range RCS-JE-TE125D C-B2 11202 RTD 8.1.3.3 Containment Temperature T3-A7,T2,T3-A10 C-E0 2 Sense temperature Operating Floor Area Temperature VCS-JE-TE053A C-E0 11500 A

Operating Floor Area Temperature VCS-JE-TE053B C-E0 11500 B

19D.8.2.4 Hydrogen Monitors T2-A8,T2,T3-A10 8.1.4 Hydrogen Monitors C-H1 2 Sense concentration (Note 2)

APP-VLS-JE-AE001 Hydrogen Monitor C-H1 11500 APP-VLS-JE-AE002 Hydrogen Monitor C-H1 11500 APP-VLS-JE-AE003 Hydrogen Monitor C-H1 11500 Page 22 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number 8.1.5 19D.8.2.5 Radiation Monitors T2,T3-A10 (Note 8.1.5 PXS Radiation Monitors C-G3 2 Sense radiation 2)

PXS-JE-RE160 Containment Radiation Detector A C-G3 11500 PXS-JE-RE161 Containment Radiation Detector B C-G3 11500 PXS-JE-RE162 Containment Radiation Detector C C-G3 11500 PXS-JE-RE163 Containment Radiation Detector D C-G3 11500 8.1.6 19D.8.2.6 Solenoid-Operated Valves (SOVs) - Vent and Air-Operated Valves (AOVs) 8.1.6.4 CVS RCS Boundary AOVs T2-A1,A4 C-C4 All Transfer open and close RCS Purification Return Line Stop CVS-PL-V081 C-C4 11304 Valve Auxiliary Pressurizer Spray Line CVS-PL-V084 Isolation C-C4 11304 Note 4 Note 8.1.6.5 Containment Spray AOVs T2,T3-A2,A6,A9 All Transfer open 3

FPS-PL-V701 Containment Spray Header AOVs 11500 Containment Atmosphere C-D0, C-8.1.6.6 T2,T3-A8,A10 All Transfer open and close Sampling Function B1-C-B6 PSS-PL-V001A/B Hot Leg Sample Isol Valves A10 11300 PSS-PL-V010A/B Liquid Sample Cont Isol Valves A10 11400 Containment Air Sample Cont.

PSS-PL-V008 A8, A10 C-D0 11400 Isolation Containment Atmosphere Sample PSS-PL-V024 A8, A10 11400 Return Isolation Containment Sump Sample PSS-PL-V002 A10 11400 Isolation Valve Page 23 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number Reactor Vessel Head Vent SOVs 2 valves in the 8.1.6.7 T2-A4 C-A5 Transfer open and close AOVs same flowpath RCS-PL-V150A Reactor Vessel Head Vent 11601 C-A5 RCS-PL-V150B Reactor Vessel Head Vent 11601 C-A5 RCS-PL-V150C Reactor Vessel Head Vent 11601 C-A5 RCS-PL-V150D Reactor Vessel Head Vent 11601 C-A5 PXS AOV T2, T3-A2 1 valve Transfer open CVS-PL-V089 PXS Makeup AOV 11300 PXS-PL-V234 IRWST makeup AOV 11400 8.1.7 19D.8.2.7 Motor-Operated Valves (MOVs)

CVS Charging and Injection 8.1.7.6 T2-A1 C-C0 All Transfer open MOVs CVS-PL-V091 Makeup Line Cont. Isolation C-C0 11300 8.1.7.7 RNS IRWST MOVs T2,T3-A2, A7 C-B6 All Transfer open and close RNS-PL-V024 IRWST Discharge Isolation Valve A2 C-B6 11206 RNS HL Suction to Spent Fuel 8.1.7.9 T3-A7 C-B8 Pool RNS HL Suction Isolation - Inner RNS-PL-V001A A2, A7 C-B8 11208 A

RNS HL Suction Isolation - Inner RNS-PL-V001B A2, A7 C-B8 11208 B 2 valves in the same RNS HL Suction & Cont. Isolation flowpath RNS-PL-V002A A2, A7 C-B8 11208

-A RNS HL Suction & Cont. Isolation RNS-PL-V002B A2, A7 C-B8 11208

-B 8.1.10 19D.8.2.10 Hydrogen Igniters 8.1.10 Hydrogen Igniters T2,T3-A8 See below Note 3 Ignite hydrogen Page 24 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number VLS-EH-01 Hydrogen Igniter 01, 1 C-B4 11204 VLS-EH-02 Hydrogen Igniter 02, 2 C-B4 11204 VLS-EH-03 Hydrogen Igniter 03, 1 C-B4 11204 VLS-EH-04 Hydrogen Igniter 04, 2 C-B4 11204 VLS-EH-05 Hydrogen Igniter 05, 1 C-D2 11402 VLS-EH-06 Hydrogen Igniter 06, 2 C-E2 11502 VLS-EH-07 Hydrogen Igniter 07, 2 C-D2 11402 VLS-EH-08 Hydrogen Igniter 08, 1 C-E2 11502 VLS-EH-09 Hydrogen Igniter 09, 1 C-C5 11305 VLS-EH-10 Hydrogen Igniter 10, 2 C-C5 11305 VLS-EH-11 Hydrogen Igniter 11, 2 C-D1 11401 VLS-EH-12 Hydrogen Igniter 12, 1 C-E1 11501 VLS-EH-13 Hydrogen Igniter 13, 1 C-D1 11401 VLS-EH-14 Hydrogen Igniter 14, 2 C-E1 11501 VLS-EH-15 Hydrogen Igniter 15, 2 C-C5 11305 VLS-EH-16 Hydrogen Igniter 16, 1 C-C5 11305 VLS-EH-17 Hydrogen Igniter 17, 2 C-B7 11207 VLS-EH-18 Hydrogen Igniter 18, 1 C-B7 11207 VLS-EH-19 Hydrogen Igniter 19, 2 C-B8 11208 VLS-EH-20 Hydrogen Igniter 20, 2 C-B6 11206 VLS-EH-21 Hydrogen Igniter 21, 1 C-B6 11206 VLS-EH-22 Hydrogen Igniter 22, 1 C-D0 11400 VLS-EH-23 Hydrogen Igniter 23, 2 C-D0 11400 VLS-EH-24 Hydrogen Igniter 24, 2 C-D0 11400 VLS-EH-25 Hydrogen Igniter 25, 2 C-D0 11400 Page 25 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number VLS-EH-26 Hydrogen Igniter 26, 2 C-D0 11400 VLS-EH-27 Hydrogen Igniter 27, 1 C-D0 11300 VLS-EH-28 Hydrogen Igniter 28, 1 C-D0 11400 VLS-EH-29 Hydrogen Igniter 29, 1 C-D0 11400 VLS-EH-30 Hydrogen Igniter 30, 2 C-D0 11403 VLS-EH-31 Hydrogen Igniter 31, 1 C-D0 11400 VLS-EH-32 Hydrogen Igniter 32, 1 C-D0 11400 VLS-EH-33 Hydrogen Igniter 33, 2 C-B9 11209 VLS-EH-34 Hydrogen Igniter 34, 1 C-B9 11209 VLS-EH-35 Hydrogen Igniter 35, 1 C-C5 11500 VLS-EH-36 Hydrogen Igniter 36, 2 C-C5 11500 VLS-EH-37 Hydrogen Igniter 37, 1 C-C5 11500 VLS-EH-38 Hydrogen Igniter 38, 2 C-C5 11500 VLS-EH-39 Hydrogen Igniter 39, 1 C-G1 11500 VLS-EH-40 Hydrogen Igniter 40, 2 C-G3 11500 VLS-EH-41 Hydrogen Igniter 41, 2 C-G2 11500 VLS-EH-42 Hydrogen Igniter 42, 1 C-G2 11500 VLS-EH-43 Hydrogen Igniter 43, 1 C-E0 11500 VLS-EH-44 Hydrogen Igniter 44, 1 C-G1 11500 VLS-EH-45 Hydrogen Igniter 45, 2 C-E0 11500 VLS-EH-46 Hydrogen Igniter 46, 2 C-G2 11500 VLS-EH-47 Hydrogen Igniter 47, 1 C-G2 11500 VLS-EH-48 Hydrogen Igniter 48, 2 C-G1 11500 VLS-EH-49 Hydrogen Igniter 49, 1 C-E3 11503 VLS-EH-50 Hydrogen Igniter 50, 2 C-E3 11503 Page 26 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number VLS-EH-51 Hydrogen Igniter 51, 1 C-H0 11500 VLS-EH-52 Hydrogen Igniter 52, 2 C-H0 11500 VLS-EH-53 Hydrogen Igniter 53, 2 C-H0 11500 VLS-EH-54 Hydrogen Igniter 54, 1 C-H0 11500 VLS-EH-55 Hydrogen Igniter 55, 1 C-E4 11504 VLS-EH-56 Hydrogen Igniter 56, 2 C-E4 11504 VLS-EH-57 Hydrogen Igniter 57, 2 C-E4 11504 VLS-EH-58 Hydrogen Igniter 58, 1 C-E4 11504 VLS-EH-59 Hydrogen Igniter 59, 2 C-E3 11503 VLS-EH-60 Hydrogen Igniter 60, 1 C-E3 11503 VLS-EH-61 Hydrogen Igniter 61, 1 C-H0 11500 VLS-EH-62 Hydrogen Igniter 62, 2 C-H0 11500 VLS-EH-63 Hydrogen Igniter 63, 1 C-H0 11500 VLS-EH-64 Hydrogen Igniter 64, 2 C-H0 11500 VLS-EH-65 Hydrogen Igniter 65, 1 11500 VLS-EH-66 Hydrogen Igniter 66, 2 11500 19D.8.2.11 Electrical Containment Penetration Assemblies Maintain containment Electrical Containment C-C0,C-8.1.11 T2,T3-A7 All boundary; Conduct electricity Penetration Assemblies D0,C-C6 for sensors and igniters ECS-EY-P01X Electrical Penetration P01 C-D0 11400 ECS-EY-P02X Electrical Penetration P02 C-D0 11400 DAS-EY-P03Z Electrical Penetration P03 C-D0 11400 ECS-EY-P06Y Electrical Penetration P06 C-D0 11400 ECS-EY-P07X Electrical Penetration P07 11400 Page 27 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number ECS-EY-P09W Electrical Penetration P09 C-D0 11400 ECS-EY-P10W Electrical Penetration P10 C-D0 11400 ECS IDSA-EY-P11Z 1E Electrical Penetration P11 C-C6 11400 ECS IDSA-EY-P12Y 1E Electrical Penetration P12 C-C6 11400 ECS IDSA-EY-P13Y 1E Electrical Penetration P13 C-C6 11400 ECS IDSD-EY-P14Z 1E Electrical Penetration P14 C-C6 11306 ECS IDSD-EY-P15Y 1E Electrical Penetration P15 C-C6 11306 ECS IDSD-EY-P16Y 1E Electrical Penetration P16 C-C6 11306 ECS-EY-P17X Electrical Penetration P17 11300 ECS-EY-P18X Electrical Penetration P18 C-C0 11300 ECS-EY-P19Z Electrical Penetration P19 11300 ECS-EY-P20Z Electrical Penetration P20 11300 ECS EDS-EY-P21Z 1E Electrical Penetration P21 C-C6 11300 ECS-EY-P22X Electrical Penetration P22 C-C0 11300 ECS-EY-P23X Electrical Penetration P23 C-C0 11300 ECS-EY-P24 Spare Electrical Penetration C-C0 11300 ECS-EY-P25W Electrical Penetration P25 C-C0 11300 ECS-EY-P26W Electrical Penetration P26 C-C0 11300 ECS IDSC-EY-P27Z 1E Electrical Penetration P27 C-C6 11300 ECS IDSC-EY-P28Y 1E Electrical Penetration P28 C-C6 11300 ECS IDSC-EY-P29Y 1E Electrical Penetration P29 C-C6 11300 ECS IDSB-EY-P30Z 1E Electrical Penetration P30 C-C6 11306 ECS IDSB-EY-P31Y 1E Electrical Penetration P31 C-C6 11306 ECS IDSB-EY-P32Y 1E Electrical Penetration P32 C-C6 11306 19D.8.2.12 Cables Page 28 of 30

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Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location Building Time Frames Section and Location Desired Channels/

Description T2,T3 and Actions Function Equip Tag No. Room Divisions (Note 5)

(Notes 6, 7)

Number Note 1 Note Conduct electricity for valves, 8.1.12 Cables T2,T3-A10 All 4 sensors and igniters 19D.8.2.13 Float Level Sensors T2,T3-8.1.13 PXS Containment Water Level C-A4,C-A5 2 Sense Level A2,A6,A9,A10 PXS-JE-LSLE050 Containment Floodup Level C-A4 11104 PXS-JE-LSLE052 Containment Floodup Level C-A4 11104 PXS-JE-LSLE051 Containment Floodup Level C-A5 11104 19D.8.2.14 Containment Hatches (Gasket Material Only)

Containment Hatches Maintain containment T2,T3-A7 All (Gasket Material Only) boundary CNS-MY-Y01 Equipment Hatch 11500 CNS-MY-Y02 Maintenance Hatch 11300 CNS-MY-Y03 Personnel Hatch - Upper 11500 CNS-MY-Y04 Personnel Hatch - Lower 11300 19D.8.2.15 Containment Vessel Containment Vessel T2,T3-A7 All Maintain containment boundary CNS-MV-01 Containment Shell Page 29 of 30

ND-18-0342 Reviewers Aid: Differences in COL Referenced Tables (LAR-18-001)

Notes:

a. Hot Leg RTDs could fail as temperature exceeds the designed condition.

b. If device fails, monitoring can be made through the Cont. Atmosphere Sampling Function.

c. Equipment is part of the fire protection system, on vertical pipe inside containment, feeding water to top rings, Room 11500.

d. Cables are located in most rooms inside containment.

1. Cables are located in most rooms inside containment.

2. A channel consists of two thermocouples within a single division. Each quadrant contains two divisions. The minimum requirement is two OPERABLE thermocouples in each of the two divisions for each quadrant. All Core Exit Thermocouples (CETs) are located inside the Reactor Pressure Vessel which is in Room 11105 (reactor cavity).

3. There are two groups of igniters. Each containment compartment and hydrogen pathway is covered by at least one igniter in each group. The minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway.

4. Equipment is part of the fire protection system, on vertical pipe inside containment, feeding water to top rings, Room 11500.

5. Time Frames T2 and T3 are beyond design basis, and therefore, only one channel of each instrumentation parameter is required to be OPERABLE. However, it is preferred to have more than one channel of each parameter available to resolve information ambiguity.

6. See Appendix 19D, Section 19D.4 for definitions of Equipment Survivability Time Frames T2 and T3.

7. See Appendix 19D, Section 19D.6 for Actions associated with Time Frames T2 and T3.

Time Frame T2 Time Frame T3

• A1 = Subsection 19D.6.2.1

• A1 = Subsection 19D.6.3.1

• A2 = Subsection 19D.6.2.2

• A2 = Subsection 19D.6.3.2

• A3 = Subsection 19D.6.2.3

• A3 = Subsection 19D.6.3.3

• A4 = Subsection 19D.6.2.4

• A4 = Subsection 19D.6.3.4

• A5 = Subsection 19D.6.2.5

• A5 = Subsection 19D.6.3.5

• A6 = Subsection 19D.6.2.6

• A6 = Subsection 19D.6.3.6

• A7 = Subsection 19D.6.2.7

• A7 = Subsection 19D.6.3.7

• A8 = Subsection 19D.6.2.8

• A8 = Subsection 19D.6.3.8

• A9 = Subsection 19D.6.2.9

• A9 = Subsection 19D.6.3.9

• A10 = Subsection 19D.6.2.10

• A10 = Subsection 19D.6.3.10 Page 30 of 30

Southern Nuclear Operating Company ND-18-0342 Enclosure 4 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Changes to the Licensing Basis Documents

- Public Information (LAR-18-001)

Note:

Added text is shown as Blue Underline Deleted text is shown as Red Strikethrough*

Relocated text is show in Green Underline and Strikethrough Omitted text is shown as three asterisks (*...*...*)

(This Enclosure consists of 37 pages, including this cover page)

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Hydrogen Igniter Relocation Related Changes Plant-Specific Tier 1 (and associated COL Appendix C) Changes Plant-Specific Tier 1 (and associated COL Appendix C) Section 2.3.9 -

Revise various Table 2.3.9-2 line items as shown below.

Equipment Name Tag Number Function Power Location Room Group No.

Number Hydrogen Igniter 09 VLS-EH-09 Energize 1 In-containment refueling water 11305 storage tank (IRWST) sparger side Hydrogen Igniter 10 VLS-EH-10 Energize 2 IRWST sparger side 11305 Hydrogen Igniter 15 VLS-EH-15 Energize 2 IRWST vacuum breaker vents 11305 Hydrogen Igniter 16 VLS-EH-16 Energize 1 IRWST vacuum breaker vents 11305 Hydrogen Igniter 27 VLS-EH-27 Energize 1 Lower compartment area 11400 (CMT and valve area) 11300 Hydrogen Igniter 30 VLS-EH-30 Energize 2 Loop compartment 01 11401 Lower compartment area 11403 (CMT and valve area)

Hydrogen Igniter 35 VLS-EH-35 Energize 1 IRWST hooded vents 11305 11500 Hydrogen Igniter 36 VLS-EH-36 Energize 2 IRWST hooded vents 11305 11500 Hydrogen Igniter 37 VLS-EH-37 Energize 1 IRWST hooded vents 11305 11500 Hydrogen Igniter 38 VLS-EH-38 Energize 2 IRWST hooded vents 11305 11500 Page 2 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Plant-Specific Tier 2 Changes Updated Final Safety Analysis Report (UFSAR) Section 6.2 - Revise Table 6.2.4-6, Igniter Location, to include the revisions shown below.

(Note that the table reflects a recently approved departure which is not yet incorporated into the docketed UFSAR.)

• IRWST - Hydrogen releases into the IRWST are controlled by the distribution of igniters internal to the IRWST and within near the vents from and into the IRWST.

o IRWST Sparger Side - Igniters are located within the IRWST just below the tank roof of the IRWST and near the spargers. In the event of hydrogen releases via the spargers, the igniters near the release points will provide the most immediate point of recombination.

o IRWST Roof Vents - Should the environment within the IRWST be inerted or otherwise not be ignited by the assemblies near the sparger, the hydrogen will be ignited as it exhausts from the IRWST at any of the vents fitted with igniter assemblies. The igniters are located in the upper compartment just above the vents.

o IRWST Vacuum Breaker Vents - In Finally, in the event that the IRWST is hydrogen rich and air is drawn into the IRWST the mixture will become flammable. In order to provide this recombination, the two inlet vents on the other side of the IRWST from the sparger side and primary exhaust vents are each fitted with an igniter.

o IRWST Hooded Vents - Should the environment within the IRWST be inerted or otherwise not be ignited by the assemblies near the sparger side, the hydrogen will be ignited as it exhausts from the IRWST by the igniters at the vent hoods. The igniters are located in the upper compartment just outside the vent hoods.

• Lower Compartment Area - *...*...* The hydrogen control protection is provided by igniters spread over the potential release areas and located either just above near the mezzanine deck elevation or near the ceiling.

Page 3 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

UFSAR Section 6.2 - Revise Table 6.2.4-7, Subcompartment/Area Igniter Coverage, to include the revisions shown below.

(Note that the table reflects a recently approved departure which is not yet incorporated into the docketed UFSAR.)

Igniter Coverage (Elevation)1 Subcompartment Power Group 1 Power Group 2 Tunnel connecting Loop 1 (El 89-3) 4 (El 96-6)

Compartments 3 (El 95) 2 (El 99) 31 (El 120) 30 (El 120132-8)

Lower Compartment Area 22 (El 134) 23, 24, 25 (El 134)

(CMT and Valve area) 27, (El 117-3) 26 (El 119-6) 28 (El 118-11) 30 (El 132-8 120) 29, 31, 32 (El 120)

IRWST Hooded Vents 35, 37 (El 137-6) 36, 38 (El 137-6)

Outlets IRWST Sparger Side Interior 9 (El 133-3) 10 (El 133-3)

IRWST Vacuum Breaker 16 (El 132-7) 15 (El 132-7)

Vents Inlet UFSAR Section 6.2 - Revise Figure 6.2.4-9, Hydrogen Igniter Locations Plan View Elevation 118-6, to include the revisions identified below and shown in Enclosure 5 (this figure contains security-related information and is withheld under 10 CFR 2.390d).

(Note that the figure reflects a recently approved departure which is not yet incorporated into the docketed UFSAR.)

The IGNITER #30 location is revised from Loop compartment 01 (Room 11401) to Room 11403, both of which are in the Lower compartment area (CMT and valve area) as shown in Enclosure 5.

UFSAR Section 6.2 - Revise Figure 6.2.4-10, Hydrogen Igniter Locations Plan View Elevation 135-3, to include the revisions identified below and shown in Enclosure 5 (this figure contains security-related information and is withheld under 10 CFR 2.390d).

(Note that the figure reflects a recently approved departure which is not yet incorporated into the docketed UFSAR.)

The IGNITER #35, IGNITER #36, IGNITER #37 and IGNITER #38 locations are revised from inside the IRWST (Room 11305) to outside the IRWST vent hoods located in the upper compartment lower region (Room 11500) as shown in Enclosure 5.

Page 4 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

UFSAR Section 6.2 - Revise Figure 6.2.4-13, Hydrogen Igniter Locations Section A-A, to include the revisions identified below and shown in Enclosure 5 (this figure contains security-related information and is withheld under 10 CFR 2.390d).

(Note that the figure reflects a recently approved departure which is not yet incorporated into the docketed UFSAR.)

The figure is revised to show IGNITER #30 in Room 11403 which is in the Lower compartment area (CMT and valve area) as shown in Enclosure 5.

UFSAR Incorporated by Reference Technical Requirements Manual (TRM) -

Revise Table TR 3.6.2-1, Hydrogen Igniters, item 9, to include the revisions shown below.

(Note that the TRM table reflects a recently approved departure which is not yet incorporated into the docketed UFSAR.)

REQUIRED LOCATION IGNITERS

9. IRWST Sparger Side 52

10. IRWST Vacuum Breaker Vents 2

11. IRWST Roof Vents 2

12. IRWST Hooded Vents 3 1213. Refueling Cavity 3 1314. Upper Compartment - Lower Region 9 1415. Upper Compartment - Mid Region 3 1516. Upper Compartment - Upper Region 3 Page 5 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Equipment Survivability Assessment Related Changes Combined License Change Combined License (COL) Section 2.D.(12), Site- and Unit-specific Conditions-Revise item (g)9 to reflect the modification of this amendment as shown below.

(g) Before initial fuel load, SNC shall:

9. Perform a thermal lag assessment of the as-built equipment listed in Tables 6b and 6c in Attachment A of APP-GW-GLR-069, Equipment Survivability Assessment, UFSAR Tables 19D-8 and 19D-9 to provide additional assurance that this equipment can perform its severe accident functions during environmental conditions resulting from hydrogen burns associated with severe accidents. SNC shall perform this assessment for equipment used for severe accident mitigation that has not been tested at severe accident conditions. SNC shall assess the ability of the as-built equipment to perform during accident hydrogen burns using the environment enveloping method or the test based thermal analysis method described in Electric Power Research Institute (EPRI) NP-4354, Large Scale Hydrogen Burn Equipment Experiments.

Plant-Specific Tier 1 (and associated COL Appendix C) Changes Plant-Specific Tier 1 (and associated COL Appendix C) Section 2.2.3 -

Delete item 9.c as shown below.

9. The PXS has the following features:

c) The equipment listed in Table 2.2.3-6 has sufficient thermal lag to withstand the effects of identified hydrogen burns associated with severe accidents.

Plant-Specific Tier 1 (and associated COL Appendix C) Section 2.2.3 - Revise ITAAC Table item 9.c as shown below.

No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 205 2.2.03.09c Not used per Amendment No. Type tests, analyses, or a A report exists and

1. 1. 1. 9.c) The equipment listed combination of type tests and concludes that the in Table 2.2.3-6 has sufficient analyses will be performed to thermal lag of this thermal lag to withstand the determine the thermal lag of equipment is greater effects of identified hydrogen this equipment. than the value required.

burns associated with severe accidents.

Page 6 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Plant-Specific Tier 1 (and associated COL Appendix C) Section 2.2.3 -

Delete Table 2.2.3-6 in its entirety.

Replace the table with Table 2.2.3-6 is not used.

UFSAR Changes UFSAR Section 19.59 - Revise Subsection 19.59.10.5, Combined License Information, sixth paragraph, as shown below.

A thermal lag assessment of the as-built equipment required to mitigate severe accidents (hydrogen igniters and containment penetrations) will be performed to provide additional assurance that this equipment can perform its severe accident functions during environmental conditions resulting from hydrogen burns associated with severe accidents. This assessment will be performed prior to fuel load and is required only for equipment used for severe accident mitigation that has not been tested at severe accident conditions. The ability of the as-built equipment to perform during severe accident hydrogen burns will be assessed using the Environment Enveloping method or the Test Based Thermal Analysis method discussed in EPRI NP-4354 (Reference 19.59-3).

UFSAR Section 19.59 - Revise Subsection 19.59.11, References, as shown below.

19.59-5. Not usedAPP-GW-GLR-069, Equipment Survivability Assessment, Westinghouse Electric Company LLC.

UFSAR Appendix 19D - Revise Subsection 19D.6.2.10, Accident Monitoring, first paragraph, as shown below.

During the initial core melting and relocation, containment hydrogen and radiation monitors are used for core damage assessment and verification of the hydrogen igniter operation. Steam generator radiation monitoring is used to determine steam generator tube integrity. In the longer term, containment atmosphere and containment liquid sampling can be used to monitor hydrogen and radiation. Containment pressure, temperature, and water level indication and RCS pressure need to be monitored throughout Time Frame 2.

Page 7 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

UFSAR Appendix 19D - Revise Subsection 19D.6.3.10, Accident Monitoring, as shown below.

Containment pressure, temperature, water level and radiation, steam generator radiation and the containment hydrogen concentration are sufficient to monitor the accident in the long-term.

Hydrogen concentration and radiation can be monitored with containment atmosphere and liquid sampling functions. In both Time Frame 2 and Time Frame 3, auxiliary building radiation monitors, if properly correlated, could be used for containment radiation monitoring.

UFSAR Appendix 19D - Revise Subsection 19D.8.2.6, Solenoid Valve, title as shown below.

19D.8.2.6, Solenoid-Operated Valves (SOVs) and Air-Operated Valves (AOVs)

UFSAR Appendix 19D - Revise to include new Subsection 19D.8.2.14, Containment Hatches (Gasket Material Only), new Subsection 19D.8.2.15, Containment Shell, and revise existing Subsection 19D.8.2.14, Assessment of Equipment for Sustained Burning, number and text, as shown below.

19D.8.2.14 Containment Hatches (Gasket Material Only)

The equipment hatch and a personnel hatch are located at the operating deck elevation. The maintenance hatch and a second personnel hatch are located at the maintenance floor elevation. The gasket material of the hatches is required to perform throughout the severe accident to maintain the containment pressure boundary. In the severe accident environment, during hydrogen combustion, the equipment experiences ambient temperature conditions beyond their design basis. However, the hatches are enclosed in the thick metal of the hatch barrels. The internal temperature does not rise beyond that experienced during design basis equipment qualification testing. Therefore, there is reasonable assurance of survivability of this equipment.

19D.8.2.15 Containment Shell The containment shell is used to maintain containment integrity. The shell is exposed to the severe accident environment in the upper compartment and Room 11300. The upper compartment shell is externally cooled by the PCS. In the analysis, the lower shell is modeled as a heat sink that is adiabatic on the external side and therefore provides the bounding temperature transient for the whole of the containment steel. The active operation time of the containment extends through Time Frame 3 (ex-vessel severe accident environment). The containment shell remains within the code limits during the severe accident. Therefore, the containment shell is expected to survive the severe accident pressure and temperatures predicted for the AP1000 plant.

Page 8 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001) 19D.8.2.1416 Assessment of Equipment for Sustained Burning

• ...*...* Table 19D-7 specifies the equipment and instrumentation used in Time Frames 2 and 3 to provide reasonable assurance of achieving a controlled stable state. The specific equipment located inside containment which must survive a severe accident for Time Frames 0 and 1 is listed in Table 19D-8 and in Table 19D-9 for severe accident Time Frames 2 and 3.

UFSAR Appendix 19D - Revise Table 19D-3, Equipment and Instrumentation Operation Prior to End of Time Frame 1 - Core Uncovery and Heatup, for the Accident Monitoring Action, Instrumentation column, as shown below.

Action Equipment Instrumentation Purpose Comment Containment

• containment

• containment isolation

• containment integrity

• containment isolation Isolation isolation system system valve position system often automatic

• containment

• containment pressure

• manual action in EOP shell

• penetrations

• containment hatches (gasket material only)

Accident Monitoring

• SG radiation

• accident management

• required by 10 CFR

• containment pressure

• emergency 50.34(f)

• containment response(1) temperature

• emergency action

• containment hydrogen levels(1) monitors

• containment water level

• containment radiation

• containment atmosphere sampling functions

• containment liquid sampling function

• auxiliary building radiation

• core-exit t/cs

• RCS pressure

• core-exit t/cs

• IRWST water level Page 9 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

UFSAR Appendix 19D - Revise Table 19D-4, Equipment and Instrumentation Operation Prior to End of Time Frame 2 - In-Vessel Core Melting and Relocation, for the Accident Monitoring Action, Instrumentation column, as shown below.

Action Equipment Instrumentation Purpose Comment Containment

• containment

• containment pressure

• containment integrity

• containment isolation Isolation shell system active operation

• penetrations completed in Time

• containment Frame 1 hatches (gasket material only)

Accident Monitoring

• SG radiation

• accident management

• active operation

• containment pressure

• emergency continues in Time

• containment response(1) Frame 2 temperature

• emergency action

• containment hydrogen levels(1) monitors

• containment water level

• containment radiation

• containment atmosphere sampling functions

• containment liquid sampling function

• auxiliary building radiation

• RCS pressure Page 10 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

UFSAR Appendix 19D - Revise Table 19D-5, Equipment and Instrumentation Operation During Time Frame 3 - Ex-Vessel Core Relocation, for the Accident Monitoring Action, Instrumentation column, as shown below.

Action Equipment Instrumentation Purpose Comment Containment

• containment

• containment pressure

• containment integrity

• active operation of Isolation shell

• containment containment isolation

• penetrations temperature system completed in

• containment Time Frame 1 hatches (gasket material only)

• RNS hot leg

• containment

• containment vent

• manual action within suction MOVs pressures SAMG

• SFP water level Accident Monitoring

• SG radiation

• accident management

• active operation

• containment pressure

• emergency continues in Time

• containment response(1) Frame 3 temperature

• emergency action

• containment hydrogen levels(1) monitors

• containment water level

• containment radiation

• containment atmosphere sampling functions

• containment liquid sampling function

• auxiliary building radiation

• RCS pressure Page 11 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

UFSAR Appendix 19D - Revise Table 19D-7, Sustained Hydrogen Combustion Survivability Assessment, for the Instrumentation section, as shown below.

EQUIPMENT AND SUSTAINED HYDROGEN COMBUSTION SURVIVABILITY ASSESSMENT INSTRUMENTATION Instrumentation Containment Atmosphere The capabilities to perform containment atmosphere sampling are discussed in Subsection Sampling Function 9.3.3.1.2.2 - Post-Accident Sampling. Successful containment atmosphere sampling is dependent on the availability of either of the hot leg sample source isolation valves and the containment atmosphere sampling isolation valves in series with the isolation valve. The sample return function is provided by the containment air sample return containment isolation valves. The sample isolation valve from reactor coolant hot leg number 1 is located in a different room from the fourth stage ADS valves. This precludes radiative heating, which could potentially cause operability concerns. The sample isolation valve from reactor coolant hot leg number 2 is located in a different room from the fourth stage ADS valves.

This precludes radiative heating, which could potentially cause operability concerns. The containment isolation valves are located less than 20 feet from a CMT. However, a steel shroud around base of the CMT prevents a sustained flame existing on the containment side of that CMT and, therefore, affecting the operability of either of the containment isolation valves.

The containment atmosphere sampling function provides a backup to the VLS hydrogen monitoring. The containment isolation valves are located less than 20 feet from the PXS-A compartment vent. The survivability of the valves has been considered in their placement in the containment. The sampling valve is located in Room 11300 which does not normally have a direct hydrogen source term. In the event of a specific primary pipe break (DVI line break), the potential hydrogen releases from the break would be mitigated by the ADS-4 valves and the hydrogen would be released to the loop compartment instead of Room 11300. The combination of failures that may be postulated to produce hydrogen releases and sustained burning in the vicinity has a low probability. There is reasonable assurance for the survivability of the valves by demonstrating that the valves survive the more likely hydrogen release scenarios.

Containment Liquid The capabilities to perform containment liquid atmosphere sampling are discussed in Sampling Function Subsection 9.3.3.1.2.2 - Post-Accident Sampling. Successful containment atmosphere sampling is dependent on the availability of either of the hot leg sample source isolation valves and the containment isolation valves in series with the isolation valve. The sample isolation valve from reactor coolant hot leg number 1 is located in a different room from the fourth stage ADS valves. This precludes radiative heating, which could potentially cause operability concerns. The sample isolation valve from reactor coolant hot leg number 2 is located in a different room from the fourth stage ADS valves. This precludes radiative heating, which could potentially cause operability concerns. The containment isolation valves are located less than 20 feet from a CMT. However, a steel shroud around base of the CMT prevents a sustained flame existing on the containment side of that CMT and, therefore, affecting the operability of either of the containment isolation valves.

The containment isolation valves are located less than 20 feet from the PXS-A compartment vent. The survivability of the valves has been considered in their placement in the containment. The sampling valve is located in Room 11300 which does not normally have a direct hydrogen source term. In the event of a specific primary pipe break (DVI line break),

potential hydrogen releases from the break would be mitigated by the ADS-4 valves and the hydrogen would be released to the loop compartment instead of Room 11300. The combination of failures that may be postulated to produce hydrogen releases from the break (DVI line break and common cause failures of multiple ADS-4 valves) and sustained burning in the vicinity of these valves has a low probability. Defense-in-depth precluding sustained combustion in this room provides reasonable assurance for the survivability of the valves, which are demonstrated to survive the more likely hydrogen release scenarios.

Page 12 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

UFSAR Appendix 19D - Add new Table 19D-8, Equipment Located Inside Containment (Time Frames T0 and T1) Equipment, Action Time Frame, and Equipment Location, and new Table 19D-9, Equipment Located Inside Containment (Time Frames T2 and T3)

Equipment, Action Time Frame, and Equipment Location, as shown on the following pages. [Note these are entirely new tables for the UFSAR and blue underline format is omitted.

For differences from previous licensing basis, see Enclosure 3.]

Page 13 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions 19D.8.2.1 Differential Pressure and Pressure Transmitters PXS - IRWST Water Level T0,T1-A1,A2,A3,A4,A10 2 Sense level PXS-JE-LT046 IRWST Level Transmitter 11300 PXS-JE-LT047 IRWST Level Transmitter 11300 PXS-JE-LT048 IRWST Level Transmitter 11300 RCS Pressure T0,T1-A1,A4,A5,A10 2 Sense pressure RCS-JE-PT140A RCS Wide Range Pressure Trans. A 11300 RCS-JE-PT140C RCS Wide Range Pressure Trans. C 11300 RCS-JE-PT140B RCS Wide Range Pressure Trans. B 11306 RCS-JE-PT140D RCS Wide Range Pressure Trans. D 11306 SG Wide Range Water Level T0,T1-A3,A5 2 per SG Sense level SGS-JE-LT012 SG 1 Wide Range Level Transmitter 11201 SGS-JE-LT016 SG 1 Wide Range Level Transmitter 11201 SGS-JE-LT011 SG 1 Wide Range Level Transmitter 11300 SGS-JE-LT015 SG 1 Wide Range Level Transmitter 11300 SGS-JE-LT013 SG 2 Wide Range Level Transmitter 11300 SGS-JE-LT014 SG 2 Wide Range Level Transmitter 11300 SGS-JE-LT017 SG 2 Wide Range Level Transmitter 11300 SGS-JE-LT018 SG 2 Wide Range Level Transmitter 11300 Containment Pressure T0,T1-A6,A7,A8,A10 2 Sense pressure PCS-JE-PT012 Extended Range Cont. Pressure 1 11400 PCS-JE-PT013 Extended Range Cont. Pressure 2 11400 PCS-JE-PT014 Extended Range Cont. Pressure 3 11400 19D.8.2.2 Thermocouples Core-exit Temperature T0,T1-A1,A2,A3,A10 2 (Note 2) Sense temperature IIS-JE-TE002 Core-exit Thermocouple, B09 11105 IIS-JE-TE003 Core-exit Thermocouple, C04 11105 Page 14 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions IIS-JE-TE005 Core-exit Thermocouple, C08 11105 IIS-JE-TE008 Core-exit Thermocouple, E02 11105 IIS-JE-TE010 Core-exit Thermocouple, E06 11105 IIS-JE-TE012 Core-exit Thermocouple, E10 11105 IIS-JE-TE015 Core-exit Thermocouple, G02 11105 IIS-JE-TE016 Core-exit Thermocouple, G04 11105 IIS-JE-TE017 Core-exit Thermocouple, G06 11105 IIS-JE-TE020 Core-exit Thermocouple, G12 11105 IIS-JE-TE021 Core-exit Thermocouple, G14 11105 IIS-JE-TE025 Core-exit Thermocouple, J08 11105 IIS-JE-TE026 Core-exit Thermocouple, J10 11105 IIS-JE-TE030 Core-exit Thermocouple, L04 11105 IIS-JE-TE033 Core-exit Thermocouple, L10 11105 IIS-JE-TE035 Core-exit Thermocouple, L14 11105 IIS-JE-TE038 Core-exit Thermocouple, N08 11105 IIS-JE-TE039 Core-exit Thermocouple, N10 11105 IIS-JE-TE040 Core-exit Thermocouple, N12 11105 IIS-JE-TE041 Core-exit Thermocouple, P07 11105 IIS-JE-TE001 Core-exit Thermocouple, B07 11105 IIS-JE-TE004 Core-exit Thermocouple, C06 11105 IIS-JE-TE006 Core-exit Thermocouple, C10 11105 IIS-JE-TE009 Core-exit Thermocouple, E04 11105 IIS-JE-TE013 Core-exit Thermocouple, E12 11105 IIS-JE-TE014 Core-exit Thermocouple, E14 11105 IIS-JE-TE018 Core-exit Thermocouple, G08 11105 IIS-JE-TE019 Core-exit Thermocouple, G10 11105 IIS-JE-TE022 Core-exit Thermocouple, J02 11105 Page 15 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions IIS-JE-TE023 Core-exit Thermocouple, J04 11105 IIS-JE-TE024 Core-exit Thermocouple, J06 11105 IIS-JE-TE027 Core-exit Thermocouple, J12 11105 IIS-JE-TE029 Core-exit Thermocouple, L02 11105 IIS-JE-TE031 Core-exit Thermocouple, L06 11105 IIS-JE-TE034 Core-exit Thermocouple, L12 11105 IIS-JE-TE036 Core-exit Thermocouple, N04 11105 IIS-JE-TE037 Core-exit Thermocouple, N06 11105 IIS-JE-TE007 Core-exit Thermocouple, C12 11105 IIS-JE-TE011 Core-exit Thermocouple, E08 11105 IIS-JE-TE028 Core-exit Thermocouple, K14 11105 IIS-JE-TE032 Core-exit Thermocouple, L08 11105 IIS-JE-TE042 Core-exit Thermocouple, P09 11105 19D.8.2.3 Resistance Temperature Detectors (RTDs)

Hot Leg RTDs T0,T1-A1,A3 2 Sense temperature RCS-JE-TE135A RCS Hot Leg 1 Wide Range RTD 11201 RCS-JE-TE135B RCS Hot Leg 2 Wide Range RTD 11202 Cold Leg RTDs T0,T1-A1,A3 2 Sense temperature RCS-JE-TE125A RCS Cold Leg 1A Wide Range RTD 11201 RCS-JE-TE125C RCS Cold Leg 1B Wide Range RTD 11201 RCS-JE-TE125B RCS Cold Leg 2A Wide Range RTD 11202 RCS-JE-TE125D RCS Cold Leg 2B Wide Range RTD 11202 Containment Temperature T0,T1-A10 2 Sense temperature VCS-JE-TE053A Operating Floor Area Temperature A 11500 VCS-JE-TE053B Operating Floor Area Temperature B 11500 IRWST Water Temperature T0,T1-A3,A4 2 Sense temperature Page 16 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions 11300, PXS-JE-TE041 IRWST Water Temperature 11305 11300, PXS-JE-TE042 IRWST Water Temperature 11305 11300, PXS-JE-TE043 IRWST Water Temperature 11305 11300, PXS-JE-TE044 IRWST Water Temperature 11305 19D.8.2.4 Hydrogen Monitors Hydrogen Monitors T0,T1-A8,A10 2 Sense concentration VLS-JE-AE001 Hydrogen Monitor 11500 VLS-JE-AE002 Hydrogen Monitor 11500 VLS-JE-AE003 Hydrogen Monitor 11500 19D.8.2.5 Radiation Monitors PXS Radiation Monitors T0,T1-A10 2 Sense radiation PXS-JE-RE160 Containment Radiation Detector A 11500 PXS-JE-RE161 Containment Radiation Detector B 11500 PXS-JE-RE162 Containment Radiation Detector C 11500 PXS-JE-RE163 Containment Radiation Detector D 11500 19D.8.2.6 Solenoid-Operated Valves (SOVs) and Air-Operated Valves (AOVs)

PXS Core Makeup Tank AOVs T0,T1-A1 1 per CMT Transfer open PXS-PL-V014A CMT A Discharge Isolation 11206 PXS-PL-V015A CMT A Discharge Isolation 11206 PXS-PL-V014B CMT B Discharge Isolation 11207 PXS-PL-V015B CMT B Discharge Isolation 11207 PXS PRHR AOVs T0,T1-A3,A4 1 Transfer open PXS-PL-V108A PRHR HX Control A 11300 PXS-PL-V108B PRHR HX Control B 11300 Page 17 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions Containment Isolation AOVs and T1-A7 All Varies, see below SOVs CVS-PL-V045 Letdown Containment Isolation 11300 Transfer close PSS-PL-V008 Cont. Air Sample Cont. Isolation 11400 Transfer open and close PSS-PL-V010A Liquid Sample Line Cont. Isolation A 11400 Transfer open and close PSS-PL-V010B Liquid Sample Line Cont. Isolation B 11400 Transfer open and close Containment Atmosphere Sample PSS-PL-V024 11400 Transfer open and close Return Isolation RNS-PL-V061 RNS Return from CVS Cont. Isolation 11208 Transfer close VFS-PL-V004 Cont. Purge Inlet Cont. Isolation 11400 Transfer open and close VFS-PL-V009 Cont. Purge Discharge Cont. Isolation 11400 Transfer open and close VWS-PL-V082 Fan Coolers Return Cont. Isolation 11500 Transfer close WLS-PL-V055 Sump Discharge Cont. Isolation 11300 Transfer close WLS-PL-V067 RCDT Gas Outlet Cont. Isolation 11300 Transfer close CVS RCS Boundary AOVs T0,T1-A1 All Transfer open and close RCS Purification Return Line Stop CVS-PL-V081 11304 Valve Auxiliary Pressurizer Spray Line CVS-PL-V084 11304 Isolation Containment Sampling Function T0,T1-A8,A10 All Transfer open and close PSS-PL-V001A/B Hot Leg Sample Isol Valves A10 11300 PSS-PL-V010A/B Liquid Sample Cont Isol Valves A10 11400 PSS-PL-V008 Containment Air Sample Cont. Isolation A8, A10 11400 Containment Atmosphere Sample PSS-PL-V024 A8, A10 11400 Return Isolation Containment Sump Sample Isolation PSS-PL-V002 A10 11400 Valve 2 valves in the Reactor Vessel Head Vent SOVs T1-A4 Transfer open and close same flowpath Page 18 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions RCS-PL-V150A Reactor Vessel Head Vent 11601 RCS-PL-V150B Reactor Vessel Head Vent 11601 RCS-PL-V150C Reactor Vessel Head Vent 11601 RCS-PL-V150D Reactor Vessel Head Vent 11601 19D.8.2.7 Motor-Operated Valves (MOVs)

PXS Accumulator MOVs T1-A1 1 per Accum Transfer open PXS-PL-V027A Accumulator A Discharge Isolation 11206 PXS-PL-V027B Accumulator B Discharge Isolation 11207 PXS Core Makeup Tank MOVs T0,T1-A1 1 per CMT Transfer open PXS-PL-V002A CMT A Inlet Isolation 11400 PXS-PL-V002B CMT B Inlet Isolation 11400 PXS Recirculation MOVs T1-A2 1 Transfer open PXS-PL-V117A Cont. Recirculation. A Isolation 11206 PXS-PL-V117B Cont. Recirculation. B Isolation 11207 Page 19 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions 1 flowpath ADS Stages 1, 2, 3, & 4 MOVs T1-A4 Transfer open per stage RCS-PL-V001A First Stage ADS A 11703 RCS-PL-V011A First Stage ADS Isolation A 11703 RCS-PL-V002A Second Stage ADS A 11703 RCS-PL-V012A Second Stage ADS Isolation A 11703 RCS-PL-V003A Third Stage ADS A 11703 RCS-PL-V013A Third Stage ADS Isolation A 11703 RCS-PL-V001B First Stage ADS B 11603 RCS-PL-V011B First Stage ADS Isolation B 11603 RCS-PL-V002B Second Stage ADS B 11603 RCS-PL-V012B Second Stage ADS Isolation B 11603 RCS-PL-V003B Third Stage ADS B 11603 RCS-PL-V013B Third Stage ADS Isolation B 11603 RCS-PL-V014A Fourth Stage ADS MOV 11301 RCS-PL-V014B Fourth Stage ADS MOV 11302 RCS-PL-V014C Fourth Stage ADS MOV 11301 RCS-PL-V014D Fourth Stage ADS MOV 11302 Containment Isolation MOVs T1-A7 All Varies, see below CCS-PL-V207 CCS Containment Isolation Valve 11400 Transfer close CVS-PL-V091 Makeup Line Cont. Isolation 11300 Transfer open and close RNS-PL-V002A RNS HL Suction & Cont. Isolation - A 11208 Transfer open and close RNS-PL-V002B RNS HL Suction & Cont. Isolation - B 11208 Transfer open and close RNS Suction from IRWST - Cont.

RNS-PL-V023 11208 Transfer open and close Isolation SFS-PL-V034 SFS Suction Line Cont. Isolation. 11206 Transfer close Page 20 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions CVS Charging and Injection MOVs T0,T1-A1 1 Transfer open and close CVS-PL-V091 Makeup Line Cont. Isolation 11300 RNS MOVs T1-A1 2 Transfer open and close RNS-PL-V001A/B RNS Suction Isol from Hot Leg 11208 RNS-PL-V002A/B RNS Suction Isol from Hot Leg 11208 RNS Suction from IRWST - Cont.

RNS-PL-V023 11208 Isolation RNS-PL-V024 IRWST Discharge Isolation Valve 11206 PXS PRHR MOV T0,T1-A3,A4 1 Transfer open PXS-PL-V101 PRHR HX Inlet Isolation 11500 19D.8.2.8 Squib Valves IRWST Injection T1-A2 2 Transfer open PXS-PL-V123A IRWST Injection Line A Squib Valve 11206 PXS-PL-V125A IRWST Injection Line A Squib Valve 11206 PXS-PL-V123B IRWST Injection Line B Squib Valve 11207 PXS-PL-V125B IRWST Injection Line B Squib Valve 11207 PXS Containment Recirculation T1-A2 2 Transfer open PXS-PL-V118A Cont. Recirculation A Squib Valve 11206 PXS-PL-V120A Cont. Recirculation A Squib Valve 11206 PXS-PL-V118B Cont. Recirculation B Squib Valve 11207 PXS-PL-V120B Cont. Recirculation B Squib Valve 11207 Fourth Stage ADS T1-A4 3 Transfer open RCS-PL-V004A Fourth Stage ADS A 11301 RCS-PL-V004C Fourth Stage ADS C 11301 RCS-PL-V004B Fourth Stage ADS B 11302 RCS-PL-V004D Fourth Stage ADS D 11302 Page 21 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions 19D.8.2.9 Position Sensors Valve Position Sensors T1-A7 All Sense valve position CCS-PL-V207-L CCS Containment Isolation Valve 11400 CVS-PL-V045-L Letdown Containment Isolation 11300 CVS-PL-V091-L Makeup Line Cont. Isolation 11300 PSS-PL-V008-L Containment Air Sample Cont. Isolation 11400 PSS-PL-V010A-L Liquid Sample Cont. Isolation Valve A 11400 PSS-PL-V010B-L Liquid Sample Cont. Isolation Valve B 11400 Containment Atmosphere Sample PSS-PL-V024-L 11400 Return Isolation RNS-PL-V002A-L RNS HL Suction & Cont. Isolation - A 11208 RNS-PL-V002B-L RNS HL Suction & Cont. Isolation - B 11208 RNS Suction from IRWST - Cont.

RNS-PL-V023-L 11208 Isolation RNS-PL-V061-L RNS Return from CVS - Cont. Isolation 11208 SFS-PL-V034-L SFS Suction Line Cont. Isolation. 11206 VFS-PL-V004-L Containment Purge Inlet Cont. Isolation 11400 VFS-PL-V009-L Containment Discharge Cont. Isolation 11400 Fan Coolers Return Cont. Isolation VWS-PL-V082-L 11500 Valve WLS-PL-V055-L Sump Discharge Cont. Isolation 11300 WLS-PL-V067-L RCDT Gas Outlet Cont. Isolation 11300 19D.8.2.10 Hydrogen Igniters Hydrogen Igniters T1-A8 Note 3 Ignite hydrogen VLS-EH-01 Hydrogen Igniter 01, 1 11204 VLS-EH-02 Hydrogen Igniter 02, 2 11204 VLS-EH-03 Hydrogen Igniter 03, 1 11204 VLS-EH-04 Hydrogen Igniter 04, 2 11204 Page 22 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions VLS-EH-05 Hydrogen Igniter 05, 1 11402 VLS-EH-06 Hydrogen Igniter 06, 2 11502 VLS-EH-07 Hydrogen Igniter 07, 2 11402 VLS-EH-08 Hydrogen Igniter 08, 1 11502 VLS-EH-09 Hydrogen Igniter 09, 1 11305 VLS-EH-10 Hydrogen Igniter 10, 2 11305 VLS-EH-11 Hydrogen Igniter 11, 2 11401 VLS-EH-12 Hydrogen Igniter 12, 1 11501 VLS-EH-13 Hydrogen Igniter 13, 1 11401 VLS-EH-14 Hydrogen Igniter 14, 2 11501 VLS-EH-15 Hydrogen Igniter 15, 2 11305 VLS-EH-16 Hydrogen Igniter 16, 1 11305 VLS-EH-17 Hydrogen Igniter 17, 2 11207 VLS-EH-18 Hydrogen Igniter 18, 1 11207 VLS-EH-19 Hydrogen Igniter 19, 2 11208 VLS-EH-20 Hydrogen Igniter 20, 2 11206 VLS-EH-21 Hydrogen Igniter 21, 1 11206 VLS-EH-22 Hydrogen Igniter 22, 1 11400 VLS-EH-23 Hydrogen Igniter 23, 2 11400 VLS-EH-24 Hydrogen Igniter 24, 2 11400 VLS-EH-25 Hydrogen Igniter 25, 2 11400 VLS-EH-26 Hydrogen Igniter 26, 2 11400 VLS-EH-27 Hydrogen Igniter 27, 1 11300 VLS-EH-28 Hydrogen Igniter 28, 1 11400 VLS-EH-29 Hydrogen Igniter 29, 1 11400 VLS-EH-30 Hydrogen Igniter 30, 2 11403 VLS-EH-31 Hydrogen Igniter 31, 1 11400 Page 23 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions VLS-EH-32 Hydrogen Igniter 32, 1 11400 VLS-EH-33 Hydrogen Igniter 33, 2 11209 VLS-EH-34 Hydrogen Igniter 34, 1 11209 VLS-EH-35 Hydrogen Igniter 35, 1 11500 VLS-EH-36 Hydrogen Igniter 36, 2 11500 VLS-EH-37 Hydrogen Igniter 37, 1 11500 VLS-EH-38 Hydrogen Igniter 38, 2 11500 VLS-EH-39 Hydrogen Igniter 39, 1 11500 VLS-EH-40 Hydrogen Igniter 40, 2 11500 VLS-EH-41 Hydrogen Igniter 41, 2 11500 VLS-EH-42 Hydrogen Igniter 42, 1 11500 VLS-EH-43 Hydrogen Igniter 43, 1 11500 VLS-EH-44 Hydrogen Igniter 44, 1 11500 VLS-EH-45 Hydrogen Igniter 45, 2 11500 VLS-EH-46 Hydrogen Igniter 46, 2 11500 VLS-EH-47 Hydrogen Igniter 47, 1 11500 VLS-EH-48 Hydrogen Igniter 48, 2 11500 VLS-EH-49 Hydrogen Igniter 49, 1 11503 VLS-EH-50 Hydrogen Igniter 50, 2 11503 VLS-EH-51 Hydrogen Igniter 51, 1 11500 VLS-EH-52 Hydrogen Igniter 52, 2 11500 VLS-EH-53 Hydrogen Igniter 53, 2 11500 VLS-EH-54 Hydrogen Igniter 54, 1 11500 VLS-EH-55 Hydrogen Igniter 55, 1 11504 VLS-EH-56 Hydrogen Igniter 56, 2 11504 VLS-EH-57 Hydrogen Igniter 57, 2 11504 VLS-EH-58 Hydrogen Igniter 58, 1 11504 Page 24 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions VLS-EH-59 Hydrogen Igniter 59, 2 11503 VLS-EH-60 Hydrogen Igniter 60, 1 11503 VLS-EH-61 Hydrogen Igniter 61, 1 11500 VLS-EH-62 Hydrogen Igniter 62, 2 11500 VLS-EH-63 Hydrogen Igniter 63, 1 11500 VLS-EH-64 Hydrogen Igniter 64, 2 11500 VLS-EH-65 Hydrogen Igniter 65, 1 11500 VLS-EH-66 Hydrogen Igniter 66, 2 11500 19D.8.2.11 Electrical Containment Penetration Assemblies Maintain containment boundary; Electrical Containment Penetration T1-A7 All Conduct electricity for sensors Assemblies and igniters ECS-EY-P01X Electrical Penetration P01 11400 ECS-EY-P02X Electrical Penetration P02 11400 DAS-EY-P03Z Electrical Penetration P03 11400 ECS-EY-P06Y Electrical Penetration P06 11400 ECS-EY-P07X Electrical Penetration P07 11400 ECS-EY-P09W Electrical Penetration P09 11400 ECS-EY-P10W Electrical Penetration P10 11400 IDSA-EY-P11Z 1E Electrical Penetration P11 11400 IDSA-EY-P12Y 1E Electrical Penetration P12 11400 IDSA-EY-P13Y 1E Electrical Penetration P13 11400 IDSD-EY-P14Z 1E Electrical Penetration P14 11306 IDSD-EY-P15Y 1E Electrical Penetration P15 11306 IDSD-EY-P16Y 1E Electrical Penetration P16 11306 ECS-EY-P17X Electrical Penetration P17 11300 ECS-EY-P18X Electrical Penetration P18 11300 Page 25 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions ECS-EY-P19Z Electrical Penetration P19 11300 ECS-EY-P20Z Electrical Penetration P20 11300 EDS-EY-P21Z Electrical Penetration P21 11300 ECS-EY-P22X Electrical Penetration P22 11300 ECS-EY-P23X Electrical Penetration P23 11300 ECS-EY-P24 Spare Electrical Penetration 11300 ECS-EY-P25W Electrical Penetration P25 11300 ECS-EY-P26W Electrical Penetration P26 11300 IDSC-EY-P27Z 1E Electrical Penetration P27 11300 IDSC-EY-P28Y 1E Electrical Penetration P28 11300 IDSC-EY-P29Y 1E Electrical Penetration P29 11300 IDSB-EY-P30Z 1E Electrical Penetration P30 11306 IDSB-EY-P31Y 1E Electrical Penetration P31 11306 IDSB-EY-P32Y 1E Electrical Penetration P32 11306 19D.8.2.12 Cables Conduct electricity for valves, Cables T0,T1-A10 Note 1 All sensors and igniters 19D.8.2.13 Float Level Sensors PXS Containment Water Level T0,T1-A2,A10 2 Sense level PXS-JE-LE050 Containment Floodup Level 11104 PXS-JE-LE052 Containment Floodup Level 11104 PXS-JE-LE051 Containment Floodup Level 11104 19D.8.2.14 Containment Hatches (Gasket Material Only)

Containment Hatches T0,T1-A7 All Maintain containment boundary (Gasket Material Only)

CNS-MY-Y01 Equipment Hatch 11500 CNS-MY-Y02 Maintenance Hatch 11300 Page 26 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-8: Equipment Located Inside Containment (Time Frames T0 and T1)

Time Frames T0,T1 Required Section and Room Description and Actions Channels/ Function Equip Tag No. Number (Notes 4, 5) Divisions CNS-MY-Y03 Personnel Hatch - Upper 11500 CNS-MY-Y04 Personnel Hatch - Lower 11300 19D.8.2.15 Containment Vessel Containment Vessel T0,T1-A7 Maintain containment boundary CNS-MV-01 Containment Shell Notes:

1. Cables are located in most rooms inside containment.

2. A channel consists of two thermocouples within a single division. Each quadrant contains two divisions. The minimum requirement is two OPERABLE thermocouples in each of the two divisions for each quadrant. All Core Exit Thermocouples are located inside the Reactor Pressure Vessel which is in Room 11105 (reactor cavity).

3. There are two groups of igniters. Each containment compartment and hydrogen pathway is covered by at least one igniter in each group. The minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway.

4. See Appendix 19D, Section 19D.4 for definitions of Equipment Survivability Time Frames T0 and T1.

5. See Appendix 19D, Section 19D.6 for Actions associated with Time Frames T0 and T1.

• A1 = Subsection 19D.6.1.1

• A2 = Subsection 19D.6.1.2

• A3 = Subsection 19D.6.1.3

• A4 = Subsection 19D.6.1.4

• A5 = Subsection 19D.6.1.5

• A6 = Subsection 19D.6.1.6

• A7 = Subsection 19D.6.1.7

• A8 = Subsection 19D.6.1.8

• A10 = Subsection 19D.6.1.9 Page 27 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5) 19D.8.2.1 Differential Pressure and Pressure Transmitters RCS Pressure T2-A1,A4,A10 2 Sense pressure RCS-JE-PT140A RCS Wide Range Pressure Trans. A 11300 RCS-JE-PT140C RCS Wide Range Pressure Trans. C 11300 RCS-JE-PT140B RCS Wide Range Pressure Trans. B 11306 RCS-JE-PT140D RCS Wide Range Pressure Trans. D 11306 SG Wide Range Water Level T2-A3 2 per SG Sense level SGS-JE-LT012 SG 1 Wide Range Level Transmitter 11201 SGS-JE-LT016 SG 1 Wide Range Level Transmitter 11201 SGS-JE-LT011 SG 1 Wide Range Level Transmitter 11300 SGS-JE-LT015 SG 1 Wide Range Level Transmitter 11300 SGS-JE-LT013 SG 2 Wide Range Level Transmitter 11300 SGS-JE-LT014 SG 2 Wide Range Level Transmitter 11300 SGS-JE-LT017 SG 2 Wide Range Level Transmitter 11300 SGS-JE-LT018 SG 2 Wide Range Level Transmitter 11300 T2-A1,T2,T3-Containment Pressure 2 Sense pressure A6,A7,A8,A10 PCS-JE-PT012 Extended Range Cont. Pressure 1 11400 PCS-JE-PT013 Extended Range Cont. Pressure 2 11400 PCS-JE-PT014 Extended Range Cont. Pressure 3 11400 19D.8.2.2 Thermocouples Core-exit Temperature T2-A3, A10 2 (Note 2) Sense temperature IIS-JE-TE002 Core-exit Thermocouple, B09 11105 IIS-JE-TE003 Core-exit Thermocouple, C04 11105 IIS-JE-TE005 Core-exit Thermocouple, C08 11105 IIS-JE-TE008 Core-exit Thermocouple, E02 11105 Page 28 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

IIS-JE-TE010 Core-exit Thermocouple, E06 11105 IIS-JE-TE012 Core-exit Thermocouple, E10 11105 IIS-JE-TE015 Core-exit Thermocouple, G02 11105 IIS-JE-TE016 Core-exit Thermocouple, G04 11105 IIS-JE-TE017 Core-exit Thermocouple, G06 11105 IIS-JE-TE020 Core-exit Thermocouple, G12 11105 IIS-JE-TE021 Core-exit Thermocouple, G14 11105 IIS-JE-TE025 Core-exit Thermocouple, J08 11105 IIS-JE-TE026 Core-exit Thermocouple, J10 11105 IIS-JE-TE030 Core-exit Thermocouple, L04 11105 IIS-JE-TE033 Core-exit Thermocouple, L10 11105 IIS-JE-TE035 Core-exit Thermocouple, L14 11105 IIS-JE-TE038 Core-exit Thermocouple, N08 11105 IIS-JE-TE039 Core-exit Thermocouple, N10 11105 IIS-JE-TE040 Core-exit Thermocouple, N12 11105 IIS-JE-TE041 Core-exit Thermocouple, P07 11105 IIS-JE-TE001 Core-exit Thermocouple, B07 11105 IIS-JE-TE004 Core-exit Thermocouple, C06 11105 IIS-JE-TE006 Core-exit Thermocouple, C10 11105 IIS-JE-TE009 Core-exit Thermocouple, E04 11105 IIS-JE-TE013 Core-exit Thermocouple, E12 11105 IIS-JE-TE014 Core-exit Thermocouple, E14 11105 IIS-JE-TE018 Core-exit Thermocouple, G08 11105 IIS-JE-TE019 Core-exit Thermocouple, G10 11105 IIS-JE-TE022 Core-exit Thermocouple, J02 11105 IIS-JE-TE023 Core-exit Thermocouple, J04 11105 Page 29 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

IIS-JE-TE024 Core-exit Thermocouple, J06 11105 IIS-JE-TE027 Core-exit Thermocouple, J12 11105 IIS-JE-TE029 Core-exit Thermocouple, L02 11105 IIS-JE-TE031 Core-exit Thermocouple, L06 11105 IIS-JE-TE034 Core-exit Thermocouple, L12 11105 IIS-JE-TE036 Core-exit Thermocouple, N04 11105 IIS-JE-TE037 Core-exit Thermocouple, N06 11105 IIS-JE-TE007 Core-exit Thermocouple, C12 11105 IIS-JE-TE011 Core-exit Thermocouple, E08 11105 IIS-JE-TE028 Core-exit Thermocouple, K14 11105 IIS-JE-TE032 Core-exit Thermocouple, L08 11105 IIS-JE-TE042 Core-exit Thermocouple, P09 11105 19D.8.2.3 Resistance Temperature Detectors (RTDs)

Hot Leg RTDs T2-A1,A3 2 Sense temperature RCS-JE-TE135A RCS Hot Leg 1 Wide Range RTD 11201 RCS-JE-TE135B RCS Hot Leg 2 Wide Range RTD 11202 Cold Leg RTDs T2-A1,A3 2 Sense temperature RCS-JE-TE125A RCS Cold Leg 1A Wide Range RTD 11201 RCS-JE-TE125C RCS Cold Leg 1B Wide Range RTD 11201 RCS-JE-TE125B RCS Cold Leg 2A Wide Range RTD 11202 RCS-JE-TE125D RCS Cold Leg 2B Wide Range RTD 11202 Containment Temperature T3-A7,T2,T3-A10 2 Sense temperature VCS-JE-TE053A Operating Floor Area Temperature A 11500 VCS-JE-TE053B Operating Floor Area Temperature B 11500 19D.8.2.4 Hydrogen Monitors Hydrogen Monitors T2-A8,T2,T3-A10 2 Sense concentration Page 30 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

VLS-JE-AE001 Hydrogen Monitor 11500 VLS-JE-AE002 Hydrogen Monitor 11500 VLS-JE-AE003 Hydrogen Monitor 11500 19D.8.2.5 Radiation Monitors PXS Radiation Monitors T2,T3-A10 2 Sense radiation PXS-JE-RE160 Containment Radiation Detector A 11500 PXS-JE-RE161 Containment Radiation Detector B 11500 PXS-JE-RE162 Containment Radiation Detector C 11500 PXS-JE-RE163 Containment Radiation Detector D 11500 19D.8.2.6 Solenoid-Operated Valves (SOVs) and Air-Operated Valves (AOVs)

CVS RCS Boundary AOVs T2-A1,A4 All Transfer open and close RCS Purification Return Line Stop CVS-PL-V081 11304 Valve Auxiliary Pressurizer Spray Line CVS-PL-V084 Isolation 11304 Containment Spray AOVs T2,T3-A2,A6,A9 Note 4 All Transfer open FPS-PL-V701 Containment Spray Header AOV 11500 Containment Sampling Function T2,T3-A8,A10 All Transfer open and close PSS-PL-V001A/B Hot Leg Sample Isol Valves A10 11300 PSS-PL-V010A/B Liquid Sample Cont Isol Valves A10 11400 Containment Air Sample Cont.

PSS-PL-V008 A8, A10 11400 Isolation Containment Atmosphere Sample PSS-PL-V024 A8, A10 11400 Return Isolation Containment Sump Sample Isolation PSS-PL-V002 A10 11400 Valve Page 31 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5) 2 valves in the Reactor Vessel Head Vent SOVs T2-A4 Transfer open and close same flowpath RCS-PL-V150A Reactor Vessel Head Vent 11601 RCS-PL-V150B Reactor Vessel Head Vent 11601 RCS-PL-V150C Reactor Vessel Head Vent 11601 RCS-PL-V150D Reactor Vessel Head Vent 11601 PXS AOV T2, T3-A2 1 valve Transfer open CVS-PL-V089 PXS Makeup AOV 11300 PXS-PL-V234 IRWST makeup AOV 11400 19D.8.2.7 Motor-Operated Valves (MOVs)

CVS Charging and Injection MOVs T2-A1 All Transfer open CVS-PL-V091 Makeup Line Cont. Isolation 11300 RNS MOVs T2,T3-A2, A7 All Transfer open and close RNS-PL-V024 IRWST Discharge Isolation Valve A2 11206 RNS-PL-V001A RNS HL Suction Isolation - Inner A A2, A7 11208 RNS-PL-V001B RNS HL Suction Isolation - Inner B A2, A7 11208 2 valves in the RNS-PL-V002A RNS HL Suction & Cont. Isolation - A A2, A7 11208 same flowpath RNS-PL-V002B RNS HL Suction & Cont. Isolation - B A2, A7 11208 19D.8.2.10 Hydrogen Igniters Hydrogen Igniters T2,T3-A8 Note 3 Ignite hydrogen VLS-EH-01 Hydrogen Igniter 01, 1 11204 VLS-EH-02 Hydrogen Igniter 02, 2 11204 VLS-EH-03 Hydrogen Igniter 03, 1 11204 VLS-EH-04 Hydrogen Igniter 04, 2 11204 VLS-EH-05 Hydrogen Igniter 05, 1 11402 VLS-EH-06 Hydrogen Igniter 06, 2 11502 Page 32 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

VLS-EH-07 Hydrogen Igniter 07, 2 11402 VLS-EH-08 Hydrogen Igniter 08, 1 11502 VLS-EH-09 Hydrogen Igniter 09, 1 11305 VLS-EH-10 Hydrogen Igniter 10, 2 11305 VLS-EH-11 Hydrogen Igniter 11, 2 11401 VLS-EH-12 Hydrogen Igniter 12, 1 11501 VLS-EH-13 Hydrogen Igniter 13, 1 11401 VLS-EH-14 Hydrogen Igniter 14, 2 11501 VLS-EH-15 Hydrogen Igniter 15, 2 11305 VLS-EH-16 Hydrogen Igniter 16, 1 11305 VLS-EH-17 Hydrogen Igniter 17, 2 11207 VLS-EH-18 Hydrogen Igniter 18, 1 11207 VLS-EH-19 Hydrogen Igniter 19, 2 11208 VLS-EH-20 Hydrogen Igniter 20, 2 11206 VLS-EH-21 Hydrogen Igniter 21, 1 11206 VLS-EH-22 Hydrogen Igniter 22, 1 11400 VLS-EH-23 Hydrogen Igniter 23, 2 11400 VLS-EH-24 Hydrogen Igniter 24, 2 11400 VLS-EH-25 Hydrogen Igniter 25, 2 11400 VLS-EH-26 Hydrogen Igniter 26, 2 11400 VLS-EH-27 Hydrogen Igniter 27, 1 11300 VLS-EH-28 Hydrogen Igniter 28, 1 11400 VLS-EH-29 Hydrogen Igniter 29, 1 11400 VLS-EH-30 Hydrogen Igniter 30, 2 11403 VLS-EH-31 Hydrogen Igniter 31, 1 11400 VLS-EH-32 Hydrogen Igniter 32, 1 11400 Page 33 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

VLS-EH-33 Hydrogen Igniter 33, 2 11209 VLS-EH-34 Hydrogen Igniter 34, 1 11209 VLS-EH-35 Hydrogen Igniter 35, 1 11500 VLS-EH-36 Hydrogen Igniter 36, 2 11500 VLS-EH-37 Hydrogen Igniter 37, 1 11500 VLS-EH-38 Hydrogen Igniter 38, 2 11500 VLS-EH-39 Hydrogen Igniter 39, 1 11500 VLS-EH-40 Hydrogen Igniter 40, 2 11500 VLS-EH-41 Hydrogen Igniter 41, 2 11500 VLS-EH-42 Hydrogen Igniter 42, 1 11500 VLS-EH-43 Hydrogen Igniter 43, 1 11500 VLS-EH-44 Hydrogen Igniter 44, 1 11500 VLS-EH-45 Hydrogen Igniter 45, 2 11500 VLS-EH-46 Hydrogen Igniter 46, 2 11500 VLS-EH-47 Hydrogen Igniter 47, 1 11500 VLS-EH-48 Hydrogen Igniter 48, 2 11500 VLS-EH-49 Hydrogen Igniter 49, 1 11503 VLS-EH-50 Hydrogen Igniter 50, 2 11503 VLS-EH-51 Hydrogen Igniter 51, 1 11500 VLS-EH-52 Hydrogen Igniter 52, 2 11500 VLS-EH-53 Hydrogen Igniter 53, 2 11500 VLS-EH-54 Hydrogen Igniter 54, 1 11500 VLS-EH-55 Hydrogen Igniter 55, 1 11504 VLS-EH-56 Hydrogen Igniter 56, 2 11504 VLS-EH-57 Hydrogen Igniter 57, 2 11504 VLS-EH-58 Hydrogen Igniter 58, 1 11504 Page 34 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

VLS-EH-59 Hydrogen Igniter 59, 2 11503 VLS-EH-60 Hydrogen Igniter 60, 1 11503 VLS-EH-61 Hydrogen Igniter 61, 1 11500 VLS-EH-62 Hydrogen Igniter 62, 2 11500 VLS-EH-63 Hydrogen Igniter 63, 1 11500 VLS-EH-64 Hydrogen Igniter 64, 2 11500 VLS-EH-65 Hydrogen Igniter 65, 1 11500 VLS-EH-66 Hydrogen Igniter 66, 2 11500 19D.8.2.11 Electrical Containment Penetration Assemblies Maintain containment boundary; Electrical Containment Penetration T2,T3-A7 All Conduct electricity for sensors Assemblies and igniters ECS-EY-P01X Electrical Penetration P01 11400 ECS-EY-P02X Electrical Penetration P02 11400 DAS-EY-P03Z Electrical Penetration P03 11400 ECS-EY-P06Y Electrical Penetration P06 11400 ECS-EY-P07X Electrical Penetration P07 11400 ECS-EY-P09W Electrical Penetration P09 11400 ECS-EY-P10W Electrical Penetration P10 11400 IDSA-EY-P11Z 1E Electrical Penetration P11 11400 IDSA-EY-P12Y 1E Electrical Penetration P12 11400 IDSA-EY-P13Y 1E Electrical Penetration P13 11400 IDSD-EY-P14Z 1E Electrical Penetration P14 11306 IDSD-EY-P15Y 1E Electrical Penetration P15 11306 IDSD-EY-P16Y 1E Electrical Penetration P16 11306 ECS-EY-P17X Electrical Penetration P17 11300 ECS-EY-P18X Electrical Penetration P18 11300 Page 35 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

ECS-EY-P19Z Electrical Penetration P19 11300 ECS-EY-P20Z Electrical Penetration P20 11300 EDS-EY-P21Z Electrical Penetration P21 11300 ECS-EY-P22X Electrical Penetration P22 11300 ECS-EY-P23X Electrical Penetration P23 11300 ECS-EY-P24 Spare Electrical Penetration 11300 ECS-EY-P25W Electrical Penetration P25 11300 ECS-EY-P26W Electrical Penetration P26 11300 IDSC-EY-P27Z 1E Electrical Penetration P27 11300 IDSC-EY-P28Y 1E Electrical Penetration P28 11300 IDSC-EY-P29Y 1E Electrical Penetration P29 11300 IDSB-EY-P30Z 1E Electrical Penetration P30 11306 IDSB-EY-P31Y 1E Electrical Penetration P31 11306 IDSB-EY-P32Y 1E Electrical Penetration P32 11306 19D.8.2.12 Cables Conduct electricity for valves, Cables T2,T3-A10 Note 1 All sensors and igniters 19D.8.2.13 Float Level Sensors PXS Containment Water Level T2,T3-A2,A6,A9,A10 2 Sense level PXS-JE-LE050 Containment Floodup Level 11104 PXS-JE-LE052 Containment Floodup Level 11104 PXS-JE-LE051 Containment Floodup Level 11104 19D.8.2.14 Containment Hatches (Gasket Material Only)

Containment Hatches T2,T3-A7 All Maintain containment boundary (Gasket Material Only)

CNS-MY-Y01 Equipment Hatch 11500 CNS-MY-Y02 Maintenance Hatch 11300 Page 36 of 37

ND-18-0342 Proposed Changes to the Licensing Basis Documents - Public Information (LAR-18-001)

Table 19D-9: Equipment Located Inside Containment (Time Frames T2 and T3)

Desired Time Frames T2,T3 Section and Room Channels/

Description and Actions Function Equip Tag No. Number Divisions (Notes 6, 7)

(Note 5)

CNS-MY-Y03 Personnel Hatch - Upper 11500 CNS-MY-Y04 Personnel Hatch - Lower 11300 19D.8.2.15 Containment Vessel Containment Vessel T2,T3-A7 All Maintain containment boundary CNS-MV-01 Containment Shell Notes:

1. Cables are located in most rooms inside containment.

2. A channel consists of two thermocouples within a single division. Each quadrant contains two divisions. The minimum requirement is two OPERABLE thermocouples in each of the two divisions for each quadrant. All Core Exit Thermocouples (CETs) are located inside the Reactor Pressure Vessel which is in Room 11105 (reactor cavity).

3. There are two groups of igniters. Each containment compartment and hydrogen pathway is covered by at least one igniter in each group. The minimum requirement is one igniter is OPERABLE in each compartment and hydrogen pathway.

4. Equipment is part of the fire protection system, on vertical pipe inside containment, feeding water to top rings, Room 11500.

5. Time Frames T2 and T3 are beyond design basis, and therefore, only one channel of each instrumentation parameter is required to be OPERABLE. However, it is preferred to have more than one channel of each parameter available to resolve information ambiguity.

6. See Appendix 19D, Section 19D.4 for definitions of Equipment Survivability Time Frames T2 and T3.

7. See Appendix 19D, Section 19D.6 for Actions associated with Time Frames T2 and T3.

Time Frame T2 Time Frame T3

• A1 = Subsection 19D.6.2.1

• A1 = Subsection 19D.6.3.1

• A2 = Subsection 19D.6.2.2

• A2 = Subsection 19D.6.3.2

• A3 = Subsection 19D.6.2.3

• A3 = Subsection 19D.6.3.3

• A4 = Subsection 19D.6.2.4

• A4 = Subsection 19D.6.3.4

• A5 = Subsection 19D.6.2.5

• A5 = Subsection 19D.6.3.5

• A6 = Subsection 19D.6.2.6

• A6 = Subsection 19D.6.3.6

• A7 = Subsection 19D.6.2.7

• A7 = Subsection 19D.6.3.7

• A8 = Subsection 19D.6.2.8

• A8 = Subsection 19D.6.3.8

• A9 = Subsection 19D.6.2.9

• A9 = Subsection 19D.6.3.9

• A10 = Subsection 19D.6.2.10

• A10 = Subsection 19D.6.3.10 Page 37 of 37