ND-18-1005, Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

ML18222A254
Person / Time
Site:	Vogtle
Issue date:	08/10/2018
From:	Whitley B Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
LAR-18-020, ND-18-1005
Download: ML18222A254 (20)

Text

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

Regulatory Affairs 42 Inverness Center Parkway Birmingham, AL 35242 Tel 205.992.7079 Fax 205.992.5296 August 10, 2018 Docket Nos.: 52-025 ND-18-1005 52-026 10 CFR 50.90 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment:

Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

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 (COL) Numbers NPF-91 and NPF-92, for VEGP Units 3 and 4, respectively. The requested amendment proposes changes to COL Appendix A, Technical Specifications (TS).

The license amendment request (LAR) proposes to change TS Limiting Condition for Operation (LCO) 3.1.8, Physics Tests Exception - Mode 2, related to Functions of LCO 3.3.1, Reactor Trip System (RTS) Instrumentation, for which the required number of channels may be reduced from 4 channels to 3 channels, to include Function 4. Additionally, LCO 3.8.3, Inverters - Operating, the request proposes to make an editorial nomenclature change from constant voltage source transformer to voltage regulating transformer. provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination), and environmental considerations for the proposed changes. provides the proposed markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents. provides conforming Technical Specification Bases changes for information only.

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

U.S. Nuclear Regulatory Commission ND-18-1005 Page 2 of4 SNC requests NRC staff review and approval of the license amendment request (LAR) no later than February 27, 2019. Approval by this date will allow sufficient time to implement licensing basis changes necessary to support procedure development in relation to conducting the necessary operator training to support plant operations. SNC expects to implement the proposed amendment within 30 days of approval of the LAR.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this LAR 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 1Q1h of August 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: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to the Licensing Basis Documents (LAR-18-020)

3) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Technical Specification Bases Changes (LAR-18-020) (For Information Only)

U.S. Nuclear Regulatory Commission ND-18-1005 Page 3 of 4 cc:

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

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

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

Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. E. W. Rasmussen Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Ms. P. Reister 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

U.S. Nuclear Regulatory Commission ND-18-1005 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. C. Churchman (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.

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

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

Southern Nuclear Operating Company ND-18-1005 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

(Enclosure 1 consists of 10 pages, including this cover page)

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION

3. TECHNICAL EVALUATION (included in 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 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

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 change Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.1.8, Physics Tests Exceptions - Mode 2, related to Functions of LCO 3.3.1, Reactor Trip System (RTS) Instrumentation, for which the required number of channels may be reduced from 4 channels to 3 channels, to include Function 4. Additionally, the request proposes to revise LCO 3.8.3, Inverters - Operating, to make an editorial nomenclature change from constant voltage source transformer to voltage regulating transformer.

Conforming Bases revisions are provided for information only. The TS Bases changes will be incorporated following NRC approval of the amendment request in accordance with TS 5.5.6, Technical Specification Bases Control Program.

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION A. Physics Tests Exception TS LCO 3.1.8, Physics Tests Exceptions - Mode 2, identifies exceptions to certain TS requirements that may be taken during the performance of physics testing. Physics testing is conducted during initial plant startup activities, and following a core reload. As discussed in various Updated Final Safety Analysis Report (UFSAR) subsections of section 14.2.10, Startup Test Procedures, the following tests involve either specific physics tests and/or the necessity for connection of the reactivity computer, as related instrumentation, for the prescribed Chapter 14 tests:

• Demonstration of proper operation of the reactivity computer (subsection 14.2.10.2.4),

• Determination of the physics testing range (subsection 14.2.10.3.2),

• Determination of the critical reactor coolant system boron concentration appropriate to an endpoint control rod configuration (subsection 14.2.10.3.3),

• Determination of the isothermal temperature coefficient (subsection 14.2.10.3.4), and

• Confirmation of the reactivity worth of the rod cluster control banks (subsection 14.2.10.3.5).

TS LCO 3.0.7 describes that Test Exception LCO 3.1.8 allows specified TS requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged.

TS LCO 3.1.8 identifies several TS LCOs that may be suspended during the conduct of physics testing, and specific reactor trip instrumentation functions defined in TS LCO 3.3.1, Reactor Trip System Instrumentation, for which the required number of instrumentation channels may be reduced from 4 channels to 3 channels to accommodate the physics testing. Specifically, TS LCO 3.1.8 allows reducing the number of required channels (from 4 channels to 3 channels) for the following RTS instrumentation functions to accommodate low power physics testing:

Page 3 of 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

• Function 1, Power Range Neutron Flux

• Function 2, Power Range Neutron Flux High Positive Rate

• Function 3, Overtemperature T TS 3.1.8 allows for reducing the number of channels required during physics testing to accommodate the removal of one channel of the power range neutron flux detector trip function from service. This will allow the output from one power range detector to be connected to the Advanced Digital Reactivity Computer (ADRC), which is required to acquire reactivity data during physics testing. The removal of one channel of the power range neutron flux detectors for connection to the ADRC reduces the available trip channels for RTS Functions 1, 2, and 3 identified above, reducing the number of operable channels from 4 channels to 3 channels.

RTS Function 3 (Overtemperature T) is affected by the removal of a corresponding channel of power range neutron flux detectors because, as discussed in UFSAR subsection 7.2.1.1.3, the power range neutron flux detectors provide an input [i.e., a penalty function or f(I)] to the Overtemperature T RTS trip setpoints to account for the potential presence of an adverse axial neutron flux distribution (an asymmetry in measured neutron flux between the upper and lower power range neutron flux detectors for a given channel). The penalty function accounts for power distributions in the core potentially more adverse than the reference power distribution used for generating the core thermal design limits. The penalty function reduces the Overtemperature T trip setpoint when its corresponding power range neutron detectors indicate an adverse axial neutron flux distribution.

As discussed in UFSAR subsection 7.2.1.1.3, RTS Function 4 (Overpower T) also incorporates the f(I) penalty function into its trip logic to account for adverse axial neutron flux distribution as detected by its corresponding power range neutron detectors. Therefore, like the Overtemperature T RTS Function, the removal of a single channel of power range neutron detectors as required during physics testing also affects its corresponding Overpower T trip channel. Accordingly, RTS Function 4 is also proposed to be included in the list of RTS functions allowed to be reduced from 4 channels to 3 channels during physics testing conducted under the provisions of TS 3.1.8.

Description of Proposed Changes to Current Licensing Basis Documents The TS LCO 3.1.8 list of LCO 3.3.1, Reactor Trip System (RTS) Instrumentation, Functions for which the required number of channels may be reduced from 4 channels to 3 channels, is revised to include Function 4.

Technical Justification As discussed in UFSAR subsection 7.2.1.1.3, the Reactor Trip System (RTS) Overpower T reactor trip provides confidence of fuel integrity during overpower conditions and limits the required range for Overtemperature T protection. The Overpower T reactor trip combines three hot leg temperature measurements per division with two cold leg temperature measurements per division to form four T power signals, qT. The Overpower T reactor Page 4 of 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020) trip includes adjustments for variations in density and heat capacity of water with temperature and dynamic compensation for piping delays from the core to the loop temperature detectors.

Additionally, there are various control functions that act to reduce the likelihood of an Overpower T reactor trip during normal operation when low margin is detected. These include a turbine loading suspension and a block on automatic and manual rod withdrawal on low margin to the Overpower T trip function, and a turbine runback on low-low margin to the Overpower T trip function. There are also corresponding alarms. The low and low-low margin setpoints change proportionally with the reactor trip setpoints. These functions are intended to mitigate low margin to trip conditions.

The proposed activity to add RTS Function 4 (Overpower T) to the list of RTS trip functions for which the required number of channels may be reduced from 4 channels to 3 channels is consistent with the exceptions provided for RTS Functions 1, 2, and 3, which are also affected by the removal of a single power range neutron flux detector channel for physics testing.

Because removal of a single power range neutron flux detector impacts the number of operable Overpower T channels available, the Overpower T trip function should be addressed in TS 3.1.8, consistent with RTS Functions 1, 2, and 3. As discussed previously, similar to RTS Function 3 (Overtemperature T), the removal of a single power range neutron flux detector from service affects the Overpower T trip function because the Overpower T trip function contains a neutron flux detector input (f(I) penalty) to account for an adverse axial neutron flux distribution. Thus, relaxation of the number of channels (from 4 channels to 3 channels) for the Overpower T trip function is needed to support physics testing, and is consistent with the treatment of RTS Functions 1, 2, and 3 for performance of physics testing.

With all four Overpower T Reactor Trip channels operable, the Overpower trip occurs when two out of the four (2oo4) Overpower T trip channels provide a trip signal. The bypass of a single channel in a 2oo4 trip system results in the logic system operating as a 2oo3 trip system. The trip of a single channel in a 2oo4 trip system results in the logic system operating as a 1oo3 trip system. Accordingly, with a single channel of a 2oo4 trip system bypassed or tripped, the resultant configuration continues to meet the single failure criterion; i.e., one additional single failure will not prevent the trip system from fulfilling its design function. Thus, with a single Overpower T trip channel out of service as required during physics testing, the Overpower T trip function will continue to be capable of performing its design function, while still meeting the single failure criterion. Similarly, the turbine loading suspension, block on automatic and manual rod withdrawal, and turbine runback control functions that act to reduce the likelihood of an Overpower T reactor trip during normal operation when low margin is detected will also continue to be capable of their functions, including the corresponding alarms.

B. Voltage Regulating Transformer Nomenclature TS LCO 3.8.3, Inverters - Operating, Note 1 identifies the Class 1E transformer as the Class 1E constant voltage source transformer, while in other instances within the licensing basis, these transformers are referred to as voltage regulating transformers. To achieve consistency in terminology within other references in the licensing basis the nomenclature in TS 3.8.3 is proposed to be revised to the Class 1E voltage regulating transformer.

Page 5 of 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020)

Description of Changes to Current Licensing Basis Documents The proposed change revises TS LCO 3.8.3, Note 1 nomenclature from Class 1E constant voltage source transformer to Class 1E voltage regulating transformer.

Technical Justification As described in UFSAR subsection 8.3.2.1.1.2, the Class 1E voltage regulating transformers provide a backup source of power to the Class 1E 208Y/120 Vac instrument and control power distribution panels. Divisions A and D each consist of one Class 1E inverter associated with an instrument and control distribution panel and a backup voltage regulating transformer with a distribution panel. The inverter is powered from the respective 24-hour battery bank switchboard. Divisions B and C each consist of two inverters, two instrument and control distribution panels, and a backup voltage regulating transformer with a distribution panel. One inverter is powered by the 24-hour battery bank switchboard and the other, by the 72-hour battery bank switchboard.

The proposed activity revises TS LCO 3.8.3, Note 1 to change Class 1E constant voltage source transformer to Class 1E voltage regulating transformer, to be consistent with the terminology used elsewhere in the licensing basis.

This proposed activity is administrative in nature, as it changes only the terminology used to name the subject transformers. No physical changes are being made to the Class 1E voltage regulating transformers or their associated equipment or interfaces. No changes are being made to any events or conditions under which they are credited within the Technical Specifications or the UFSAR. Thus, there are no adverse changes to any design functions described in the UFSAR.

The proposed activity does not result in a change to any procedure described in the UFSAR nor change the manner in which the Class 1E voltage regulating transformers are operated.

The proposed activity does not affect the method of controlling any design function or change any method of evaluation described in the UFSAR. No tests or experiments not described in the UFSAR are being introduced with this change. Since there are no physical changes associated with the proposed activity, there are no adverse changes to any design feature credited in the ex-vessel severe accident assessment.

These Technical Specification changes do not result in a modification to, addition to, or removal of a structure, system, or component (SSC) such that a design function is adversely affected, has no impact on plant operating procedures or a method of control that adversely affects a design function, does not result in an adverse change to a method of evaluation or use of an alternate method of evaluation, does not represent tests or experiments outside the reference bounds of the design basis, and does not alter the assumptions or results of the ex-vessel severe accident assessment.

The proposed changes do not adversely impact any functions associated with containing, controlling, channeling, monitoring, or processing radioactive or non-radioactive materials, nor do they diminish the functionality of any design or operational features that are credited with Page 6 of 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020) 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 this activity.

The proposed changes have no adverse impact on 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.

3. TECHNICAL EVALUATION (included in 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 amendment request involves a change to plant-specific Technical Specifications (COL Appendix A); and therefore, requires an 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.C.6 states that after issuance of a license, Changes to the plant-specific TS (Technical Specifications) will be treated as license amendments under 10 CFR 50.90. 10 CFR 50.90 addresses the application for amendments of licenses, construction permits, and early site permits. As discussed above, a change to COL Appendix A is requested, and thus a license amendment request (LAR) (as supplied herein) is required.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 13, Instrumentation and Control, requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. The proposed changes assure the continued ability of the PMS to monitor interacting variables and systems. Therefore, the proposed changes comply with the requirements of GDC 13.

10 CFR Part 50, Appendix A, GDC 20, Protection System Functions, requires that the protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences, and (2) to sense accident conditions and to initiate the operation of systems and components important to safety. The proposed changes support the ability of the PMS to detect accident conditions and automatically initiate systems to mitigate the effects of the accident. Therefore, the proposed changes comply with the requirements of GDC 20.

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 Design Control Document (DCD) or Updated Final Safety Analysis Report (UFSAR).

Page 7 of 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020) 4.2 Precedent There are no identified precedents for the changes in this request.

4.3 Significant Hazards Consideration The requested amendment proposes to change Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.1.8, Physics Tests Exceptions - Mode 2, related to Functions of TS LCO 3.3.1, Reactor Trip System (RTS) Instrumentation, for which the required number of channels may be reduced from 4 channels to 3 channels, to include Function 4. Additionally, for TS LCO 3.8.3, Inverters - Operating, the request proposes to make an editorial nomenclature change from constant voltage source transformer to voltage regulating transformer.

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, 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 do not involve changes to current plant design or safety analysis assumptions. These changes provide Technical Specifications consistency with the approved plant design and safety analysis assumptions. The changes do not affect the operation of any systems or equipment that initiate an analyzed accident or alter any structures, systems, and components (SSCs) accident initiator or initiating sequence of events. The proposed changes do not adversely impact the ability of any SSCs provided for, or credited in, mitigating any analyzed accident. Therefore, the requested 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 involve changes to current plant design or safety analysis assumptions. These changes provide Technical Specifications consistency with the approved plant design and safety analysis assumptions. The proposed changes do not adversely affect plant protection instrumentation systems, and do not affect the design function, support, design, or operation of mechanical and fluid systems. The proposed changes do not result in a new failure mechanism or introduce any new accident precursors. No design function described in the Updated Final Safety Analysis Report (UFSAR) is affected by the proposed changes. Therefore, the requested amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

Page 8 of 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020) 4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No The proposed changes do not involve changes to current plant design or safety analysis assumptions. These changes provide Technical Specifications consistency with the approved plant design and safety analysis assumptions. No safety analysis or design basis acceptance limit/criterion is involved. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Based on the above, 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.

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 requested amendment proposes to change Technical Specifications (TS) Limiting Condition for Operation (LCO) 3.1.8, Physics Tests Exceptions - Mode 2, related to Functions of TS LCO 3.3.1, Reactor Trip System (RTS) Instrumentation, for which the required number of channels may be reduced from 4 channels to 3 channels, to include Function 4. Additionally, an editorial nomenclature change is made to TS LCO 3.8.3, Inverters - Operating, revising the text from constant voltage source transformer to voltage regulating transformer.

A review has determined that the proposed changes require an amendment to the COL. However, a review of the anticipated construction and operational effects of the requested amendment has determined that 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 Page 9 of 10

ND-18-1005 Request for License Amendment: Technical Specification Changes for Physics Tests Exceptions and Nomenclature (LAR-18-020) 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 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.

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 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 None.

Page 10 of 10

Southern Nuclear Operating Company ND-18-1005 Enclosure 2 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Changes to the Licensing Basis Documents (LAR-18-020)

Note:

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

Omitted text is shown as three asterisks (*...*...*)

(Enclosure 2 consists of 2 pages, including this cover page)

ND-18-1005 Proposed Changes to the Licensing Basis Documents (LAR-18-020)

COL Appendix A, Technical Specifications 3.1.8 LCO 3.1.8 During the performance of PHYSICS TESTS, the requirements of:

LCO 3.1.3 Moderator Temperature Coefficient (MTC),

LCO 3.1.4 Rod Group Alignment Limits, LCO 3.1.5 Shutdown Bank Insertion Limits, LCO 3.1.6 Control Bank Insertion Limits, and LCO 3.4.2 RCS Minimum Temperature for Criticality may be suspended, and the number of required channels for LCO 3.3.1, Reactor Trip System (RTS) Instrumentation, Functions 1, 2, and 3 3, and 4 may be reduced to 3 provided:

COL Appendix A, Technical Specifications 3.8.3 LCO 3.8.3 The Division A, B, C, and D inverters shall be OPERABLE.

- NOTES -

One inverter may be disconnected from its associated DC bus for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to perform an equalizing charge on its associated battery, providing:

1. The associated instrument and control bus is energized from its Class 1E constant voltage source voltage regulating transformer; and

2. All other AC instrument and control buses are energized from their associated OPERABLE inverters.

Page 2 of 2

Southern Nuclear Operating Company ND-18-1005 Enclosure 3 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Technical Specification Bases Changes (LAR-18-020)

(For Information Only)

Note:

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

Omitted text is shown as three asterisks (*...*...*)

(Enclosure 3 consists of 4 pages, including this cover page)

ND-18-1005 Technical Specification Bases Changes for Information Only (LAR-18-020)

Technical Specification Bases 3.1.8 LCO This LCO allows the reactor parameters of MTC and minimum temperature for criticality to be outside their specified limits. *...*...*

The requirements of LCO 3.1.3, LCO 3.1.4, LCO 3.1.5, LCO 3.1.6, and LCO 3.4.2 may be suspended and the number of required channels for LCO 3.3.1, "Reactor Trip System (RTS) Instrumentation," Functions 1, 2, and 3 3, and 4 may be reduced to 3 required channels during the performance of PHYSICS TESTS provided:

Technical Specification Bases 3.

8.3 BACKGROUND

Under normal operation, a Class 1E inverter supplies power to the Class 1E AC instrument and control bus. If the inverter is inoperable or from service. The backup source is a Class 1E regulating 480-208/

120 volt voltage regulating transformer providing a regulated output to the Class 1E AC instrument and control bus through a static transfer switch and a manual bypass switch.

LCO This LCO is modified by a Note that allows one inverter to be disconnected from its associated Class 1E DC bus for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, if the associated Class 1E AC instrument and control bus is powered from its Class 1E voltage regulating transformer during the period and all other inverters are OPERABLE. *...*...*

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ND-18-1005 Technical Specification Bases Changes for Information Only (LAR-18-020)

ACTIONS A.1 With a required inverter inoperable, its associated Class 1E AC instrument and control bus is automatically energized from its voltage regulating transformer. A manual switch is also provided which can be used if the static transfer switch does not properly function Required Action A.1 allows 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to fix the inoperable inverter and return it to service. The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> time limit is based upon engineering systems such a shutdown might entail. When the AC instrument and control bus is powered from its voltage regulating transformer, it is relying upon interruptible AC electrical power sources (offsite and onsite).

Technical Specification Bases 3.8.4 ACTIONS (continued)

The Completion Time of immediately is consistent with the required times for actions requiring prompt attention. The restoration of the required inverters should be completed as quickly as possible in order to minimize the time the unit safety systems may be without power or powered from a voltage regulating transformer.

Technical Specification Bases 3.

8.5 BACKGROUND

The Class 1E AC distribution Divisions A and D each consists of one 208/120 V bus. The Class 1E AC distribution Divisions B and C each consists of two 208/120 V buses. The buses are normally powered from separate inverters which are connected to the respective division Class 1E battery banks. The backup source provided for each division for the Class 1E AC instrument and control buses is a Class 1E voltage regulating transformer providing regulated output to the Class 1E AC Page 3 of 4

ND-18-1005 Technical Specification Bases Changes for Information Only (LAR-18-020)

LCO *...*...*

OPERABLE Class 1E DC electric power distribution subsystems require the associated buses, motor control centers, and electrical circuits to be buses to be energized to their proper voltages and frequencies from the associated inverter or voltage regulating transformer.

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