ML18247A407

Safety Evaluation for Amd Nos. 145/144- Vogtle Electric Generating Plant Units 3 and 4 (LAR-18-015) Fire Protection System Non-Safety Cable Spray Removal

ML18247A407
Person / Time
Site:	Vogtle
Issue date:	10/04/2018
From:	Bill Gleaves NRC/NRO/DLSE/LB4
To:	City of Dalton, GA, Georgia Power Co, MEAG Power, Oglethorpe Power Corp, Southern Nuclear Operating Co
Gleaves B/415-5848
Shared Package
ML18247A399	List: ML18247A400 ML18247A401 ML18247A402 ML18247A403 ML18247A404 ML18247A405 ML18247A406 ML18247A407
References
EPID L-2018-LLA-0114, LAR 18-015
Download: ML18247A407 (11)

Text

SAFETY EVALUATION BY THE OFFICE OF NEW REACTORS RELATED TO AMENDMENT NOS. 145 AND 144 TO THE COMBINED LICENSE NOS. NPF-91 AND NPF-92, RESPECTIVELY SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026

1.0 INTRODUCTION

By letter dated April 27, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18117A464), and supplemented by letter dated August 13, 2018, (ADAMS Accession No. ML18225A291), Southern Nuclear Operating Company (SNC) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Combined License (COL) Numbers NPF-91 and NPF-92, respectively. The License Amendment Request (LAR)18-015 requests changes to remove the fire protection system (FPS) containment open nozzle water spray suppression system for the open non-safety related cable trays in fire zone 1100 AF 11300B and installing passive fire stops and radiant energy shields.

Pursuant to Section 52.63(b)(1) of Title 10 of the Code of Federal Regulations (10 CFR), SNC also requested an exemption from the provisions of 10 CFR Part 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents. The requested exemption would allow a departure from the certified information in Tier 1 of the generic AP1000 Design Control Document (DCD)1. In order to modify the UFSAR (the plant-specific design control document (PS-DCD)) Tier 1 information, the NRC must find SNCs exemption request 1

While the licensee describes the requested exemption as being from Section III.B of 10 CFR Part 52, Appendix D, the entirety of the exemption pertains to proposed departures from Tier 1 information in the plant-specific design control document (PS-DCD). In the remainder of this evaluation, the NRC will refer to the exemption as an exemption from Tier 1 information to match the language of Section VIII.A.4 of

included in its submittal for the LAR to be acceptable. The staffs review of the exemption request, as well as the LAR, is included in this safety evaluation.

The supplement dated August 13, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on June 19, 2018 (83 FR 28463).

2.0 REGULATORY EVALUATION

In this LAR, SNC proposes a site-specific license amendment to depart from Tier 2 information in Updated Final Safety Analysis Report (UFSAR) Subsections 9.5.1, 19.59, and Appendix 9A, by removing the FPS containment open nozzle water spray suppression system for the open non-safety-related cable trays in fire zone 1100 AF 11300B and installing passive fire stops and radiant energy shields. Enclosure 2 of the LAR requests the exemption necessary to implement the involved changes to the COL Appendix C and corresponding plant-specific Tier 1 information. COL Appendix C Figure 2.3.4-1 (Sheet 2) shows the FPS and Figure 2.3.4-2 shows the FPS piping which must remain functional following a safe shutdown earthquake.

These two figures depict FPS piping to cable tray sprays in fire zone 1100 AF 11300B.

The staff considered the following regulatory requirements in reviewing the LAR that included the proposed changes.

Appendix D,Section VIII.A.4 to 10 CFR Part 52 states that exemptions from Tier 1 information are governed by the requirements in 10 CFR 52.63(b)(1) and 10 CFR 52.98(f). It also states that the Commission will deny such a request if it finds that the design change will result in a significant decrease in the level of safety otherwise provided by the design.

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.

10 CFR 52.63(b)(1) allows the licensee who references a design certification rule to request NRC approval for an exemption from one or more elements of the certification information. The Commission may only grant such a request if it determines that the exemption will comply with the requirements of 10 CFR 52.7, which, in turn, points to the requirements listed in 10 CFR 50.12 for specific exemptions. In addition to the factors listed in 10 CFR 52.7, the Commission shall consider whether the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.

10 CFR 52.98(f) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL. These activities involve a change to COL Appendix C ITAAC information, with corresponding changes to the associated PS-DCD Tier 1 information.

10 CFR 50.48(a)(1) requires a fire protection plan that satisfies 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 3, Fire Protection.

10 CFR Part 52, Appendix D, which specifically governs the granting of exemptions from Tier 1 information.

10 CFR 50.48(a)(2)(iii) requires the licensee to describe specific features necessary to limit fire damage to structures, systems, or components (SSCs) important to safety so that the capability to shut down the plant safely is ensured.

The specific NRC technical requirements applicable to LAR 18-015 are the GDC in Appendix A, General Design Criteria for Nuclear Power Plants, to 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities. In particular, these technical requirements include the following GDC:

GDC 3 requires SSCs important to safety to be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions.

GDC 4 requires SSCs important to safety to be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents.

GDC 35 requires the emergency core cooling system safety function to transfer heat from the reactor core following any loss of reactor coolant at a rate such that (1) fuel and clad damage that could interfere with continued effective core cooling is prevented and (2) clad metal-water reaction is limited to negligible amounts.

3.1 TECHNICAL EVALUATION

OF THE REQUESTED CHANGES 3.

1.1 PROPOSED CHANGE

S The information presented by SNC in LAR 17-031 was evaluated by the staff for its completeness, quality, and clarity. SNCs proposed changes to COL Appendix C, corresponding plant specific Tier 1, and the UFSAR related to the replacement of the containment open nozzle water spray suppression system in fire zone 1100 AF 11300B with passive fire stops are as follows:

1. COL Appendix C (and corresponding plant specific Tier 1), Figure 2.3.4-1, Sheet 2 -

Remove depiction of containment water spray piping to fire zone 1100 AF 11300B.

2. COL Appendix C (and corresponding plant specific Tier 1), Figure 2.3.4 Remove depiction of containment water spray piping to valves V133A/B/C/D/E.

3. UFSAR Table 9.5.1 Remove exception to NFPA 15 Section 5.7.2.1 that requires all actuation valves be listed as the non-listed valves are no longer being used.

4. UFSAR Figure 9.5.1-1, Sheet 3 - Remove depiction of branch line for Cable Tray Spray.

5. UFSAR Subsection 9A.3.1.1 - Delete fourth bullet (Water spray systems in specific locations) under Fire Detection and Suppression Features.

6. UFSAR Subsection 9A.3.1.1.7 - Modify last sentence of second paragraph to account for removal of water spray suppression system for non-safety-related electrical cables in open cable trays in fire zone 1100 AF 11300B and replacement with passive fire stops.

7. UFSAR Subsection 9A.3.1.1.8 - Modify third, fourth, and sixth paragraphs to account for removal of water spray suppression system for non-safety-related electrical cables in open cable trays in fire zone 1100 AF 11300B and replacement with passive fire stops.

8. UFSAR Table 9A-3, Sheet 1 - Remove water spray as a method of fixed suppression capability for fire zone 1100 AF 11300B.

9. UFSAR Table 19.59 Revise the text of item 80 to remove the words automatic and maintenance floor when referring to the fire system in the containment.

3.1.2 EVALUATION OF PROPOSED CHANGES 3.1.2.1 FIRE PROTECTION The staff has reviewed the analysis provided in LAR 18-015. As described in the VEGP Units 3 and 4 UFSAR, Revision 6, the primary objectives of the AP1000 fire protection program are to prevent fires and to minimize the consequences should a fire occur. The program provides protection so that the plant can be shut down safely following a fire.

VEGP Units 3 and 4 are subdivided into fire areas to isolate potential fires and minimize the risk of the spread of fire and the resultant consequential damage from corrosive gases, fire suppression agents, smoke, and radioactive contamination. Complete fire barrier separation necessary to define a fire area is not provided throughout primary containment (including the middle and upper annulus zones of the shield building) because of the need to satisfy other design requirements, such as allowing for pressure equalization within the containment following a high-energy line break or to maintain the free exchange of gases for purposes such as passive containment cooling.

As currently described in the VEGP Units 3 and 4 UFSAR, Revision 6, the containment shield building comprises one fire area, fire area 1000 AF 01. This fire area is separated into 18 fire zones and includes the spaces inside containment as well as the valve room for the passive containment cooling system, the middle annulus, the upper annulus, and the operating deck staging area outside containment. These zones are based on the establishment of boundaries (structures or distance) that inhibit fire propagation from fire zone to fire zone.

Fire zone 1100 AF 11300B is depicted in security-related Figure 9A-1 (Sheet 5 of 16), Nuclear Island Fire Areas Plan at Elevation 100-0 & 107-2. Fire zone 1100 AF 11300B is physically separated from fire zones below by the maintenance floor, which has a concrete thickness of more than one foot, except for access stairways and hatches. It is also separated from the operating deck above by a ceiling that has a concrete thickness of more than one foot, except for several openings for an access stairway, elevator, hatches, and blockouts.

The walls of fire zone 1100 AF 11300B are the steel containment vessel, the steel wall of the in-containment refueling water storage tank, the noncombustible enclosure for the Division B and D penetrations and raceways, or walls with a concrete thickness of more than one foot. Safe shutdown components in fire zone 1100 AF 11300B are separated from redundant safe shutdown components in fire zone1100 AF 11300A by these barriers or by a horizontal distance of more than 20 feet with no intervening combustibles or fire hazards.

Safety-related cables located in fire zone 1100 AF 11300B are routed in closed cable trays or conduit. For open cable trays, which represent the only significant in-situ combustibles in this fire zone, open nozzle water spray suppression systems are currently provided. These systems are automatic except that, to preclude inadvertent actuation, operator action is required to open the outboard containment isolation valve.

The passive fire stops that are proposed to replace the containment open nozzle water spray suppression system for the non-safety-related open cable trays consists of a high density silicone elastomer (HDSE) material placed in the open non-safety-related cable trays at each point where the trays cross from fire zone 1100 AF 11300B into adjacent fire zones. In addition to the HDSE material, the passive fire stops have a 12 gauge stainless steel heat shield installed across the cable trays at the mid-point of the fire stop to aid in prevention of flame propagation. The affected non-safety-related open cable trays are either horizontally or vertically oriented and contain a range of cable sizes from instrument cables (1/4 to 1/2 diameter) to reactor coolant pump (RCP) power cables that are greater than 1 diameter. The HDSE material is formed into fire stops that are about four inches deep and about nine to 12 inches long for the full width of the affected non-safety-related open cable trays. The HDSE material completely surrounds the non-safety-related cables at the point of placement of the passive fire stops. The purpose of these passive fire stops is to prevent a fire in the non-safety-related open cable trays in fire zone 1100 AF 11300B from propagating to another fire zone. SNC stated that a flame-propagation test (fire test) of the proposed passive fire stop design was performed to demonstrate that the passive fire stop will prevent flame propagation along the non-safety related open cable trays beyond the passive fire stop for a 3-hour fire exposure. The fire test was performed using the guidelines of the Institute of Electrical and Electronics Engineers (IEEE) Standard 1202, IEEE Standard for Flame-Propagation Testing of Wire and Cable, (IEEE Std. 1202). The following items that differed from the IEEE Std. 1202 section 4 requirements were part of the fire test program:

1. The passive fire stop test specimen was mounted in the vertically-oriented cable tray test section; no fire stop is shown in IEEE Std. 1202. The test specimen material of construction and placement in the cable tray were identical to the expected field installation. The use of vertically-oriented cable trays in the test is appropriate because it is assumed that a fire would not propagate faster along a horizontally oriented cable tray.

2. The heat source for the fire test was a propane gas ribbon-style burner with a calculated heat output of 140,000 Btu/hr, which exceeds the IEEE Std. 1202 requirement of 70,000 BTU/hr.

3. The width of the burner was not limited to the 10 inches specified in IEEE Std. 1202.

Actual width was 20 inches.

4. The cables mounted in the cable tray were pre-conditioned to a temperature consistent with that expected in containment during plant operation, about 90°C. The IEEE Std. 1202 requires conditioning to a maximum temperature of 86°F. Pre-heating to 90°C is conservative because less of the 3-hour test time is spent raising the temperature from ambient.

5. The cable trays used in the test were of the identical type to be used in the plant installation. The RCP power cables were also used in the test. For the smaller diameter cable test PVC jacketed cables were used. PVC material is not used in containment, but its use in this test is conservative because of its flammability.

6. Although not specified in IEEE Std. 1202, the width of the cable tray used in the fire test was 36 inches, which is the maximum width of the non-safety-related open cable trays subject to the installation of the proposed passive fire stops. The use of the widest cable tray maximizes the potential combustion loading from the cables affected by the propane burner.

7. Two fire tests were performed. Both tests included the propane burner aimed at a vertically oriented cable tray with the passive fire stop installed.

SNC stated that the successful conclusion of the two fire tests of the passive fire stop proposed for use in the non-safety-related open cable trays in fire zone 1100 AF 11300B confirms the acceptability of the passive fire stop as a defense-in-depth feature (in addition to train separation and distance) to prevent propagation of a fire from fire zone 1100 AF 11300B to another fire zone.

The VEGP Units 3 and 4 UFSAR, Revision 6, Section 9.5.1, Fire Protection System, states that the fire protection program and the design of the FPS conform to 10 CFR 50.48, Fire Protection; GDC 3; and SECY-93-087, Section IE, Fire Protection. The VEGP Units 3 and 4 UFSAR, Revision 6, Table 9.5.1-1 gives a point by point description of the conformance of the fire protection program with the guidelines of Branch Technical Position CMEB 9.5-1, Guidelines for Fire Protection for Nuclear Power Plants.

The staff issued Request for Additional information (RAI) 9567, (ADAMS Accession No. ML18197A060), requesting SNC to describe if the passive fire stops will be installed according to Regulatory Guide (RG) 1.189, Fire Protection for Nuclear Power Plants, Revision 1, Regulatory Position 4.2.3.3, Fire Stops for Cable Routing, and also the applicability of the guidance in RG 1.189, Revision 1. In its supplement dated August 13, 2018, SNC responded to the RAI and stated that the purpose of the passive fire stops is to prevent a fire in the non-safety-related open cable trays of fire zone 1100 AF 11300B from propagating to another fire zone. The passive fire stops need not be installed at locations other than the boundary of the fire zone 1100 AF 11300B because the safe shutdown components within fire zone 1100 AF 11300B are conservatively assumed to be disabled by the fire and the plant can shutdown and maintain safe shutdown. Additionally, the containment open nozzle water spray suppression system, which the passive fire stops are replacing, is only credited for providing assurance that a fire will not propagate out of fire zone 1100 AF 11300B.

SNC also stated that the fire protection program utilizes the guidance of various industry and regulatory documents including that provided in Revision 1 of RG 1.189. Although RG 1.189 is not applicable to the AP1000 design and VEGP Units 3 and 4, the VEGP FPS conforms to RG 1.189, Revision 1, for programmatic and/or operational aspects. The discussion of RG 1.189 in LAR 18-015 is only intended to illustrate that the use of passive fire stops is recognized by the NRC.

The staff finds the response acceptable because it gives reasonable assurance that the plant will be able to shutdown and maintain a safe shutdown condition, and explains the intended use of RG 1.189 in the LAR. Based on these findings, the staff concluded that the passive fire stops meet the requirements of 10 CFR 50.48(a)(1) and GDC 3 because they will provide the same function as the containment open nozzle water spray system and are designed and located to minimize, the probability and effect of fires and explosions.

3.1.2.2 Effect of Debris on Emergency Core Cooling System Performance The staff evaluated the passive fire stops, which are proposed to replace the open nozzle water suppression system for the non-safety-related open cable trays, for becoming a source of debris impacting the performance of the emergency core cooling system. SNC stated that the non-safety-related open cable trays in fire zone 11300B that will contain the passive fire stops are not in the zone-of-influence (ZOI) of postulated high energy line breaks. SNC also stated that the passive fire stops are made of HDSE material which in cured form is stable under high heat and radiation and chemically stable in a flooded environment in containment following a design basis accident. The HDSE material of the passive fire stops is made of non-fibrous high-density silicone material (147 lbs/ft3) that exceeds the minimum density requirement of 100 lbs/ft3 for coatings and sealants inside containment as stated in UFSAR Section 6.3.2.2.7.1 for in-containment refueling water storage tank (IRWST) and containment recirculation screen design criteria.

The staff finds the passive fire stops will not become a source of debris that might be generated following a design-basis accident because the passive fire stops are not located within a ZOI, are stable before or following a design basis event, and continues to meet the UFSAR Section 6.3.2.2.7.1 for IRWST and containment recirculation screen design criteria. Based on these findings, the staff concluded that the proposed passive fire stops meet GDC 4 and 35 because (1) they are designed to accommodate the effects of and to be compatible with the environmental conditions in the containment and (2) they will not interfere with design safety function of the emergency core cooling system. Therefore, the staff finds the proposed changes to be acceptable.

3.2 EVALUATION OF EXEMPTION The regulations in Section III.B of Appendix D to 10 CFR Part 52 require a holder of a COL referencing Appendix D to 10 CFR Part 52 to incorporate by reference and comply with the requirements of Appendix D, including certified information in Tier 1 of the generic AP1000 DCD. Exemptions from Tier 1 information are governed by the change process in Section VIII.A.4 of Appendix D of 10 CFR Part 52. Because SNC has identified changes to plant-specific Tier 1 information, with corresponding changes to the associated COL Appendix C information resulting in the need for a departure, an exemption from the certified design information within plant-specific Tier 1 material is required to implement the LAR.

The Tier 1 information for which a plant-specific departure and exemption was requested is described above. The result of this exemption would be that SNC could implement modifications to Tier 1 information to the UFSAR as well as a COL Appendix C table. Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design as certified in the 10 CFR Part 52, Appendix D, design certification rule is requested for the involved Tier 1 information described and justified in LAR 18-015. This exemption is a permanent exemption limited in scope to the particular Tier 1 information specified.

As stated in Section VIII.A.4 of Appendix D to 10 CFR Part 52, an exemption from Tier 1 information is governed by the requirements of 10 CFR 52.63(b)(1) and 52.98(f). Additionally,Section VIII.A.4 of Appendix D to 10 CFR Part 52 provides that the Commission will deny a request for an exemption from Tier 1 if it finds that the requested change will result in a significant decrease in the level of safety otherwise provided by the design. Pursuant to 10 CFR 52.63(b)(1), the Commission may grant exemptions from one or more elements of the certification information, so long as the criteria given in 10 CFR 52.7, which, in turn, references 10 CFR 50.12, are met and that the special circumstances, which are defined by 10 CFR 50.12(a)(2), outweigh any potential decrease in safety due to reduced standardization.

Pursuant to 10 CFR 52.7, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 52. As 10 CFR 52.7 further states, the Commissions consideration will be governed by 10 CFR 50.12, Specific exemptions, which states that an exemption may be granted when: (1) the exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; and (2) special circumstances are present. Specifically, 10 CFR 50.12(a)(2) lists six circumstances for which an exemption may be granted. It is necessary for one of these bases to be present in order for the NRC to consider granting an exemption request. SNC stated that the requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subparagraph defines special circumstances as when [a]pplication 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 staffs analysis of these findings is presented below.

3.2.1 AUTHORIZED BY LAW The requested exemption would allow SNC to implement the amendment described above.

This exemption is a permanent exemption limited in scope to particular Tier 1 information.

Subsequent changes to this plant-specific Tier 1 information, and corresponding changes to Appendix C, or any other Tier 1 information would be subject to the exemption process specified in Section VIII.A.4 of Appendix D to 10 CFR Part 52 and the requirements of 10 CFR 52.63(b)(1). As stated above, 10 CFR Part 52, Appendix D, Section VIII.A.4 allows the NRC to grant exemptions from one or more elements of the Tier 1 information. The NRC staff has determined that granting of SNCs proposed exemption will not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commissions regulations. Therefore, as required by 10 CFR 50.12(a)(1), the exemption is authorized by law.

3.2.2 NO UNDUE RISK TO THE PUBLIC HEALTH AND SAFETY As discussed above in the technical evaluation, the proposed changes comply with the NRCs substantive safety regulations. Therefore there is no undue risk to the public health and safety.

3.2.3 CONSISTENT WITH COMMON DEFENSE AND SECURITY The proposed exemption would allow changes as described above in the technical evaluation, thereby departing from the AP1000 certified (Tier 1) design information. The change does not alter or impede the design, function, or operation of any plant SSCs associated with the facilitys physical or cyber security and, therefore, does not affect any plant equipment that is necessary to maintain a safe and secure plant status. In addition, the changes have no impact on plant security or safeguards. Therefore, as required by 10 CFR 50.12(a)(1), the staff finds that the common defense and security is not impacted by this exemption.

3.2.4 SPECIAL CIRCUMSTANCES Special circumstances, in accordance with 10 CFR 50.12(a)(2), are present whenever 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 underlying purpose of the Tier 1 information is to ensure that a licensee will safely construct and operate a plant based on the certified information found in the AP1000 DCD, which was incorporated by reference into the VEGP Units 3 and 4 licensing basis. The proposed changes described in the above technical evaluation do not impact the ability of any SSCs to perform their functions or negatively impact safety.

Special circumstances are present in the particular circumstances discussed in LAR 18-015 because the application of the current plant specific Tier 1 information in COL Appendix C Figure 2.3.4-1 (Sheet 2) and Figure 2.3.4-2 does not achieve the underlying purpose of the rule. The proposed changes are equal or provide additional clarity to the existing requirement.

The proposed changes do not affect any function or feature used for the prevention and mitigation of accidents or their safety analyses, and no safety-related SSC or function is involved. This exemption request and associated revisions to the Tier 1 information and corresponding changes to Appendix C demonstrate that the applicable regulatory requirements will continue to be met. Therefore, for the above reasons, the staff finds that the special circumstances required by 10 CFR 50.12(a)(2)(ii) for the granting of an exemption from the Tier 1 information exist.

3.2.5 SPECIAL CIRCUMSTANCES OUTWEIGH REDUCED STANDARDIZATION This exemption would allow the implementation of changes to Tier 1 information in the plant-specific DCD and corresponding changes to Appendix C that are being proposed in the LAR.

The justification provided in LAR 18-015, the exemption request, and the associated licensing basis mark-ups demonstrate that there is a limited change from the standard information provided in the generic AP1000 DCD. The design functions of the system associated with this request will continue to be maintained because the associated revisions to the Tier 1 information support the design function of the fire protection system. Consequently, the safety impact that may result from any reduction in standardization is minimized, because the proposed design change does not result in a reduction in the level of safety. Based on the foregoing reasons, as required by 10 CFR Part 52.63(b)(1), the staff finds that the special circumstances outweigh any decrease in safety that may result from the reduction of standardization of the AP1000 design.

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. The staff finds that the justification provided in the LAR, exemption request, and the associated mark-ups demonstrate that there is a limited change from the standard information provided in the generic AP1000 DCD.

3.2.6 NO SIGNIFICANT REDUCTION IN SAFETY This exemption would allow the implementation of changes discussed above. The exemption request proposes to depart from the certified design by allowing changes discussed above in the technical evaluation. The changes for consistency will not impact the functional capabilities of this system. The proposed changes will not adversely affect the ability of the fire protection system to perform its design functions, and the level of safety provided by the current systems and equipment therein is unchanged. Therefore, based on the foregoing reasons and as required by 10 CFR 52.7, 10 CFR 52.98(f), and 10 CFR Part 52, Appendix D, Section VIII.A.4, the staff finds that granting the exemption would not result in a significant decrease in the level of safety otherwise provided by the design.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations in 10 CFR 50.91(b)(2), the Georgia State official was notified of the proposed issuance of the amendment on September 4, 2018. The State official had no comment.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite. Also, there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (Federal Register, 83 FR 2846 dated June 19, 2018). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need to be prepared in connection with the issuance of the amendment.

Because the exemption is necessary to allow the changes proposed in the license amendment, and because the exemption does not authorize any activities other than those proposed in the license amendment, the environmental consideration for the exemption is identical to that of the license amendment. Accordingly, the exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the exemption.

6.0 CONCLUSION

The staff has determined that pursuant to Section VIII.A.4 of Appendix D to 10 CFR Part 52, the exemption (1) is authorized by law, (2) presents no undue risk to the public health and safety, (3) is consistent with the common defense and security, (4) presents special circumstances, and (5) does not reduce the level of safety at SNCs facility. Therefore, the staff grants SNC an exemption from the Tier 1 information requested by SNC.

The staff has concluded, based on the considerations discussed in Section 3.1 that there is reasonable assurance that: (1) the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that 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, the staff finds the changes proposed in this license amendment acceptable.

7.0 REFERENCES

1. Request for License Amendment and Exemption Regarding RE: Fire Protection System Non Safety Cable Spray Removal (LAR 18-015) letter from Southern Nuclear Operating Company, dated April 27, 2018, (ADAMS Accession No. ML18117A464).

2. Vogtle Electric Generating Plant, Supplement to Request for License Amendment and Exemption Regarding RE: Fire Protection System Non Safety Cable Spray Removal (LAR 18-015) letter from Southern Nuclear Operating Company, dated August 13, 2018, (ADAMS Accession No. ML18225A291).

3. U.S. NRC, Final Request for Additional Information No. 1 for Vogtle Electric Generating Plants Units 3 and 4 (LAR-18-015), dated July 13, 2018, (ADAMS Accession No. ML18197A060).

4. AP1000 Design Certification Nuclear Regulatory Commission Final Rule, Federal Register/Volume 71, No.18, dated January 27, 2006, Pages 4464-4482.

5. AP1000 Design Control Document, Revision 19, DCD Tier 2, Appendix 9A, Fire Protection Analysis, dated June 13, 2011, (ADAMS Accession No. ML11171A499).

6. Final Safety Evaluation Report Related to Certification of the AP1000 Standard Plant Design, NUREG-1793, Supplement 2, dated August 5, 2011 (ADAMS Accession No. ML112061231).

7. Vogtle Electric Generating Plant, Final Safety Evaluation Report (FSER) dated August 5, 2011 (ADAMS Accession No. ML111950510 - letter, ADAMS Accession No. ML110450302

- FSER package).

8. Vogtle Electric Generating Plant UFSAR Units 3 and 4, Chapter 9, Auxiliary Systems, Revision 6, dated March 12, 2017, (ADAMS Accession No. ML17172A218).

9. Branch Technical Position CMEB 9.5.1, Guidelines for Fire Protection for Nuclear Power Plants, Revision 2, dated July 1981, (ADAMS Accession No. ML07066045417).

10. Institute of Electrical and Electronics Engineers (IEEE) Standard 1202, IEEE Standard for Flame-Propagation Testing of Wire and Cable.

11. U.S. NRC, Regulatory Guide (RG) 1.189, Fire Protection for Nuclear Power Plants, Revision 1.