"Draft Meeting" is not in the list (Request, Draft Request, Supplement, Acceptance Review, Meeting, Withholding Request, Withholding Request Acceptance, RAI, Draft RAI, Draft Response to RAI, ...) of allowed values for the "Project stage" property.

Text

COL Docs - Draft LAR for ASME Section III Pressure Testing Post N-5 (ALT-12) for 11/15/18 Public Meeting
	ML18317A261
Person / Time
Site:	Vogtle
Issue date:	11/13/2018
From:	; NRC
To:	; NRC/NRO/DLSE/LB4
References
	Download: ML18317A261 (43)
	v • d • e

1 Vogtle PEmails From:

Hoellman, Jordan Sent:

Tuesday, November 13, 2018 12:29 PM To:

Vogtle PEmails

Subject:

draft LAR for ASME Section III Pressure Testing Post N-5 (ALT-12) for 11/15/18 Public Meeting Attachments:

ASME Section III PT LAR DRAFT 11-15-18.pdf Attached is the draft LAR regarding ASME Section III Pressure Testing Requirements Post N-5 Installation Data Report (ALT-12) for the 11/15/18 public meeting. The attachment does not contain any SUNSI.

Hearing Identifier:

Vogtle_COL_Docs_Public Email Number:

387 Mail Envelope Properties (SN6PR0901MB2366ECB7FC29F4ED0B1D5689D5C20)

Subject:

draft LAR for ASME Section III Pressure Testing Post N-5 (ALT-12) for 11/15/18 Public Meeting Sent Date:

11/13/2018 12:28:54 PM Received Date:

11/13/2018 12:29:04 PM From:

Hoellman, Jordan Created By:

Jordan.Hoellman2@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>

Tracking Status: None Post Office:

SN6PR0901MB2366.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 216 11/13/2018 12:29:04 PM ASME Section III PT LAR DRAFT 11-15-18.pdf 1473887 Options Priority:

Standard Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

Recipients Received:

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

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 November xx, 2018 Docket Nos.:

52-025 ND-18-xxxx 52-026 10 CFR 50.90 10 CFR 52.63 10 CFR 50.55a U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment and Exemption:

Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx) (VEGP 3&4-PSI/ISI-Alt-12)

Ladies and Gentlemen:

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

The requested amendment proposes changes to plant-specific Tier 1 information and corresponding changes to COL Appendix C. 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 also requested for the plant-specific DCD Tier 1 material departures.

The requested amendment proposes changes to plant-specific Tier 1 information and corresponding changes to COL Appendix C to allow pressure testing of ASME Section III welds to be completed using ASME Section XI requirements following repair and/or replacement activities that occur following the completion of the ASME Section III N-5 data report for installation of the component(s) in the plant.

Pursuant to 10 CFR 50.55a(z)(2), SNC hereby requests NRC authorization to use an alternative to the requirements of ASME Section III, NB-6221(a), NC-6221(a), and ND-6221(a) of the ASME Boiler and Pressure Vessel (B&PV) Code, 1998 Edition through the 2000 Addenda (code of record) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. The proposed request for alternative is applicable to pressure testing following repair and/or replacement activities that occur following the completion of the ASME Section III N-5 data report for installation of the component(s) in the plant.

DRAFT U.S. Nuclear Regulatory Commission ND-18-XXXX Page 2 of 5 The details of the 10 CFR 50.55a(z)(2) request are contained in Enclosure 4 to this letter. provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed changes. provides the background and supporting basis for the requested exemption. identifies the requested changes and provides markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents. includes the ASME Section III Code Alternative VEGP 3&4-PSI/ISI-Alt-12.

This letter, including enclosures, has been reviewed and confirmed to not contain security-related information. This letter does not contain any regulatory commitments.

Approval of the license amendment, exemption, and alternative request are requested by May 30, 2019 to support the potential for repair and replacement activities that occur following the ASME Section III N-5 installation data report. SNC expects to implement this proposed amendment within 30 days of approval of the requested changes.

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

Should you have any questions, please contact Corey Thomas at (205) 992-5221.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the xxth of November 2018.

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

DRAFT U.S. Nuclear Regulatory Commission ND-18-XXXX Page 3 of 5 Enclosures

1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

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

Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

3) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to Licensing Basis Documents (LAR-18-0xx)

4) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2)

Alternative Requirements for ASME Section III Pressure Tests Conducted Following the N-5 Installation Data Report (VEGP 3&4-PSI/ISI-Alt-12)

DRAFT U.S. Nuclear Regulatory Commission ND-18-XXXX Page 4 of 5 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 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

DRAFT U.S. Nuclear Regulatory Commission ND-18-XXXX Page 5 of 5 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

DRAFT Southern Nuclear Operating Company ND-18-XXXX Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0XX)

(This Enclosure consists of 12 pages, including this cover page)

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 2 of 12 Table of Contents 1.

SUMMARY

DESCRIPTION 2.

DETAILED DESCRIPTION 3.

TECHNICAL EVALUATION 4.

REGULATORY EVALUATION 4.1.

Applicable Regulatory Requirements/Criteria 4.2.

Precedent 4.3.

Significant Hazards Consideration Determination 4.4.

Conclusions 5.

ENVIRONMENTAL CONSIDERATIONS 6.

REFERENCES

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 3 of 12 Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) 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 changes to Tier 1 (and COL Appendix C) Tables 2.1.2-4, 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4 to allow pressure testing in accordance with ASME Section XI 2007 Edition with the 2008 Addenda for pressure tests required following the ASME Code Section III N-5 installation data report.

The requested amendment requires changes to plant-specific Tier 1 information and corresponding changes to COL Appendix C. This enclosure requests approval of the license amendment necessary to implement the changes to COL Appendix C. Enclosure 2 requests the exemption necessary to implement the involved changes to the plant-specific Tier 1 information.

2. DETAILED DESCRIPTION As described in UFSAR Subsection 3.9.3, pressure-retaining components that are safety-related are constructed according to the rules of the ASME Boiler and Pressure Vessel (B&PV) Code,Section III, Division 1. Under 10 CFR 50.55a facilities licensed under Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding.

Following the 10 CFR 52.103(g) finding, the licensee is subject to ASME Section XI.

ASME Section III, Division I, Articles NB-6221(a), NC-6221(a), and ND-6221(a) contain the requirements for pressure testing of piping and components. Vogtle Units 3 and 4 utilize the 1998 Edition through 2000 Addenda of ASME Section III. ASME Section III piping and components pressure tests are performed at 1.25 times system design pressure and are required to be completed satisfactorily prior to completing the ASME Section III N-5 installation data report (hereinafter N-5). These tests are performed using water (hydrostatic test) or with air (pneumatic test), in accordance with ASME Section III NB-6112, NC-6112, and ND-6112.

Due to construction activities, it is anticipated that piping and components will need to be repaired and/or replaced following the completion of the N-5, but prior to the 10 CFR 52.103(g) finding. Under 10 CFR 50.55a facilities licensed under Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding.

Historically, operating plants have transitioned to ASME Section XI for repair and/or replacement activities following completion of the N-5.

Under 10 CFR 50.55a, facilities licensed under Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding.

ASME Section XI allows for a system leakage test at nominal system operation pressure which is achieved through normal system operation. ASME Section III pressure testing is performed at 1.25 times design pressure. Pressure testing at 1.25 times design pressure following the N-5 creates a hardship due to a reduction in Class 1 hydrostatic testing allowable cycles, defeating pressure relief devices from performance of their function, and establishing system boundaries to perform a test at 1.25 times system design pressure.

SNC proposes use of pressure testing in accordance with the 2007 Edition and 2008 Addenda of ASME Section XI for pressure testing that is required due to repair and/or replacement activities that occur after the completion of the N-5, that has previously documented that all

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 4 of 12 ASME Section III requirements have been met. Performance of a leakage test in accordance with ASME Section XI requirements for test pressure following completion of the N-5 along with maintaining the remaining ASME Section III construction requirements provides reasonable assurance of structural integrity, as this pressure test, at nominal system operating pressure, is the same as the pressure testing performed at operating facilities.

Proposed Licensing Basis Changes The following changes are proposed to address the ITAAC for pressure testing in accordance with ASME Section XI following completion of the N-5:

1. Tier 1 (and COL Appendix C) Table 2.1.2-4 Inspections, Tests, Analyses for Design Commitment Item 4 is revised from A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested. to A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be pressure tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

2. Tier 1 (and COL Appendix C) Tables 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4, Design Commitment Item 4 are revised from The piping identified in Table. as ASME Code Section III retains its pressure boundary integrity at its design pressure. to The piping identified in Table. as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI., where. is reference to the applicable Tier 1 piping table.

3. Tier 1 (and COL Appendix C) Tables 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4, Inspections, Tests, Analyses for Design Commitment 4 is revised from.tested.

to.tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI., where. is unnecessary omitted text.

4. Tier 1 (and COL Appendix C) Tables [2.2.1-3], 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and [2.7.1-4], Acceptance Criteria for Design Commitment 4 is revised from A report exists and concludes that the results. conform with the requirements of the ASME Code Section III. to A report exists and concludes that the results. conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report, which will be performed in accordance with ASME Section XI.,

where. is unnecessary omitted text.

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 5 of 12

3. TECHNICAL EVALUATION Changes to Tier 1 (and COL Appendix C) Tables 2.1.2-4, 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4 are proposed to allow pressure testing in accordance with ASME Section XI following the ASME Code Section III N-5. The proposed changes revise Tables 2.1.2-4, 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4 Design Commitment Item 4, and associated Inspections, Tests, Analyses, and Acceptance Criteria to allow pressure testing in accordance with ASME Section XI for pressure tests following the ASME Code Section III N-5. The proposed changes allow pressure testing in accordance with the pressure testing criteria for operating plants following the completion of the N-5. This change is necessary because under 10 CFR 50.55a, ASME Section III applies until the 10 CFR 52.103(g) finding. The proposed changes are consistent with the current requirements in ASME Section XI and with when operational plants have historically transitioned into ASME Section XI for repair and/or replacement activities.

ASME Section III Class 1 Piping and Components Consistent with the markups to the Tier 1 (and COL Appendix C) Table 2.1.2-4, this request does not apply to the Class 1 components and piping listed in Tier 1 (and COL Appendix C)

Table 2.1.2-1 and 2.1.2-2. This request does not apply to Class 1 components because all ASME Section III pressure testing requirements for components are met prior to shipping to the Vogtle construction site.

ASME Section III, Division I, Article, NB-6221(a) contains the requirements for pressure testing of piping and components. NB-6221 (a) states The installed system shall be hydrostatically tested at not less than 1.25 times the lowest Design Pressure of any component within the boundary protected by the overpressure protection devices which satisfy the requirements of NB-7000. ASME Section XI IWB-5221(a) requires that the system leakage test shall be conducted at a pressure not less than the pressure corresponding to 100% rated reactor power. This pressure will later be referenced as nominal system operating pressure.

In accordance with UFSAR Subsection 3.9.1.1.5.1 the primary-side (Class 1) pressure test, also referred to as the ASME Section III Class 1 hydrostatic test, is performed at a water temperature compatible with reactor material ductility requirements and a test pressure of 3107 psig (1.25 times design pressure of 2485 psig). In this test, the reactor coolant system (RCS) is pressurized to 3107 psig coincident with steam generator secondary-side pressure of zero psig. The RCS is designed for 10 hydrostatic test cycles. The number of cycles is independent of other operating transients. In accordance with UFSAR Table 5.4-11, nominal operating pressure for the Class 1 system is 2235 psig and design pressure is 2485 psig.

Performance of additional pressure tests at greater than design pressure reduces testing margins for performance of future tests.

Due to the design and layout of the RCS, it will be excessively difficult to isolate piping and components from the remaining RCS for performance of an elevated pressure test. Since the design and layout of the RCS may not allow for a segment of the system to be pressure tested at test pressures greater than design, ASME Section XI allows for a system leakage test at nominal operating pressure which may be performed under normal system operating conditions; thereby removing the burden of establishing impractical test boundaries.

Additionally, in accordance with UFSAR Table 5.4-16, automatic depressurization of the RCS

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 6 of 12 occurs at 2485 psig. Performance of additional hydrostatic tests at 3107 psig, following the completion of the N-5 requires defeating the safety features designed to protect the system from overpressurization.

The proposed changes are consistent with ASME Section XI requirements for system leakage tests performed following completion of the N-5 for repair and/or replacement activities. The N-5 is not completed until a satisfactorily ASME Section III pressure test has been completed and all other ASME Section III requirements are met. All other inspections are performed in accordance with ASME Section III (e.g., Liquid Penetrant, radiography, magnetic particle) and conducted in accordance with ASME Section V as required by ASME Section III. The ASME Section XI system leakage test for the RCS is performed at nominal system operating pressure attained at a rate in accordance with Vogtle unit specific Pressure and Temperature Limits Report in accordance with IWB-5221(b).

In accordance with IWA-5213(b), which requires a 10 minute hold time for non-insulated components and a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months hold time for insulated components once reaching nominal operating pressure. The examination is conducted in accordance with ASME Section XI IWA-5241. Any additional corrective actions, other than further system leakage tests, shall be conducted in accordance with ASME Section III.

The proposed changes are related to construction tests for the RCS and do not affect the RCS design functions. The RCS continues to accommodate the temperatures and pressures associated with operational transients, and provides a barrier against the release of radioactivity generated within the reactor and is designed to provide a high degree of integrity throughout operation of the plant.

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 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 non-radioactive material effluents are affected by this activity.

Proposed changes 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 this change.

The change activity has 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.

ASME Section III Class 2 and 3 Piping and Components Consistent with the markups to Tier 1 (and COL Appendix C) Tables 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4, this request does not apply to Class 2 and 3 components because all ASME Section III pressure testing requirements for components are met prior to shipping to the Vogtle construction site. Component connection

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 7 of 12 welds to piping are in the scope of the piping; therefore, the design commitment for components remain unchanged.

ASME Section III, Division I, Article, NC-6221(a) and ND-6221(a) contain the requirements for pressure testing of piping and components. Both state that the installed system shall be hydrostatically tested at not less than 1.25 times the lowest Design Pressure of any component within the boundary protected by the overpressure protection devices which satisfy the requirements of NC-7000 and ND-7000. ASME Section XI IWC-5221 and IWD-5221 requires that the system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating function or at the system pressure developed during a test conducted to verify system operability. This pressure will later be referenced as nominal system operating pressure.

Due to the limited number of isolation valves in the AP1000, it will be excessively difficult to isolate small segments of components and piping from the bulk of the system for performance of a hydrostatic test. ASME Section XI allows for a system leakage test at nominal operating pressure which may be performed under normal system operating conditions; thereby, removing the burden of establishing impractical test boundaries. Performance of a hydrostatic test following the completion of the N-5 requires defeating relief valve safety features designed to protect systems from overpressurization. Performance of multiple cycles exceeding design pressure for repair and replacement activities following completion of the N-5 is undesirable as the system would be subject to fatigue cycling at pressures greater than design pressure.

The proposed changes are consistent with ASME Section XI requirements for system leakage tests performed following completion of the N-5 for repair and/or replacement activities. The N-5 is not completed until a satisfactory ASME Section III pressure test has been completed and all other ASME Section III requirements are met. All other inspections are performed in accordance with ASME Section III (e.g., Liquid Penetrant, radiography, magnetic particle) and conducted in accordance with ASME Section V as required by ASME Section III. The ASME Section XI system leakage test is performed at nominal system operating pressure. Hold times are established in accordance with IWA-5213(b) which requires a 10 minute hold time for non-insulated components and a 4 hour4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months hold time for insulated components once reaching nominal operating pressure. The examination is conducted in accordance with ASME Section XI IWA-5241. Any additional corrective actions, other than further pressure tests, shall be conducted in accordance with ASME Section III.

These systems continue to maintain their structural integrity as evidenced by meeting the ASME Section III requirements. Repairs and/or replacement activities performed following the N-5 will be performed in accordance with ASME Section III; except, pressure tests will be performed in accordance with ASME Section XI following completion of the N-5; therefore, the proposed changes do not affect the system design functions.

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 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 non-radioactive material effluents are affected by this activity.

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 8 of 12 Proposed changes 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 this change.

The change activity has 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.

An ITAAC post closure notification will be issued for ASME pressure tests completed following the completion of the N-5 in accordance with the ITAAC closure notification process.

Additionally, pressure testing conducted following completion of the N-5 will be documented in a supplement to the N-5.

Summary The proposed changes to Tier 1 (and COL Appendix C) for pressure testing following the completion of the N-5 will not adversely affect any safety-related equipment or function, design function, radioactive material barrier or safety analysis.

ALARA objectives related to occupational doses continue to be met.

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 COL. This activity involves changes to Tier 1 information and COL Appendix C ITAAC; therefore, this activity requires an amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this license amendment request.

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 is identified.

4.3 Significant Hazards Consideration Determination The requested amendment proposes to depart from approved AP1000 Design Control Document (DCD) Tier 1 information and associated COL Appendix C. The requested amendment proposes changes to Tier 1 (and COL Appendix C) Tables 2.1.2-4, 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4 to allow pressure testing in accordance with ASME Section XI following completion of the ASME Code Section III N-5 installation data report.

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:

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 9 of 12 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 allow for an ASME Section XI pressure test (system leakage test), in lieu of an ASME Section III pressure test following repair and/or replacement activities following completion of the N-5. ASME Section XI requires a pressure test at nominal system operating pressure. Due to the design of the AP1000, it may be difficult to isolate a sub-part of a system in order to perform a pressure test at 1.25 times design pressure. Allowing for a system leakage test that meets the ASME Section XI code is consistent with the rules for operating plants. The proposed changes do not affect the operation of any of the systems impacted by this change. These systems continue to maintain their structural integrity as evidenced by meeting the ASME Section III requirements and system leakage tests conducted in accordance with ASME Section XI following completion of the N-5.

The proposed 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.

Therefore, the probabilities of accidents previously evaluated 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 do not affect any other SSC design functions or methods of operation in a manner that results in a new failure mode, malfunction, or sequence of events that affect safety-related or nonsafety-related equipment. Therefore, this activity does 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 result in significant fuel cladding failures.

Therefore, the requested 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?

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 10 of 12 Response:No.

The proposed changes allow for a system leakage test in accordance with ASME Section XI in lieu of an ASME Section III hydrostatic test following repair and/or replacement activities following completion of the N-5. The ASME components and piping continue to meet the ASME Section III code, except for pressure testing conducted following the N-5. The proposed changes do not have any effect on the ability of the safety-related SSCs to perform their design basis functions. These systems continue to maintain their structural integrity as evidenced by meeting the ASME Section III construction requirements and pressure test conducted in accordance with ASME Section XI following completion of the N-5.

No safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the proposed changes, and no margin of safety is reduced.

Therefore, the requested 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. The above evaluations demonstrate that the proposed changes can be accommodated without an increase in the probability or consequences of an accident previously evaluated, without creating the possibility of a new or different kind of accident from any accident previously evaluated, and without a significant reduction in a margin of safety. Having arrived at negative declarations with regard to the criteria of 10 CFR 50.92, this assessment determined that the proposed changes do not involve a Significant Hazards Consideration.

5. ENVIRONMENTAL CONSIDERATIONS The requested amendment proposes changes to Tier 1 (and COL Appendix C) Tables 2.1.2-4, 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4 to allow pressure testing in accordance with ASME Section XI 2007 Edition with the 2008 Addenda for pressure tests required following completion of the ASME Code Section III N-5. ASME Section III, Division I, Articles NB-6221(a), NC-6221(a), and ND-6221(a) contain the requirements for pressure testing of piping and components. Vogtle Units 3 and 4 utilize the 1998 Edition through 2000 Addenda of ASME Section III. ASME Section III system pressure tests are performed at 1.25 times system design pressure and are required to be completed satisfactorily prior to completing the N-5. Due to the design and layout of the AP1000, it may be difficult to isolate a portion of the system for performance of an elevated pressure test above design pressure. The proposed changes do not affect the operation of systems included in the scope of this request.

These systems continue to maintain their structural integrity as evidenced by meeting the ASME

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 11 of 12 Section III requirements and system leakage tests conducted in accordance with ASME Section XI following completion of the N-5.

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 Determination, 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 Determination determined that (1) the requested amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the requested amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the requested amendment does not involve a significant reduction in a margin of safety. 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.

(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 in the requested amendment would not adversely affect the design or function of any SSC. 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 adversely affect any plant radiological or non-radiological effluent release quantities.

Furthermore, the proposed changes do not adversely 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 would not adversely affect the design or function of any SSC. Plant radiation zones (in UFSAR Section 12.3) are not affected, 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 requested amendment, it has been determined that anticipated construction and operational impacts of the requested 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

DRAFT ND-18-xxxx Request for License Amendment Regarding Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 12 of 12 cumulative occupational radiation exposure. Accordingly, the requested 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), an environmental impact statement or environmental assessment of the proposed amendment is not required.

6. REFERENCES None

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

Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0XX)

(This Enclosure consists of 7 pages, including this cover page)

DRAFT ND-18-xxxx Exemption Request: Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 2 of 7 1.0 Purpose Southern Nuclear Operating Company (the Licensee) requests a permanent exemption from the provisions of 10 CFR 52, Appendix D, Design Certification Rule for the AP1000 Design,Section III.B, Scope and Contents, to allow a plant-specific 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 the allowance to perform pressure testing (system leakage tests) for repair and/or replacement activities in accordance with ASME Section XI following the completion of the N-5 installation data report (from now on referred to as the N-5).

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 due to proposed revision of plant-specific Tier 1 Tables 2.1.2-4, 2.2.1-3, 2.2.2-3, 2.2.3-4, 2.2.4-4, 2.2.5-5, 2.3.2-4, 2.3.6-4, 2.3.7-4, 2.3.10-4, and 2.7.1-4 allowing pressure testing in accordance with ASME Section XI 2007 Edition with the 2008 Addenda for pressure tests required following the completion of the ASME Code Section III N-5.

2.0 Background

ASME Section III, Division I, Articles NB-6221(a), NC-6221(a), and ND-6221(a) contain the requirements for pressure testing of piping and components. Vogtle Units 3 and 4 utilize the 1998 Edition through 2000 Addenda of ASME Section III. These tests are required to be performed at 1.25 times system design pressure and are required to be completed satisfactorily prior to completing the N-5.

These tests are performed using water (hydrostatic test) or with air (pneumatic test), in accordance with ASME Section III NB-6112, NC-6112, and ND-6112.

Due to construction activities, it is anticipated that piping and components will need to be repaired and/or replaced following the completion of the ASME Section III N-5, but prior to the 10 CFR 52.103(g) finding. Under 10 CFR 50.55a facilities licensed under Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding.

Historically, operating plants have transitioned to ASME Section XI for repair and/or replacement activities following completion of the ASME Section III N-5. Under 10 CFR 50.55a facilities licensed under Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding. Pressure testing at 1.25 times system design pressure following the completion of the N-5 creates a hardship due to a reduction in Class 1 hydrostatic testing allowable cycles, defeating pressure relief devices from performance of their function, and establishing system boundaries to perform a test at 1.25 times system design pressure. Following completion of the N-5, SNC proposes to conduct system leakage tests in accordance with the 2007 Edition and 2008 Addenda of ASME Section XI. A system leakage test in accordance with ASME Section XI following the completion of the N-5 alongside the remaining ASME Section III construction requirements provides reasonable assurance of structural integrity, as this pressure test, at nominal system operating pressure, is the same as the pressure testing performed at operating facilities.

DRAFT ND-18-xxxx Exemption Request: Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 3 of 7 3.0 Technical Justification of Acceptability The proposal is consistent with ASME Section III and ASME Section XI for pressure testing as ASME Section III allows for transition to ASME Section XI following the completion of the N-5. All other ASME Section III requirements are met up to the 10 CFR 52.103(g) finding.

Detailed technical justification supporting this request for exemption is provided in Section 3 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 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.

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).

DRAFT ND-18-xxxx Exemption Request: Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 4 of 7

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 for VEGP Units 3 and 4, 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 allowance to perform ASME Section XI pressure tests (system leakage test) following completion of the N-5 is consistent with ASME Section III and XI requirements; therefore, the proposed exemption does not represent any adverse impact to the design function of these systems and will continue to protect the health and safety of the public in the same manner.

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 DCD Tier 1 design information. The proposed exemption does not alter the design, function, or operation of any structure 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 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.

DRAFT ND-18-xxxx Exemption Request: Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 5 of 7 The proposed exemption would allow for a system leakage test in accordance with ASME Section XI following completion of the N-5.

All other ASME Section III requirements will be met up the 10 CFR 52.103(g) finding.

The proposed allowance to perform a system leakage test in accordance with ASME Section XI following completion of the N-5, discussed in Section 2.0, maintains the required design functions of the impacted systems as these systems continue to meet ASME Section III and ASME Section XI.

Due to the limited number of isolation valves in the AP1000, it will be excessively difficult to isolate small segments of components and piping from the bulk of the system for performance of a hydrostatic test. ASME Section XI allows for a system leakage test at nominal operating pressure which may be performed under normal system operating conditions; thereby, removing the burden of establishing impractical test boundaries. Performance of a hydrostatic test following the completion of the N-5 requires defeating relief valve safety features designed to protect systems from overpressurization. The Reactor Coolant System design is limited to 10 hydrostatic test cycles, removal of unnecessary cycles provides additional design margin. For the remaining Class 2 and 3 systems, performance of multiple cycles exceeding design pressure for repair and replacement activities following the N-5 is undesirable as the system would be subject to fatigue cycling at pressure greater than design pressure.

The proposed changes do not affect any function or feature used for the prevention and mitigation of accidents or their safety analyses. No safety-related structure, system, component (SSC) or function is involved. The proposed changes do not involve nor interface with any SSC accident initiator or initiating sequence of events related to the accidents evaluated and therefore do not have an adverse effect on any SSCs design function. Accordingly, this exemption from the certification information will enable the Licensee to safely construct and operate the AP1000 facility consistent with the design certified by the NRC in 10 CFR 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 the changes support the design function of the impacted ASME Class 1, 2, and 3 systems, 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 structures 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

DRAFT ND-18-xxxx Exemption Request: Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 6 of 7 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 allowing an ASME Section XI system leakage test at nominal system operating pressure in lieu of an ASME Section III pressure test at 1.25 times system design pressure as discussed in Section 2.0. The allowance to perform ASME Section XI system leakage testing following completion of the N-5 is consistent with ASME Code requirements and when operational plants transition from ASME Section III to ASME Section XI; therefore, there is no reduction in the level of safety.

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, Design Certification Rule for the AP1000 Design,Section III.B, 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 of this letter.

DRAFT ND-18-xxxx Exemption Request: Pressure Testing Requirements Post N-5 Installation Data Report (LAR-18-0xx)

Page 7 of 7 8.0 Conclusion The proposed changes to DCD Tier 1 are necessary to allow for a system leakage test in accordance with ASME Section XI following completion of the ASME Section III N-5. 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, presents special circumstances, meets the eligibility requirements for categorical exclusion, 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.

9.0 References None

DRAFT Southern Nuclear Operating Company ND-18-xxxx Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Changes to Licensing Basis Documents (LAR-18-0XX)

Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks (* * *)

(This Enclosure consists of 11 pages, including this cover page)

DRAFT ND-18-XXXX Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 2 of 11 Tier 1 (and COL Appendix C) Table 2.1.2-4, Inspections, Tests, Analyses for Design Commitments Item 4 is revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.1.2-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.1.2-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.1.2-1 and 2.1.2-2 as ASME Code Section III conform with the requirements of the ASME Code Section III.

Tier 1 (and COL Appendix C) Table 2.2.1-3, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitments Item 4.b) are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.b) The piping identified in Table 2.2.1-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test or pressure test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the pressure test of the piping identified in Table 2.2.1-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 3 of 11 Tier 1 (and COL Appendix C) Table 2.2.2-3 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.2.2-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The pipelines identified in the ASME Code Section III Table 2.2.2-2 as ASME Code Section III retain their pressure boundary integrity at their design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.2.2-1 and 2.2.2-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 4 of 11 Tier 1 (and COL Appendix C) Table 2.2.3-4 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.2.3-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.2.3-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.2.3-1 and 2.2.3-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 5 of 11 Tier 1 (and COL Appendix C) Table 2.2.4-4 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitments Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.2.4-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.2.4-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.2.4-1 and 2.2.4-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 6 of 11 Tier 1 (and COL Appendix C) Table 2.2.5-5 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.2.5-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.2.5-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.2.5-1 and 2.2.5-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 7 of 11 Tier 1 (and COL Appendix C) Table 2.3.2-4 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.3.2-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.3.2-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.2-1 and 2.3.2-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 8 of 11 Tier 1 (and COL Appendix C) Table 2.3.6-4 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.3.6-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.3.6-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.6-1 and 2.3.6-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 9 of 11 Tier 1 (and COL Appendix C) Table 2.3.7-4 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria

4. The piping lines identified in Table 2.3.7-2 as ASME Code Section III retain their pressure boundary integrity at their design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the piping lines required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the piping lines identified in Table 2.3.7-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 10 of 11 Tier 1 (and COL Appendix C) Table 2.3.10-4 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.3.10-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.3.10-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A hydrostatic test will be performed on the components and piping required by the ASME Code Section III to be hydrostatically tested except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the hydrostatic test of the components and piping identified in Tables 2.3.10-1 and 2.3.10-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT ND-18-xxxx Proposed Changes to Licensing Basis Documents (LAR-18-0XX) 11 of 11 Tier 1 (and COL Appendix C) Table 2.7.1-4 Design Commitment, Inspections, Tests, Analyses, and Acceptance Criteria for Design Commitment Item 4 are revised as shown below.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 4.a) The components identified in Table 2.7.1-1 as ASME Code Section III retain their pressure boundary integrity at their design pressure.

4.b) The piping identified in Table 2.7.1-2 as ASME Code Section III retains its pressure boundary integrity at its design pressure except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

A pressure test will be performed on the components and piping required by the ASME Code Section III to be pressure tested.

Pressure testing conducted following completion of the ASME Code Section III N-5 installation data report will be performed in accordance with ASME Section XI.

A report exists and concludes that the results of the pressure test of the components and piping identified in Tables 2.7.1-1 and 2.7.1-2 as ASME Code Section III conform with the requirements of the ASME Code Section III except for pressure testing conducted following completion of the ASME Code Section III N-5 installation data report which will be performed in accordance with ASME Section XI.

DRAFT Southern Nuclear Operating Company ND-18-xxxx Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) - Alternative Requirements for ASME Section III Pressure Tests Conducted Following the N-5 Installation Data Report (VEGP 3&4-PSI/ISI-Alt-12)

(This Enclosure consists of 6 pages, including this cover page)

DRAFT ND-18-XXXX Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) - Alternative Requirements for ASME Section III Pressure Tests Conducted Following the N-5 Installation Data Report (VEGP 3&4-PSI/ISI-Alt-12) 2 Plant Site-Unit:

Vogtle Electric Generating Plant (VEGP) - Units 3 and 4 Interval-Interval Dates:

Applies to construction activities for the time period between completion of the ASME Section III N-5 data report for installation of piping and component(s) in the plant until the 10 CFR 52.103(g) finding.

Requested Date for Approval:

Approval is requested by 5/30/19 to support xxxx.

ASME Code Components Affected:

ASME Class 1, 2, and 3 Piping including Piping Welds Applicable Code Edition and Addenda:

ASME B&PV Code,Section III, 1998 Edition through the 2000 Addenda (code of record).

Applicable Code Requirements:

Under 10 CFR 50.55a, facilities licensed under 10 CFR Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding.

Following the 10 CFR 52.103 (g) finding, the licensee is subject to ASME Section XI.

ASME Section III, Division I, Articles NB-6221(a), NC-6221(a), and ND-6221(a) contain the requirements for pressure testing of piping and components.

These articles require that each installed system be hydrostatically tested at not less than 1.25 times the lowest Design Pressure of any component within the boundary protected by the overpressure protection devices.

DRAFT ND-18-XXXX Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) - Alternative Requirements for ASME Section III Pressure Tests Conducted Following the N-5 Installation Data Report (VEGP 3&4-PSI/ISI-Alt-12) 3 Reason for Request:

Under 10 CFR 50.55a facilities licensed under 10 CFR Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding.

Following the 10 CFR 52.103 (g) finding, the licensee is subject to ASME Section XI. ASME Section III, Division I, Articles NB-6221(a), NC-6221(a),

and ND-6221(a) contain the requirements for pressure testing of piping and components. Each article states The installed system shall be hydrostatically tested at not less than 1.25 times the lowest Design Pressure of any component within the boundary protected by the overpressure protection devices. ASME Section III NB-6112, NC-6112, and ND-6112 allows for pneumatic testing in lieu.

Historically, operating plants have transitioned to ASME Section XI for repair and/or replacement activities following completion of the ASME Section III N-5 installation data report (from now on referred to as the N-5). Completion of the ASME Section III N-5 denotes that all ASME Section III requirements have been met. Due to construction activities, it is anticipated that piping and components will need to be repaired and/or replaced following the completion of the ASME Section III N-5, but prior to the 10 CFR 52.103(g) finding. Under 10 CFR 50.55a facilities licensed under Part 52 are subject to Section III of the ASME Code prior to the 10 CFR 52.103(g) finding.

There are several notable differences between ASME Sections III and XI.

This request is only applicable to the differences regarding pressure testing. ASME Section III requires pressure testing be performed at 1.25 times the lowest Design Pressure of any component within the boundary protected by the overpressure protection devices. For Class 1 piping, ASME Section XI IWB-5221(a) requires that the system leakage test shall be conducted at a pressure not less than the pressure corresponding to 100% rated reactor power. This pressure will later be referenced as nominal system operating pressure. For Class 2 and 3 piping, ASME Section XI IWC-5221 and IWD-5221 require that the system leakage test shall be conducted at the system pressure obtained while the system, or portion of the system, is in service performing its normal operating function or at the system pressure developed during a test conducted to verify system operability. This pressure will also later be referenced as nominal system operating pressure.

Maintaining ASME Section III requirements for pressure testing following completion of the N-5 creates a hardship due to:

1) Reducing Class 1 hydrostatic testing allowable cycles,

2) Defeating pressure relief devices from performance of their function for the performance of a test greater than system design

pressure,

3) Requiring establishment of system boundaries to perform a test at 1.25 times system design pressure.

DRAFT ND-18-XXXX Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) - Alternative Requirements for ASME Section III Pressure Tests Conducted Following the N-5 Installation Data Report (VEGP 3&4-PSI/ISI-Alt-12) 4 In accordance with UFSAR Subsection 3.9.1.1.5.1, the primary-side ASME Section III (Class 1) hydrostatic test is performed at a water temperature compatible with reactor material ductility requirements and a test pressure of 3107 psig (1.25 times design pressure of 2485 psig). In this test, the reactor coolant system (RCS) is pressurized to 3107 psig coincident with steam generator secondary-side pressure of zero psig. The RCS is designed for 10 ASME Section III pressure test cycles. The number of cycles is independent of other operating transients. In accordance with UFSAR Table 5.4-11, nominal operating pressure for the Class 1 system is 2235 psig and design pressure is 2485 psig. Performance of additional hydrostatic tests reduces testing margins for performance of future hydrostatic tests.

Performance of an ASME Section III pressure test requires defeating pressure devices designed to protect the system from overpressurization.

Although administrative controls are in place to protect the system, this subjects the system to risk of overpressurization not obtained when performing testing at nominal operating pressure. Satisfactory completion of ASME Section III pressure testing must be performed prior to completion of the N-5. Completion of additional elevated pressure tests following a repair and/or replacement activity puts the system at undue risk.

Due to the design and layout of the AP1000, it will be excessively difficult to isolate piping and components from the remaining bulk of the system for performance of a partial elevated pressure test that tests a small portion of a system that was subject to a repair and/or replacement activity. Since the design and layout of the system may not allow for a segment of the system to be pressure tested at test pressures greater than design, performance of a pressure test will require establishing test boundaries that will likely extend to the bulk of the system. Establishment of large pressure test boundaries presents a hardship as the bulk of the system is subject to test pressures greater than the system design pressure.

The completion of the N-5 denotes that ASME Section III activities have been completed. ASME Section XI is a proven industry standard approved for use at operating facilities. In addition, performance of pressure testing in accordance with ASME Section XI following the completion of the N-5 is consistent with how plants licensed under 10 CFR 50 have performed pressure testing activities; therefore, there is a great deal of operating experience prior to and during the operational phase for performance of ASME Section XI pressure testing. Due to the operating experience with ASME Section XI for pressure testing following the completion of the N-5, performance of additional pressure tests in accordance with ASME Section III does not provide a compensatory increase in the level of quality or safety.

DRAFT ND-18-XXXX Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) - Alternative Requirements for ASME Section III Pressure Tests Conducted Following the N-5 Installation Data Report (VEGP 3&4-PSI/ISI-Alt-12) 5 Proposed Alternative and Basis for Use:

Proposed Alternative:

In lieu of performance of a pressure test for repair and/or replacement activities following completion of the N-5 as required by ASME Section III, Division I, Articles NB-6221(a), NC-6221(a), and ND-6221(a), SNC proposes to perform a pressure test in accordance with the 2007 Edition and 2008 Addenda of ASME Section XI IWB-5221(a), IWC-5221, and IWD-5221. This is the Code of Record for Preservice Inspection performed for ASME Section XI.

The ASME Section XI pressure test (system leakage test) is performed at nominal system operating pressure in accordance with ASME Section XI IWB-5221(a), IWC-5221, and IWD-5221. Hold times are established in accordance with IWA-5213(s) which requires a 10-minute hold time for non-insulated components and a 4-hour hold time for insulated components following attaining nominal system operating pressure. The visual examination is conducted in accordance with ASME Section XI IWA-5241. Any additional corrective actions, other than further pressure tests, shall be conducted in accordance with ASME Section III.

Documentation of pressure testing performed following the completion of the N-5 will be documented on a supplement to the N-5.

Basis for Use:

The proposed changes are consistent with ASME Section III and Section XI rules for pressure tests for repair and/or replacement activities performed following completion of the N-5. The N-5 is not completed until all ASME Section III requirements are met, including a satisfactory Section III pressure test. ASME Section XI is a proven industry standard approved for use at operating facilities. In addition, performance of pressure testing in accordance with ASME Section XI following the completion of the N-5 is consistent with how plants licensed under 10 CFR 50 have performed; therefore, there is a great deal of operating experience prior to and during the operational phase for performance of ASME Section XI pressure testing to verify structural integrity.

All other ASME Section III inspections that verify structural integrity are performed in accordance with ASME Section III (e.g., liquid penetrant, radiography, magnetic particle) and conducted in accordance with ASME Section V as required by ASME Section III. Any additional corrective actions, other than pressure test pressure, shall be conducted in accordance with ASME Section III.

Operational plants transition to ASME Section XI following completion of the N-5. As described above, the alternative provides reasonable assurance of structural integrity. Compliance with ASME Section III for

DRAFT ND-18-XXXX Proposed Alternative in Accordance with 10 CFR 50.55a(z)(2) - Alternative Requirements for ASME Section III Pressure Tests Conducted Following the N-5 Installation Data Report (VEGP 3&4-PSI/ISI-Alt-12) 6 pressure testing following completion of the N-5 results in hardship without a compensating increase in the level of quality and safety; therefore, this proposed alternative provides reasonable assurance of structural integrity and should be granted pursuant to 10 CFR 50.55a(z)(2).

Duration of Proposed Alternative:

Until the 10 CFR Part 52.103(g) finding

Reference:

None Status:

Awaiting NRC authorization

v t e Letter Sequence '
EPID:L-2018-LLA-0206, Issuance of Amendments (LAR 18-017) Technical Specification Changes for Spent Fuel Pool Level - Low 2 and In-Containment Refueling Water Storage Tank (IRWST) Wide Range Level (Approved, Closed)
Initiation Request, Request, Request, Request, Request, Request Acceptance... Administration Questions 13 November 2018 Answers Results Approval, Approval, Approval, Approval, Approval, Approval Other: ML19043A676
MONTHYEAR2018-07-20 [Table View]

ML18317A261

Text

Subject:

Subject:

SUMMARY

SUMMARY

2.0 Background

Reference:

Navigation menu

Search