ND-18-1408, Request for License Amendment and Exemption: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Request for License Amendment and Exemption: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

ML18320A225
Person / Time
Site:	Vogtle
Issue date:	11/16/2018
From:	Whitley B Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
LAR-18-028, ND-18-1408
Download: ML18320A225 (43)

Text

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

3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 November 16, 2018 Docket Nos.: 52-025 ND-18-1408 52-026 10 CFR 50.90 10 CFR 52.63 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:

Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

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 to depart from information in the Updated Final Safety Analysis Report (UFSAR) Tier 2 information (which includes the plant-specific Design Control Document (DCD) Tier 2 information) and involves related changes to plant-specific Tier 1 information, with corresponding changes to the associated COL Appendix C information. 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 reflect revisions in the routing of Class 1E cables associated with the passive containment cooling system (PCS). Additionally, related consistency revisions in the safe shutdown evaluation divisional separation information are proposed. 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.

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

SNC requests NRC staff review and approval of this license amendment request (LAR) no later than May 20, 2019. Approval by this date will allow sufficient time to implement licensing basis

U.S. Nuclear Regulatory Commission ND-18-1408 Page 2 of 4 changes necessary to support closure of the related Inspections, Tests, Analyses and Acceptance Criteria. SNC expects to implement the proposed amendment within 30 days of approval of the LAR.

SNC also expects to submit a Preliminary Amendment Request (PAR) following this LAR submittal to support more near-term related construction activities. This PAR is expected to request a "no objection" finding from the NRC Staff before mid-January 2019.

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

Should you have any questions, please contact Ms. Amy Chamberlain at (205) 992-6361.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 161h of November 2018.

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

1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment Regarding Routing of Class 1 E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

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

Routing of Class 1 E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

3) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to Licensing Basis Documents (LAR-18-028)

U.S. Nuclear Regulatory Commission ND-18-1408 Page 3 of 4 cc:

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

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

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

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

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

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

Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. E. Riffle Ms. K. Roberts 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. C. J. Even Mr. A. Lerch Mr. S. Walker State of Georgia Mr. R. Dunn

U.S. Nuclear Regulatory Commission ND-18-1408 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. C. Churchman (w/o enclosures)

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

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

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

Southern Nuclear Operating Company ND-18-1408 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

(This Enclosure consists of 19 pages, including this cover page)

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 2 of 19 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 4.4.

Conclusions

5.

ENVIRONMENTAL CONSIDERATIONS

6.

REFERENCES

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 3 of 19 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 proposed changes would revise the COL and licensing basis documents to reflect revised routing for the passive containment cooling system associated Class 1E cables. Additionally, related consistency revisions in the safe shutdown evaluation divisional separation information are proposed.

The requested amendment requires a departure from the Updated Final Safety Analysis Report (UFSAR) Tier 2 information that involves a change to the COL Appendix C (and plant-specific Tier 1) information in Table 3.3-3 identifying the Class 1E divisions in specific nuclear island fire areas. This enclosure requests approval of the license amendment necessary to implement these changes. All discussions of changes to COL Appendix C are also understood to impact the corresponding plant-specific Tier 1 Table 3.3-3.

2.

DETAILED DESCRIPTION Licensing Basis Background Combined License (COL) Appendix C (and the associated plant-specific Tier 1) Table 3.3-3 identifies Class 1E divisions in the nuclear island fire areas, including auxiliary building radiologically controlled areas (RCA) and non-radiologically controlled areas (non-RCA). Each fire area is listed with the associated divisional cabling that terminates in the related rooms.

COL Appendix C Table 2.3.4-2, Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC)

No. 2.3.04.10, requires that testing be performed on the as-built individual fire detectors in the fire areas identified in COL Appendix C Subsection 3.3, Table 3.3-3.

As discussed in UFSAR Subsection 6.2.2, the passive containment cooling system (PCS) is an Engineered Safety Features (ESF) system. Its functional objective is to reduce the containment temperature and pressure following a loss of coolant accident (LOCA) or main steam line break (MSLB) accident inside containment by removing thermal energy from the containment atmosphere. The PCS is designed to withstand the effects of natural phenomena such as ambient temperature extremes, earthquakes, winds, tornadoes, or floods. The active components of the PCS, the isolation valves, are located in three redundant pipe lines. The normally open motor-operated valves are powered from separate redundant Class 1E dc power sources.

As discussed in UFSAR Appendix 9A, the AP1000 fire protection analysis evaluates the potential for occurrence of fires within the plant and documents the capabilities of the fire protection system (FPS) and the capability to safely shut down the plant. The purpose of the fire protection analysis is, in part, to confirm the capability to safely shut down the plant following a fire.

Fire areas are three-dimensional spaces designed to contain a fire that may exist within them.

A postulated fire does not extend beyond the boundary of the fire area. Chases for electrical cables, piping or ducts that pass through the fire area but are separated from it by 3-hour fire barriers are outside that fire area.

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 4 of 19 Only safety-related equipment is utilized for safe shutdown. UFSAR Table 9.A-2 lists the safety-related components used for safe shutdown and their associated electrical divisions.

Each fire area is reviewed to identify the potential scope of fire damage and to verify that the capability to achieve and maintain safe shutdown is preserved in the event of a fire. These rooms are physically separated from other safety-related divisions and by 3-hour fire barriers.

Cables of one separation group are run in separate raceways and physically separated from cables of other separation groups. In the event of a fire in one of the rooms in a given fire area, it is assumed that control of all divisional components is lost. UFSAR Table 9A-3 identifies the type and quantity of combustible materials in each fire area of the primary plant structures. Fire detection and suppression features are also summarized in UFSAR Table 9A-3. UFSAR Table 9A-4 identifies the ventilation systems serving fire areas containing Class 1E electrical components.

Reason for the Change The PCS valve room (Room 12701) is located near the top of the shield building (see Figure 9A-1, Sheet 11 of 16). The Class 1E dc cables that support components located in the PCS valve room were routed embedded in the shield building walls. Structural interferences were identified with this cable routing that were introduced by enhancements to the shield building design near the end of certification. This change proposes to reroute Class 1E cables that support PCS components within the auxiliary building.

The new routing of the cables must be appropriately reflected in the UFSAR and the safe shutdown analysis. In support of this change activity, an extensive review of the design drawings detailing Class 1E dc Divisions A, B, and C cables routings supporting PCS components was performed to confirm the new routing pathways. The new routing of the Class 1E dc cables supporting PCS components necessitates an update to UFSAR Appendix 9A, the Fire Protection Analysis, and to the Class 1E Divisions in Nuclear Island Fire Areas identified in COL Appendix C (and the associated plant-specific Tier 1) Table 3.3-3.

Additionally, during the above review, the other entries in Table 3.3.-3 were re-examined for consistency with the UFSAR descriptions and other changes necessary to consistently reflect the design were noted. These additional changes are also included in this request.

Description of the Activity When the shield building changed from reinforced concrete to modular construction in the enhanced shield building design, the modular design and the associated revised structural elements created an interference with the embedded raceway. As a result, a design change is necessary to reroute the electrical raceways which are intended to support the Class 1E dc and Uninterruptible Power Supply (UPS) System (IDS) Class 1E cabling for the loads located in the PCS valve room, which consists of Division A, Division B, and Division C, as well as non-safety raceways.

To determine the licensing basis impact of this change activity, an extensive review was performed of the routing of the affected Class 1E dc cables supporting PCS components. This review also identified additional impacts to the licensing basis fire protection analysis as described in UFSAR Appendix 9A. The fire areas in this appendix identify the room(s) that comprise the fire area and are assessed, in part, to confirm the capability to safely shut down the plant following a fire. Details pertaining to the safe shutdown components for these fire areas are tabulated in UFSAR Table 9A-2 and include IDS Class 1E cables/trays, as applicable.

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 5 of 19 In addition, the proposed updates to UFSAR Appendix 9A (particularly UFSAR Table 9A-2) necessitate consistency changes to COL Appendix C Table 3.3-3, which details the Class 1E divisions in the nuclear island fire areas, including the auxiliary building RCA and non-RCA.

Each fire area is listed with the associated divisional cabling in the related rooms.

Licensing Basis Change Descriptions:

COL Appendix C (and plant-specific Tier 1) Table 3.3-3, Class 1E Divisions in Nuclear Island Fire Areas:

Remove entire line item for Fire Area 1204 AF 01 Revise the associated Divisions for Fire Area 1200 AF 03 Revise the associated Divisions for Fire Area 1201 AF 02 Revise the associated Divisions for Fire Area 1201 AF 03 Revise the associated Divisions for Fire Area 1242 AF 02 Add entire new line item for Fire Area 1250 AF 01 UFSAR Table 3.7.3-1, Seismic Category I Equipment Outside Containment by Room Number:

Add line item for divisional cabling in Room 12411 (Corridor) in Fire Area 1200 AF 03 Add line item for divisional cabling in Room 12501 (VBS MCR/A&C equipment room) in Fire Area 1250 AF 01 UFSAR Subsection 9.5.1, Fire Protection System:

Subsection 9.5.1.2.1.1, Plant Fire Prevention and Control Features is revised to remove a statement that no safe shutdown components are in the room above the main control room, i.e., Room 12501 associated with Fire Area 1250 AF 01 UFSAR Appendix 9A, Fire Protection Analysis:

Subsection 9A.3.1.2.1.2, Fire Area 1242 AF 02; Revise the Safe Shutdown Evaluation for the associated Divisions for this fire area Subsection 9A.3.1.2.2.1, Fire Area 1201 AF 02; Revise the Safe Shutdown Evaluation for the associated Divisions for this fire area Subsection 9A.3.1.2.4.1, Fire Area 1201 AF 03; Revise the Safe Shutdown Evaluation for the associated Divisions for this fire area Subsection 9A.3.1.2.7.4, Fire Area 1250 AF 01; Revise the Smoke Control Features and the Safe Shutdown Evaluation for the associated Divisions for this fire area Subsection 9A.3.1.2.8.6, Fire Area 1200 AF 03; Revise the Safe Shutdown Evaluation for the associated Divisions for this fire area Subsection 9A.3.1.3.1.3, Fire Area 1204 AF 01; The Safe Shutdown Evaluation is revised to reflect that no safe shutdown components are in this fire area Table 9A-2, Safe Shutdown Components

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 6 of 19 o Revise the associated component Divisions for Fire Area 1200 AF 03 o Revise the associated component Divisions for Fire Area 1201 AF 03 o Revise the associated component Divisions for Fire Area 1242 AF 02 o Add line item for Fire Area 1250 AF 01 divisional components o Corrected the IDS system designator Table 9A-3, Fire Protection Summary o Revise the combustible material information associated with Fire Area 1200 AF 03 o Revise the combustible material information associated with Fire Area 1201 AF 02 o Revise the combustible material information associated with Fire Area 1201 AF 03 o Revise the combustible material information associated with Fire Area 1242 AF 02 o Revise the combustible material information associated with Fire Area 1250 AF 01 Table 9A-4, Ventilation Systems Serving Fire Areas Containing Class 1E Components o Revise the associated Divisions for Fire Area 1200 AF 03 (moves the line item from B&D section to A&C section) o Revise the associated Divisions for Fire Area 1201 AF 02 o Revise the associated Divisions for Fire Area 1201 AF 03 o Revise the associated Divisions for Fire Area 1242 AF 02 o Add line item for Fire Area 1250 AF 01

3.

TECHNICAL EVALUATION UFSAR Appendix 9A details the AP1000 fire protection analysis. The fire areas in this appendix identify the room(s) that comprise the fire area and are assessed, in part, to confirm the capability to safely shut down the plant following a fire. In support of this change activity, the AP1000 Fire Protection Analysis Report was updated to address the new cable raceway routing pathways. The AP1000 Fire Protection Analysis Report documents the design basis supporting UFSAR Appendix 9A. Therefore, the updates to the AP1000 Fire Protection Analysis Report are in turn used to update the UFSAR Appendix 9A description of the AP1000 fire protection analysis, as applicable.

The rerouted cable raceways design continues to meet the environmental conditions for the environmental zones in the auxiliary building through which the cables are to be routed. The raceways penetrate through the shield building below the connection between the shield building and the auxiliary building roof. Penetrations through the shield building cylindrical wall do not provide a straight-through radiation stream path towards the outside or to the Main Control Room (MCR). The changes to the raceways resulted in sixteen new electrical penetrations through the concrete between the shield building annulus and the auxiliary building in Rooms 12501 and 12506. The additional penetrations are not in walls that are modelled as

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 7 of 19 dose contributors in the MCR dose evaluations. Thus, there is no impact to bounding dose rates.

The changes to raceways routings in this activity remain consistent with the existing routing and separation descriptions in the applicable subsections of UFSAR Section 8.3.

IEEE 384, IEEE Standard Criteria for Independence of Class 1E Equipment and Circuits, separation requirements are maintained with the updated layout as part of this change activity.

This change activity remains consistent with the discussion in UFSAR Subsection 9A.3.7.2 for protection of accident mitigation equipment. Specifically, based on the guidance in Branch Technical Position (BTP) CMEB 9.5-1, redundant trains of safety-related equipment used to mitigate the consequences of a design basis accident (but not required for safe shutdown following a fire) are separated so that a fire within one train will not damage the redundant train.

Both trains are permitted to be damaged by a single exposure fire. Either diverse methods of performing the accident mitigation function or adequate separation is provided. While this change activity reroutes raceways through the Auxiliary Building intended to route IDS divisional cabling supporting PCS components, there are no proposed changes to the electrical cabling (including fiber optic cables) or to the methods or raceway construction; these electrical cables and methods of raceway construction remain consistent with BTP CMEB 9.5-1. There are no changes to compliance with BTP CMEB 9.5-1 as a result of this change activity.

As a result of this design change activity, there is no adverse impact on system design functions as described in the UFSAR as a fire in the areas where IDS Class 1E cables supporting PCS components are to be rerouted does not adversely affect the safe shutdown capability of components located in adjacent fire areas. In the event of a fire in the fire areas reviewed as part of this change activity, the capability to continue to maintain safe shutdown is justified as follows:

1204 AF 01 (Rooms 12163)

UFSAR Subsection 9A.3.1.3.1.3 currently states that Table 9A-2 lists the safe shutdown components located in Fire Area 1204 AF 01. Contrary to the Safe Shutdown Evaluation in UFSAR Subsection 9A.3.1.3.1.3, UFSAR Table 9A-2 does not identify any safe shutdown components as located in this fire area. Review of the design confirms that there are no safe shutdown components located in this fire area, and thus, UFSAR Subsection 9A.3.1.3.1.3 is revised appropriately.

In addition, a consistency change is made to COL Appendix C Table 3.3-3 to delete the row for fire area 1204 AF 01 which only contains non-Class 1E divisions. As the fire area is neither included in UFSAR Table 9A-2 for safe shutdown, nor in the supporting AP1000 Fire Protection Analysis Report safe shutdown components table, this fire area is deleted from COL Appendix C Table 3.3-3.

With the removal of Fire Area 1204 AF 01 from COL Appendix C Table 3.3-3, there is no longer a requirement for the testing of individual fire detectors in this fire area as part of

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 8 of 19 ITAAC in COL Appendix C Item 2.3.04.10. However, testing of the as-built individual fire detectors in this fire area continues to be performed, as required by code NFPA 72, the National Fire Alarm Code, just not as part of safe shutdown related ITAAC. Therefore, there is no adverse impact to the fire detection capability in Fire Area 1204 AF 01 as a result of the removal of this fire area from COL Appendix C Table 3.3-3.

1200 AF 03 (Rooms 12311/12411)

UFSAR Table 9A-2 lists the safe shutdown components located in this fire area and is revised as part of this activity to remove IDS Divisions B and D Class 1E cables and to include IDS Divisions A and C Class 1E cables consistent with the revised routing and the revised Fire Protection Analysis Report. This revised routing also involves proposed revisions to COL Appendix C Table 3.3-3.

This revised routing is also reflected in proposed revisions to UFSAR Table 9A-4 to move Fire Area 1200 AF 03 from the portion of the table addressing ventilation systems serving fire areas containing Class 1E Division B and D components to that portion of the table addressing ventilation systems serving fire areas containing Class 1E Division A and C components.

Due to the revised routing, divisional cabling is now also included in Room 12411 and thus, Room 12411 is added to UFSAR Table 3.7.3-1.

The revised routing also adds additional cables to both Room 12311 and 12411 and thus, the combustible material information in UFSAR Table 9A-3 is revised for these rooms. The added material is not significant to the loading and thus, does not affect the overall results of the fire protection evaluation.

The divisions A and C control cables to the reactor trip switchgear are assumed to be disabled, and the inputs from divisions B and D, which are routed in a separate fire area, are sufficient to trip the reactor when needed. The safe shutdown evaluation description in UFSAR Subsection 9A.3.1.2.8.6 is revised as part of this activity to reflect the change in division.

The divisions A and C instrument and control cables serving other safe shutdown components are assumed to be disabled. The instrument and control cables routed outside of this fire area that serve redundant safe shutdown components are sufficient to perform the applicable functions to achieve and maintain safe shutdown.

1201 AF 02 (Rooms 12204/12304)

UFSAR Table 9A-2 lists the safe shutdown components located in this fire area. Division B electrical rooms are physically separated from the other safety-related divisions and nonsafety-related equipment by 3-hour fire barriers. In the event of a fire in a division B electrical room, it is assumed that control of all division B active components is lost.

Because of the physical separation, the fire does not adversely affect the other

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 9 of 19 safety-related electrical divisions. For this event, the division A, C, and D components identified in UFSAR Table 9A-2 are sufficient to achieve and maintain safe shutdown.

There is a division D conduit that traverses fire area 1201 AF 02, the cables in this conduit are associated with the MCR/Remote Shutdown Room (RSR) transfer switch function. The habitability of the MCR is not affected by a postulated fire in this zone and the affected cables cannot cause or prevent division D components from functioning. The habitability of the MCR is not affected by a postulated fire in this zone and the affected cables cannot cause or prevent division D components from functioning. This change activity involves a proposed revision to COL Appendix C Table 3.3-3 to identify Division D in Fire Area 1201 AF 02 as well as an update to the UFSAR Subsection 9A.3.1.2.2.1 safe shutdown evaluation text to address this Division D Class 1E cabling. While these cables are Class 1E cables, they perform a non-Class 1E function; therefore, no update to UFSAR Table 9A-2 is required as a result of this change activity.

This revised routing is also reflected in proposed revisions to UFSAR Table 9A-4 to include Divisions A, B, C and D interdivisional cables.

The revised routing also adds additional cables to both Room 12204 and 12304 and thus, the combustible material information in UFSAR Table 9A-3 is revised for these rooms. The added material is not significant to the loading and thus, does not affect the overall results of the fire protection evaluation.

1201 AF 03 (Room 12305)

UFSAR Table 9A-2 lists the safe shutdown components located in this fire area and is revised as part of this activity to include IDS Division B Class 1E cables consistent with the revised routing and the revised Fire Protection Analysis Report.

The division D electrical rooms in this fire area are physically separated from safety-related divisions A and C by 3-hour fire barriers. In the event of a fire in one of these rooms, it is assumed that control of all division D components is lost. Because of the physical separation, the fire does not adversely affect the other safety-related electrical divisions with the exception of the division B components located in fire zone 1270 AF 12701. For this event, the divisions A and C components identified in UFSAR Table 9A-2 are sufficient to achieve and maintain safe shutdown.

A fire in this fire area is conservatively assumed to disable the division B PCS components located in fire zone 1270 AF 12701; however, the safe shutdown evaluation for fire zone 1270 AF 12701 confirms that safe shutdown capability is maintained.

This change activity involves a proposed revision to COL Appendix C Table 3.3-3 to identify Division B in Fire Area 1201 AF 03 as well as an update to the UFSAR Subsection 9A.3.1.2.4.1 safe shutdown evaluation text to address this divisional Class 1E cabling.

This revised routing is also reflected in proposed revisions to UFSAR Table 9A-4 to include the Division B and D cables, and Divisions A, B, C and D interdivisional cables.

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 10 of 19 The revised routing also adds additional cables to Room 12305 and thus, the combustible material information in UFSAR Table 9A-3 is revised for this room. The added material is not significant to the loading and thus, does not affect the overall results of the fire protection evaluation.

1242 AF 02 (Room 12412)

UFSAR Table 9A-2 lists the safe shutdown components located in this fire area and is revised as part of this activity to include IDS Divisions A and C Class 1E cables consistent with the revised routing and the updated Fire Protection Analysis Report.

The division A penetration room is physically separated from the other safety-related divisions and nonsafety-related equipment by 3-hour fire barriers. In the event of a fire in this room, it is assumed that control of all division A and C active components is lost.

Because of the physical separation, the fire does not adversely affect the other safety-related electrical divisions. In the event of a fire in this room, the division B and D components identified in UFSAR Table 9A-2 are sufficient to achieve and maintain safe shutdown.

In addition, division C electrical cables that serve the redundant PCS valves and instruments located in the PCS valve room are routed through this fire area. In the event of a fire, it is also assumed that this division is disabled. The remaining division B electrical cables and components routed through and located in other fire areas are sufficient to perform the applicable functions to achieve and maintain safe shutdown.

This change activity involves a proposed revision to COL Appendix C Table 3.3-3 to identify Division C in Fire Area 1242 AF 02 as well as an update to the UFSAR Subsection 9A.3.1.2.1.2 safe shutdown evaluation text to address this divisional Class 1E cabling. An additional editorial change to add a dash in the division D column is also made in COL Appendix C Table 3.3-3 for consistency with the UFSAR Subsection 9A.3.1.2.1.2 safe shutdown evaluation.

This revised routing is also reflected in proposed revisions to UFSAR Table 9A-4 to include the Division A and C cables.

The revised routing also adds additional cables to Room 12412 and thus, the combustible material information in UFSAR Table 9A-3 is revised for this room. The added material is not significant to the loading and thus, does not affect the overall results of the fire protection evaluation.

1250 AF 01 (Room 12501)

The safe shutdown evaluation for this fire area is revised as part of this activity in support of the addition of IDS Divisions A and C Class 1E cables as safe shutdown components to UFSAR Table 9A-2. The safe shutdown evaluation for fire area 1250 AF 01 is provided as follows:

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 11 of 19 The quantity and arrangement of the combustible and arrangement of the combustible materials in this fire area, and the characteristics of the barriers that separate this area from other fire areas, are such that a fire in this area does not propagate to any adjacent area.

Aside from the charcoal contained within the air filtration units, these materials primarily consist of electrical cable insulation for cables supplying fans and pumps within this fire area. There are cable concentrations near the ceiling and adjacent to the west wall.

This is a light hazard fire area and the rate of fire growth is expected to be slow.

Generally, 3-hour fire barriers provide adequate separation from adjacent fire areas and the fire is contained within the fire area. Fire barrier separation is not provided between the main control room and this fire area from fires in the main control room. There is fire barrier separation between the main control room and this fire area for fires originating in this area.

The safe shutdown components routed through this fire area are division A and division C electrical cables that serve the redundant PCS valves and instruments located in the PCS valve room. Although the consequences of a fire are expected to be very limited, a fire in this fire area is conservatively assumed to disable both the division A and division C electrical cables that serve the PCS valves and instruments for safe shutdown. The remaining division B electrical cables and components routed through and located in other fire areas are sufficient to perform the applicable functions to achieve and maintain safe shutdown.

This change activity involves a proposed revision to COL Appendix C Table 3.3-3 to include Fire Area 1250 AF 01 as well as an update to the UFSAR Subsection 9A.3.1.2.7.4 safe shutdown evaluation text to address this divisional Class 1E cabling.

Due to the revised routing, divisional cabling is now also included in Room 12501 and thus, Room 12501 is added to UFSAR Table 3.7.3-1.

This revised routing is also reflected in proposed revisions to UFSAR Table 9A-4 to include the Division A and C cables.

The revised routing also adds additional cables to Room 12501 and thus, the combustible material information in UFSAR Table 9A-3 is revised for this room. The added material is not significant to the loading and thus, does not affect the overall results of the fire protection evaluation.

Consistent with the proposed revision to UFSAR Subsection 9A.3.1.2.7.4 for the addition of safe shutdown evaluation for Class 1E cabling in Fire Area 1250 AF 01, a consistency change is needed to UFSAR Subsection 9.5.1.2.1.1 since safe shutdown components are now included in Room 12501.

UFSAR Table 9A-3 identifies the type and quantity of combustible materials in each fire area of the primary plant structures. This change activity reroutes raceways which are to include IDS Class 1E divisional cabling supporting PCS components. The electrical cable insulation

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Page 12 of 19 (jacketing) is a combustible material and is to be considered in the tabulation of combustible loadings for the affected fire areas. As a result of this change activity, the combustible loadings tabulated in UFSAR Table 9A-3 require revision to reflect the updated raceway routings which are to include IDS Class 1E divisional cabling supporting PCS components when the raceway segments are of an open cable tray design. Note that UFSAR Subsection 9A.2.2 indicates that cable enclosed in conduit or in closed metal cabinets is not included in the combustible material survey. Therefore, any rerouted raceway segments in this activity which are enclosed in conduit or in closed metal cabinets are not included in the tabulated loadings in UFSAR Table 9A-3.

The proposed updates to UFSAR Table 9A-3 are supported by updates to the AP1000 Fire Protection Analysis Report.

COL Appendix C Table 3.3-3 identifies Class 1E divisions in the nuclear island fire areas, including auxiliary building RCA and non-RCA. Each fire area is listed with the associated divisional cabling which terminates in the related rooms. As a result of this change activity and the proposed revisions to UFSAR Table 9A-2, a number of involved changes to COL Appendix C Table 3.3-3 are necessary. However, COL Appendix C Table 3.3-3 reflects only a portion of UFSAR Table 9A-2, and it shows Class 1E divisions with only one division (or two as necessary) in one fire area (except for the PMS interdivisional cables as indicated in Note 2).

COL Appendix C Table 3.3-3 is mainly used for inspections defined in ITAAC No. 3.3.00.07c.i.a through 3.3.00.07c.ii.b, which is to demonstrate that Class 1E Divisions A and C cables are separated from Divisions B and D cables in a postulated fire event through separation of fire areas listed in this table. In the revised fire protection analysis report, the division cables in the same area are allowed to be damaged in an event of fire without impacting the safe shutdown ability of the plant because the assurance of safe shutdown is achieved through other division cables running through different fire areas.

Additional Impact Evaluation The proposed changes do not adversely affect or require any change to the AP1000 probabilistic risk assessment (PRA) presented in UFSAR Chapter 19, including the Fire PRA, results and insights (e.g., core damage frequency and large release frequency). The proposed changes do not result in any changes to the existing failures included in the PRA model, and no new postulated failures are required in the PRA model. Therefore, there are no changes required to initiating event frequencies and system logic models of the PRA. The existing PRA risk significance investment protection determination for the system is not affected.

The proposed changes do not adversely affect a structure, system or component (SSC),

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

The proposed changes do not involve a change to a fission product barrier. The changes cannot result in a new failure mode, malfunction or sequence of events that could affect safety.

The changes would not allow for a new fission product release path, result in a new fission

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Page 13 of 19 product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures.

The proposed changes do not adversely affect any safetyrelated equipment, design code limit, safety-related function, safetyrelated design analysis, safety analysis input or result, or design or safety margin. No safety analysis or design basis acceptance limit or criterion would be challenged or exceeded. The proposed changes do not revise any aspects of the plant that could have an adverse effect on safety and security, including the site emergency plan.

There are no radiation zone changes or radiological access control changes required because of these proposed changes. The physical design and operation of the system, as described in the UFSAR, is not changed, and thus there are no changes required to the radiation protection design features described in UFSAR Section 12.3.

The proposed changes do not affect the containment, control, channeling, monitoring, processing or releasing of radioactive and nonradioactive materials. The proposed changes do not adversely affect the containment and control of radioactive and nonradioactive materials inside containment, and do not adversely affect the containment boundary.

The proposed changes do not adversely affect the design functions of any SSC to prevent the unmonitored release of airborne radioactivity to the atmosphere or adjacent plant areas.

Therefore, no effluent release path is affected by these changes. In addition, the types and quantities of expected effluents are not changed by the proposed changes. Therefore, radioactive or nonradioactive material effluents are not affected by these changes.

4.

REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 52.98(c) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a Combined License (COL). This activity involves a departure from COL Appendix C ITAAC; therefore, this activity requires a proposed amendment to the COL.

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

10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criterion (GDC) 2, Design basis for protection against natural phenomena. Structures, systems, and components (SSCs) important to safety shall be

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 14 of 19 designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without the loss of the capability to perform their safety functions. The design bases for these SSCs shall reflect: (1) appropriate consideration of the most severe of the natural phenomena that have been historically reported for the site and surrounding area, with sufficient margin for the limited accuracy, quantity, and period of time in which the historical data have been accumulated, (2) appropriate combinations of the effects of normal and accident conditions with the effects of the natural phenomena, and (3) the importance of the safety functions to be performed. The changes to the routing of Class 1E cables provide for protection for protection from natural phenomena by routing the cables within the shield building structure, and through fire areas with environments for which the cables are qualified. Therefore, compliance with GDC 2 is maintained.

10 CFR Part 50, Appendix A, GDC 3, Fire protection. SSCs important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on SSCs important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components. The proposed routing of the cables maintains acceptable results for the safe shutdown analysis and does not increase probability of a fire. Therefore, compliance with GDC-3 is not changed.

10 CFR Part 50, Appendix A, GDC 17, Electric power systems. An onsite electric power system and an offsite electric power system shall be provided to permit functioning of SSCs important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity to assure that (1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents. The proposed routing of the cables does not adversely impact the electric power systems of the plant and maintains cable separation necessary to maintain acceptable safe shutdown capability. Therefore, compliance with GDC-17 is not changed.

10 CFR Part 50, Appendix A, GDC 20, Protection system functions. The protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety. The proposed routing of the cables does not adversely impact the

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 15 of 19 functionality of the passive containment cooling system (PCS) as the functions for normal operation and during safe shutdown are not changed. Therefore, compliance with GDC 20 is maintained.

10 CFR Part 50, Appendix A, GDC-21, Protection system reliability and testability. The protection system shall be designed for high functional reliability and inservice testability commensurate with the safety functions to be performed. Redundancy and independence designed into the protection system shall be sufficient to assure that (1) no single failure results in loss of the protection function and (2) removal from service of any component or channel does not result in loss of the required minimum redundancy unless the acceptable reliability of operation of the protection system can be otherwise demonstrated. The protection system shall be designed to permit periodic testing of its functioning when the reactor is in operation, including a capability to test channels independently to determine failures and losses of redundancy that may have occurred. The proposed routing of cables does not adversely affect the functions of the PCS. In the event of a fire, loss of a single division does not result in a loss of safe shutdown functionality. Therefore, compliance with GDC 21 is not changed.

10 CFR Part 50, Appendix A, GDC 22, Protection system independence. The protection system shall be designed to assure that the effects of natural phenomena, and of normal operating, maintenance, testing, and postulated accident conditions on redundant channels do not result in loss of the protection function, or shall be demonstrated to be acceptable on some other defined bases. Design techniques, such as functional diversity or diversity in component design and principles of operation, shall be used to the extent practical to prevent loss of the protection function. The proposed routing of cables does not adversely affect the functions of the PCS. In the event of a fire, loss of the affected cables does not result in a loss of safe shutdown functionality. Therefore, compliance with GDC 22 is not changed.

10 CFR Part 50, Appendix A, GDC 29, Protection against anticipated operational occurrences. The protection and reactivity control systems shall be designed to assure an extremely high probability of accomplishing their safety functions in the event of anticipated operational occurrences. The proposed changes do not adversely affect the capability of the PCS to perform safe shutdown functions in the event of a fire.

Therefore, compliance with GDC 29 is not changed.

The proposed changes have been evaluated to determine whether applicable10 CFR 50 Appendix A General Design Criteria (GDC) 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.

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 16 of 19 4.3 Significant Hazards Consideration Southern Nuclear Operating Company (SNC) is requesting an amendment to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP)

Units 3 and 4, respectively. The proposed changes would revise the Updated Final Safety Analysis Report (UFSAR) Tier 2 information, which involves a change to the COL Appendix C and corresponding plant-specific Tier 1 information in Table 3.3-3 to reflect revised routing of divisional cables supporting passive containment cooling system (PCS) functions. Additionally, related consistency revisions in the safe shutdown evaluation divisional separation information are proposed.

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

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

Response

No.

The proposed routing of Class 1E cables has been found to continue to comply with divisional separation design requirements to maintain required functional capability of the safety systems for previously evaluated accidents, including the safe shutdown evaluation for a fire event. The cables continue to be qualified for the environments of the rooms through which they are proposed to be routed, and no changes are proposed to the cable design. The pertinent cables are not an initiator of any accident analyzed in Chapter 15 of the UFSAR. The changes do not involve an interface with any SSC accident initiator or initiating sequence of events, and thus, the probabilities of the accidents evaluated in the UFSAR are not affected. The proposed changes do not involve a change to any mitigation sequence or the predicted radiological releases due to postulated accident conditions, thus, the consequences of the accidents evaluated in the UFSAR are not affected.

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 routing of Class 1E cables has been found to continue to comply with divisional separation design requirements to maintain required functional capability of the safety systems for previously evaluated accidents, including the

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 17 of 19 safe shutdown evaluation for a fire event. The cables continue to be qualified for the environments of the rooms through which they are proposed to be routed, and no changes are proposed to the cable design. The routing of the pertinent cables does not change the function of the related systems, and thus, the changes do not introduce a new failure mode, malfunction or sequence of events that could adversely affect safety or safety-related equipment.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

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

Response

No.

The proposed routing of Class 1E cables has been found to continue to comply with divisional separation design requirements to maintain required functional capability of the safety systems for previously evaluated accidents, including the safe shutdown evaluation for a fire event. The cables continue to be qualified for the environments of the rooms through which they are proposed to be routed, and no changes are proposed to the cable design. The routing of the pertinent cables does not change the function of the related systems or affect the margins provided by the systems, and thus, the changes do not affect any safety-related design code, function, design analysis, safety analysis input or result, or existing design/safety margin. No safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the requested changes.

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

Based on the above, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

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

5.

ENVIRONMENTAL CONSIDERATIONS

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Page 18 of 19 The proposed changes would revise the Updated Final Safety Analysis Report (UFSAR) Tier 2 information, which involves a change to the Combined License (COL) Appendix C and corresponding plant-specific Tier 1 information in Table 3.3-3 to reflect revised routing of divisional cables supporting passive containment cooling system (PCS) functions. Additionally, related consistency revisions in the safe shutdown evaluation divisional separation information are proposed. This review supports a request to amend the COL to allow a departure from the UFSAR incorporated plant-specific design control document information.

A review has determined that the proposed changes require an amendment to the COL.

However, a review of the anticipated construction and operational effects of the requested amendment has determined that the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:

(i)

There is no significant hazards consideration.

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

(ii)

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

The proposed changes are unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents) or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation.

Therefore, it is concluded that the proposed amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

(iii)

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

The proposed change in the requested amendment does not adversely affect the shielding capability of, or adversely alter any walls, floors, or other structures that

ND-18-1408 Request for License Amendment Regarding Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 19 of 19 provide shielding. Plant radiation zones and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure. Therefore, the proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above review of the proposed amendment, it has been determined that anticipated construction and operational effects of the proposed amendment 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 the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment and proposed exemption.

6.

REFERENCES None.

Southern Nuclear Operating Company ND-18-1408 Vogtle Electric Generating Plant Units 3 and 4 Exemption Request:

Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

(This Enclosure consists of 9 pages, including this cover page)

ND-18-1408 Exemption Request: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 2 of 9 1.0 Purpose Southern Nuclear Operating Company (the Licensee) requests a permanent exemption from the provisions of 10 CFR Part 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, to allow a departure from elements of the certification information in Tier 1 of the generic AP1000 Design Control Document (DCD). The regulation, 10 CFR Part 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 changes to reflect revisions in the routing of divisional Class 1E cables.

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 Part 52, Appendix D, Section VIII.A.4 to allow departures from generic Tier 1 information due to proposed clarifications to Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) related Table 3.3-3 for the identified Class 1E divisions in the pertinent nuclear island fire areas.

2.0

Background

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

As described in COL Appendix C and plant-specific Tier 1 Section 3.3, the nuclear island structures (i.e., containment internal structures, shield and auxiliary buildings) provide protection for the safety-related equipment against the consequences of either a postulated internal or external event. The nuclear island structures are designed to withstand the effects of natural phenomena such as hurricanes, floods, tornados, tsunamis, and earthquakes without loss of capability to perform safety functions. The nuclear island structures are designed to withstand the effects of postulated internal events such as fires and flooding without loss of capability to perform safety functions.

As described in Updated Final Safety Analysis Report (UFSAR) Subsection 1.2.4.3, Auxiliary Building, the primary function of the auxiliary building is to provide protection and separation for the seismic Category I mechanical and electrical equipment located outside the containment building. The auxiliary building provides protection for the safety-related equipment against the consequences of either a postulated internal or external event. The auxiliary building also provides shielding for the radioactive equipment and piping that is housed within the building. The auxiliary building is a

ND-18-1408 Exemption Request: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 3 of 9 seismic Category I reinforced concrete structure. It shares a common basemat with the containment building and the shield building.

Separation criteria preserve the independence of redundant Class 1E circuits as described in UFSAR Subsection 8.3.2.4 and no single credible event is capable of disabling redundant safety-related systems.

UFSAR Appendix 9A describes the fire protection analysis performed for each fire area.

The methodology for this fire protection analysis follows the guidance of Branch Technical Position (BTP) CMEB 9.5-1 (Reference 1). The results of the analysis are provided in Section 9A.3.

The fire protection analysis is performed for areas of the plant containing safety-related components and for areas containing systems important to the generation of electricity.

It is performed on an area-by-area basis outside containment and a zone-by-zone basis inside containment. This approach provides confidence that plant safety is preserved.

The proposed change is to reflect revisions in the routing of divisional Class 1E cables related to a fire event as identified in ITAAC-related Table 3.3-3 for the identified Class 1E divisions in the pertinent nuclear island fire areas.

3.0 Technical Justification of Acceptability The changes described in this exemption request would revise the plant-specific Tier 1 information in Table 3.3-3 to reflect revised routing of divisional cables supporting passive containment cooling system (PCS) functions. Related consistency revisions in the safe shutdown evaluation divisional separation information are proposed in the accompanying license amendment request (Enclosure 1 of this letter).

The fire protection analysis in UFSAR Appendix 9A identifies the room(s) that comprise the fire areas and confirm the capability to safely shut down the plant following a fire. In support of this change activity, the AP1000 Fire Protection Analysis Report was updated to address the new cable raceway routing pathways. The AP1000 Fire Protection Analysis Report documents the design basis supporting UFSAR Appendix 9A.

Therefore, the updates to the AP1000 Fire Protection Analysis Report are in turn used to update the UFSAR Appendix 9A description of the AP1000 fire protection analysis, as applicable.

The rerouted cable raceways design follows the environmental conditions for the environmental zones through which the cables are to be routed. The raceways penetrate through the shield building below the connection between the shield building and the auxiliary building roof. Penetrations through the shield building cylindrical wall do not provide a radiation stream path towards the outside or to the Main Control Room (MCR). The changes to the raceways resulted in sixteen new electrical penetrations

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Page 4 of 9 through the concrete between the shield building annulus and the auxiliary building in Rooms 12501 and 12506. There is no impact to bounding dose rates.

The changes to raceways routings in this activity remain consistent with the existing routing and separation descriptions in the applicable subsections of UFSAR Section 8.3.

IEEE 384 "IEEE Standard Criteria for Independence of Class 1E Equipment and Circuits," separation requirements are maintained with the updated layout as part of this change activity. This change activity remains consistent with the discussion in UFSAR Subsection 9A.3.7.2 for protection of accident mitigation equipment. Specifically, based on the guidance in Branch Technical Position (BTP) CMEB 9.5-1, redundant trains of safety-related equipment used to mitigate the consequences of a design basis accident (but not required for safe shutdown following a fire) are separated so that a fire within one train will not damage the redundant train. Both trains are permitted to be damaged by a single exposure fire. Either diverse methods of performing the accident mitigation function or adequate separation is provided. While this change activity reroutes raceways through the auxiliary building intended to route IDS divisional cabling supporting PCS components, there are no proposed changes to the electrical cabling (including fiber optic cables) or to the methods or raceway construction; these electrical cables and methods of raceway construction remain consistent with BTP CMEB 9.5-1.

There are no changes to compliance with BTP CMEB 9.5-1 as a result of this change activity.

As a result of this design change activity, there is no adverse impact on system design functions as described in the UFSAR as a fire in the areas where IDS Class 1E cables supporting PCS components are to be rerouted does not adversely affect the safe shutdown capability of components located in adjacent fire areas. In the event of a fire in the fire areas reviewed as part of this change activity, the capability to continue to maintain safe shutdown is justified.

Tier 1 Table 3.3-3 identifies Class 1E divisions in the nuclear island fire areas, including auxiliary building RCA and non-RCA. Each fire area is listed with the associated divisional cabling that terminates in the related rooms. As a result of this change activity and the proposed revisions to UFSAR Table 9A-2, a number of involved changes to Table 3.3-3 are necessary. However, Table 3.3-3 reflects only a portion of UFSAR Table 9A-2, and it shows Class 1E divisions with only one division (or two as necessary) in one fire area (except for the PMS interdivisional cables as indicated in Note 2).

Table 3.3-3 is mainly used for inspections defined in ITAAC No. 3.3.00.07c.i.a through ITAAC No. 3.3.00.07c.ii.b, which is to demonstrate that Class 1E Divisions A and C cables are separated from Divisions B and D cables in a postulated fire event through separation of fire areas listed in this table. In the revised fire protection analysis report, the division cables in the same area are allowed to be damaged in an event of fire without impacting the safe shutdown ability of the plant because the assurance of safe shutdown is achieved through other division cables running through different fire areas.

ND-18-1408 Exemption Request: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 5 of 9 Additional details and 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 Enclosure 1 of the accompanying License Amendment Request, an exemption from the certified design information in Tier 1 is needed.

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

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

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).

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Page 6 of 9

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 information to depart from the AP1000 certified (Tier 1) design information. The plant-specific Tier 1 information 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 the Tier 1 information. Therefore, the affected plant-specific Tier 1 ITAAC will continue to serve its required purpose.

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

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

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

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

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

ND-18-1408 Exemption Request: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 7 of 9 The rule under consideration in this request for exemption is 10 CFR Part 52, Appendix D, Section III.B, which requires that a licensee referencing the AP1000 Design Certification Rule (10 CFR Part 52, Appendix D) shall incorporate by reference and comply with the requirements of Appendix D, including Tier 1 information. The VEGP Units 3 and 4 COLs reference the AP1000 Design Certification Rule and incorporate by reference the requirements of 10 CFR Part 52, Appendix D, including Tier 1 information.

The underlying purpose of Appendix D,Section III.B is to describe and define the scope and contents of the AP1000 design certification, and to require compliance with the design certification information in Appendix D.

The revised cable routings are shown to maintain the required separation and design functions of the related SSCs. The proposed changes do not affect any function or feature used for the prevention or mitigation of accidents or their safety analyses. The proposed changes neither 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 these changes have been determined to not impact the design function of the related SSCs, 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 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.

ND-18-1408 Exemption Request: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 8 of 9

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

The exemption impacts the plant-specific DCD Tier 1 information by revising Class 1E cable routings as discussed in Section 2.0. The revised cable routings maintain the required separation and safe shutdown capability, and thus do not impact the design requirements of the related SSCs. Because the SSC functions continue to be met, 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 Part 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, with respect to installation or use of facility components located within the restricted area, as defined in 10 CFR Part 20, or which changes an inspection or a surveillance requirement; however, the Licensee evaluation of the proposed exemption has determined that the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

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

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

ND-18-1408 Exemption Request: Routing of Class 1E Divisional Cables Supporting Passive Containment Cooling (LAR-18-028)

Page 9 of 9 8.0 Conclusion The proposed changes to Tier 1 are necessary to revise the identified Class 1E cable routings. The exemption request meets the requirements of 10 CFR 52.63, Finality of design certifications, 10 CFR 52.7, Specific exemptions, 10 CFR 50.12, Specific exemptions, and 10 CFR 52 Appendix D, Design Certification Rule for the AP1000.

Specifically, the exemption request meets the criteria of 10 CFR 50.12(a)(1) in that the request is authorized by law, presents no undue risk to public health and safety, and is consistent with the common defense and security. Furthermore, approval of this request does not result in a significant decrease in the level of safety, satisfies the underlying purpose of the AP1000 Design Certification Rule, and does not present a significant decrease in safety as a result of a reduction in standardization.

9.0 References None

Southern Nuclear Operating Company ND-18-1408 Vogtle Electric Generating Plant Units 3 and 4 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Relocated or duplicated text is identified in Green Omitted text is identified by three asterisks ( * * * )

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

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 2 of 11 Revise COL Appendix C Table 3.3-3, and corresponding plant-specific Tier 1 Table 3.3-3, as shown below.

Table 3.3-3 Class 1E Divisions in Nuclear Island Fire Areas Fire Area Number Class 1E Divisions A

C B

D Auxiliary Building Radiologically Controlled 1200 AF 01 Yes Yes 1204 AF 01 Yes Auxiliary Building Non-Radiologically Controlled 1200 AF 03 Yes Yes Yes Yes 1201 AF 02 Note 2 Note 2 Yes Note 2 Yes 1201 AF 03 Note 2 Note 2 Note 2 Yes Yes 1201 AF 04 Yes Yes 1201 AF 05 Yes Yes 1201 AF 06 Yes Yes 1202 AF 03 Note 2 Yes Note 2 Note 2 1202 AF 04 Yes Note 2 Note 2 Note 2 1220 AF 01 Yes Yes 1220 AF 02 Yes 1230 AF 01 Yes Yes 1230 AF 02 Yes Yes 1240 AF 01 Yes Yes 1242 AF 02 Yes Yes 1250 AF 01 Yes Yes Note 1: Dash () indicates not applicable.

Note 2: Cables from this division in this fire area are limited to interdivisional cables terminating in this fire area.

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 3 of 11 Revise UFSAR Table 3.7.3-1, Seismic Category I Equipment Outside Containment by Room Number, as shown below.

Table 3.7.3-1 (Sheet 2 of 3)

Seismic Category I Equipment Outside Containment by Room Number Room No.

Room Name Equipment Description 12303 Remote shutdown room Divisional cabling 12406 Lower MSIV compartment A SGS containment isolation valves, instrumentation 12411 Corridor Divisional cabling 12412 Electrical penetration room Division A Divisional electrical penetrations, MCR load shed panel Table 3.7.3-1 (Sheet 3 of 3)

Seismic Category I Equipment Outside Containment by Room Number Room No.

Room Name Equipment Description 12421 Non 1E equipment/penetration room Divisional cabling/electrical penetrations 12462 Cask washdown pit SFS piping 12501 VBS MCR/A&C equipment room Divisional cabling 12504 Upper MSIV compartment B SGS CIVs, instrumentation Revise UFSAR Subsection 9.5.1.2.1.1, Plant Fire Prevention and Control Features, as shown below.

Plant Arrangement Fire barrier separation is not provided between the main control room and the room above it from fires in the main control room. There are no safe shutdown components in the room above. There is fire barrier separation between the main control room and the room above it for fires in the room above.

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 4 of 11 Revise UFSAR Subsection 9A.3.1.2.1.2, Fire Area 1242 AF 02, as shown below.

Safe Shutdown Evaluation Table 9A-2 lists the safe shutdown components located in this fire area. The division A penetration room is physically separated from the other safety-related divisions and nonsafety-related equipment by 3-hour fire barriers. In the event of a fire in this room, it is assumed that control of all division A and C active components is lost. Because of the physical separation, the fire does not adversely affect the other safety-related electrical divisions. For this event, the division B, C, and D components identified in Table 9A-2 are sufficient to achieve and maintain safe shutdown.

In addition, division C electrical cables that serve the redundant passive containment cooling system valves and instruments located in the passive containment cooling system (PCS) valve room (Room 12701) are routed through this fire area. In the event of a fire, it is also assumed that this division is disabled. The remaining division B electrical cables and components routed through and located in other fire areas are sufficient to perform the applicable functions to achieve and maintain safe shutdown. Refer to Subsection 9A.3.1.1.17, Fire Zone 1270 AF 12701, for the Safe Shutdown Evaluation of that zone.

Revise UFSAR Subsection 9A.3.1.2.2.1, Fire Area 1201 AF 02, as shown below.

Safe Shutdown Evaluation Table 9A-2 lists the safe shutdown components located in this fire area. Division B electrical rooms are physically separated from the other safety-related divisions and nonsafety-related equipment by 3-hour fire barriers. In the event of a fire in a division B electrical room, it is assumed that control of all division B active components is lost. Because of the physical separation, the fire does not adversely affect the other safety-related electrical divisions. For this event, the division A, C, and D components identified in Table 9A-2 are sufficient to achieve and maintain safe shutdown.

There is a division D conduit that traverses fire area 1201 AF 02, the cables in this conduit are associated with the main control room (MCR)/remote shutdown room transfer switch function.

The habitability of the MCR is not affected by a postulated fire in this zone and the affected cables cannot cause or prevent division D components from functioning.

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 5 of 11 Revise UFSAR Subsection 9A.3.1.2.4.1, Fire Area 1201 AF 03, as shown below.

Safe Shutdown Evaluation Table 9A-2 lists the safe shutdown components located in this fire area. These division D electrical rooms are physically separated from the other safety-related divisions A and C by 3-hour fire barriers. In the event of a fire in one of these rooms, it is assumed that control of all division D components is lost. Because of the physical separation, the fire does not adversely affect the other safety-related electrical divisions with the exception of the division B components located in fire zone 1270 AF 12701. For this event, the divisions A, B, and C components identified in Table 9A-2 are sufficient to achieve and maintain safe shutdown.

Spurious actuation from control room dedicated switches which could lead to a breach of reactor coolant system pressure boundary, loss of decay heat removal function, or loss of shutdown reactivity control is prevented by the use of dual two-pole, energize-to-actuate, ungrounded dc circuits, which require at least four simultaneous hot shorts of proper polarity for spurious actuation.

A fire in this fire area is conservatively assumed to disable the division B PCS components located in fire zone 1270 AF 12701. See Subsection 9A.3.1.1.17 for the Safe Shutdown Evaluation for fire zone 1270 AF 12701.

Following detection of a fire in the dc equipment control room, * *

• ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 6 of 11 Revise UFSAR Subsection 9A.3.1.2.7.4, Fire Area 1250 AF 01, as shown below.

Smoke Control Features This fire area houses and is served by the division A & C Class 1E electrical room HVAC subsystem of the nuclear island nonradioactive ventilation system (VBS). Combination fire-smoke dampers close automatically in response to a smoke detector signal or high temperature to control the spread of fire and smoke. Closure of these fire dampers interrupts the operation of the VBS division A & C Class 1E electrical room and the main control room/control support area HVAC subsystems that are located in this fire area. Operation of the independent division B & D Class 1E electrical room HVAC subsystem continues unaffected. Smoke is removed from the fire area by using portable exhaust fans and flexible ductwork. Smoke from a fire in this fire area does not affect safe shutdown components in fire areas that are served by other ventilation systems or subsystems. The division B reactor coolant pump trip switchgear and the divisions B and D electrical cables located in fire area 1220 AF 01 and the divisions A and C B and D electrical cables located in fire areas 1200 AF 03 and 1220 AF 01 are unaffected by the small quantity of smoke that may leak into these fire areas. Safe shutdown components in these fire areas, identified in Table 9A-4, are sufficient to achieve and maintain safe shutdown.

Safe Shutdown Evaluation This fire area contains no components required for safe shutdown after a fire. No safe shutdown evaluation is required.

The quantity and arrangement of the combustible materials in this fire area, and the characteristics of the barriers that separate this area from other fire areas, are such that a fire in this area does not propagate to any adjacent area.

Aside from the charcoal contained within the air filtration units, these materials primarily consist of electrical cable insulation for cables supplying fans and pumps within this fire area. There are cable concentrations near the ceiling and adjacent to the west wall. This is a light hazard fire area and the rate of fire growth is expected to be slow. Generally, 3-hour fire barriers provide adequate separation from adjacent fire areas and the fire is contained within the fire area. Fire barrier separation is not provided between the main control room and this fire area from fires in the main control room. There is fire barrier separation between the main control room and this fire area for fires originating in this area.

The safe shutdown components routed through this fire area are division A and division C electrical cables that serve the redundant passive containment cooling system valves and instruments located in the passive containment cooling system (PCS) valve room (Room 12701). Although the consequences of a fire are expected to be very limited, a fire in this fire area is conservatively assumed to disable both the division A and division C electrical cables that serve the PCS valves and instruments used for safe shutdown. The remaining division B electrical cables and components routed through and located in other fire areas are sufficient to perform the applicable functions to achieve and maintain safe shutdown.

Neither a fire nor fire suppression activities in this fire area affect the safe shutdown capability of components located in adjacent fire areas.

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 7 of 11 Revise UFSAR Subsection 9A.3.1.2.8.6, Fire Area 1200 AF 03, as shown below.

Safe Shutdown Evaluation Table 9A-2 lists the safe shutdown components located in this fire area. Class 1E divisions A and C B and D cables are routed through these corridors. this corridor.

The divisions A and C division B and D control cables to the reactor trip switchgear are assumed to be disabled. Inputs from divisions B and D, A and C, which are routed in a separate fire area, are sufficient to trip the reactor when needed. The reactor can also be tripped with the diverse actuation system described in Section 7.7.

The divisions A and C division B and D instrument and control cables serving other safe shutdown components are assumed to be disabled. The instrument and control cables routed outside of this fire area that serve redundant safe shutdown components are sufficient to perform the applicable functions to achieve and maintain safe shutdown.

Revise UFSAR Subsection 9A.3.1.3.1.3, Fire Area 1204 AF 01, as shown below.

Safe Shutdown Evaluation This fire area contains no components required for safe shutdown after a fire. No safe shutdown evaluation is required.

Table 9A-2 lists the safe shutdown components located in this fire area.

Neither a fire nor fire suppression activities in this fire area affect the safe shutdown capability of components located in adjacent fire areas.

No fire in this fire area can cause spurious actions which could cause a breach in the reactor coolant boundary or defeat safety-related decay heat removal capability or cause an increase in shutdown reactivity of the reactor.

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 8 of 11 Revise UFSAR Table 9A-2, Safe Shutdown Components, as shown below.

Table 9A-2 (Sheet 8 of 14)

Safe Shutdown Components Fire Area/

Fire Zone System Description Class 1E Division A

C B

D 1200 AF 03 IDS Cable trays that route Class 1E cables Note 1 Note 1 Note 1 Note 1 Table 9A-2 (Sheet 10 of 14)

Safe Shutdown Components Fire Area/

Fire Zone System Description Class 1E Division A

C B

D 1201 AF 03 IDSD 250 Vdc MCC DK-1 Electrical Penetration EY-P14Z Electrical Penetration EY-P15Y Electrical Penetration EY-P16Y Class 1E Cables Note 1 Note 1 1201 AF 04 Table 9A-2 (Sheet 14 of 14)

Safe Shutdown Components Fire Area/

Fire Zone System Description Class 1E Division A

C B

D 1242 AF 02 IDSA Class 1E Electrical Penetration EY-P11Z Class 1E Electrical Penetration EY-P12Y Class 1E Electrical Penetration EY-P13Y 250 Vdc MCC DK-1 Class 1E Cables Note 1 Note 1 1243 AF 01 1243 AF 02 1250 AF 01 IDS Class 1E Cables Note 1 Note 1

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 9 of 11 Revise UFSAR Table 9A-3, Fire Protection Summary, as shown below.

Table 9A-3 (Sheet 6 of 24)

Fire Protection Summary Fire Area /Zone(1)

Safety Area(2)

Floor Area Sq Ft Combustible Material(3)

Fire Sev.

Cat.

Amount Heat Value (Btu)

Comb.

Load.

Btu/Sq Ft 1200 AF 03 YES 1230 AF 12311 CORRIDOR 355 CABLE INS NET CAT.

C C

12001213 TOTAL 1.2E+07 1.2E+07 35000 34000 1242 AF 12411 CORRIDOR 300 CABLE INS NET CAT.

C C

12001215 TOTAL 1.2E+07 1.2E+07 41000 FIRE AREA TOTAL 655 NET CAT.

C TOTAL 2.5E+07 2.4E+07 38000 37000 1201 AF 01 STAIRWELL S02 NO NEGLIGIBLE 1201 AF 02 YES 1211 AF 12104 1221 AF 12204 DIVISION B BATTERY ROOM 2 560 BATTERIES CABLE INS NET CAT.

A C

C 120 10001010 TOTAL 2.4E+07 1.0E+07 3.4E+07 61000 1222 AF 12207 1231 AF 12304 DIVISION B I&C/

PENETRATION ROOM 585 CABLE INS NET CAT.

C C

35003529 TOTAL 3.6E+07 3.6E+07 62000 61000 1231 AF 12344 FIRE AREA TOTAL 2185 NET CAT.

C TOTAL 1.3E+08 59000 1201 AF 03 YES 1211 AF 12105 1221 AF 12205 1231 AF 12305 DIVISION D I&C/

PENETRATION ROOM 585 CABLE INS NET CAT.

C C

35003503 TOTAL 3.6E+07 3.6E+07 65000 1231 AF 12345 FIRE AREA TOTAL 1730 NET CAT.

C TOTAL 1.1E+08 61000

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 10 of 11 Revise UFSAR Table 9A-3, Fire Protection Summary, as shown below.

Table 9A-3 (Sheet 11 of 24)

Fire Protection Summary Fire Area /Zone(1)

Safety Area(2)

Floor Area Sq Ft Combustible Material(3)

Fire Sev.

Cat.

Amount Heat Value (Btu)

Comb.

Load.

Btu/Sq Ft 1242 AF 01 YES 1242 AF 12401A 1242 AF 12401B FIRE AREA TOTAL 2390 NET CAT.

C TOTAL 1.5E+08 64000 1242 AF 02 YES DIVISION A ELECTRICAL PENETRATION ROOM CABLE INS C

20002014 2.1E+07 2.0E+07 FIRE AREA TOTAL 450 NET CAT.

C TOTAL 2.1E+07 2.0E+07 46000 45000 1243 AF 01 YES REACTOR TRIP SWITCHGEAR 1 FIRE AREA TOTAL 95 NET CAT.

C TOTAL 5.1E+06 54000 1243 AF 02 YES REACTOR TRIP SWITCHGEAR 2 FIRE AREA TOTAL 95 NET CAT.

C TOTAL 5.1E+06 54000 1250 AF 01 NO VBS MCR/A&C EQUIPMENT ROOM CABLE INS CHARCOAL LUBE OIL VOLATILES C

C E

E 1200012051 5000 20 10 1.2E+08 7.3E+07 3.0E+06 1.4E+06 FIRE AREA TOTAL 3575 NET CAT.

D TOTAL 2.0E+08 56000

ND-18-1408 Proposed Changes to Licensing Basis Documents (LAR-18-028)

Page 11 of 11 Revise UFSAR Table 9A-4, Ventilation Systems Serving Fire Areas Containing Class 1E Components, as shown below.

Table 9A-4 Ventilation Systems Serving Fire Areas Containing Class 1E Components Ventilation Systems Serving Fire Areas Containing Class 1E Division A and C Components Fire Area RCA Class 1E Components Ventilation System - Subsystem Distribution Header 1202 AF 04 No Division A batteries and equipment VBS - A&C AC-1 1242 AF 02 No Division A equipment and penetrations; Division A & C cable VBS - A&C AC-1 1202 AF 03 No Division C batteries, equipment & penetrations VBS - A&C AC-2 1200 AF 03 No Division B & D A & C cable only VBS - A&C AC-3 1230 AF 01 No Division A & C cable only VBS - B&D BD-3 1240 AF 01 No Division A & C cable only VXS - Equip. room Aux. building 1200 AF 01 Yes Division A valves; division A & C cable VAS - Aux/annex Aux/annex 1200 AF 02 Yes Division A & C cable only VAS - Fuel handling Fuel handling 1250 AF 01 No Division A & C cable only VBS - A&C AC-2 Ventilation Systems Serving Fire Areas Containing Class 1E Division B and D Components Fire Area RCA Class 1E Components Ventilation System - Subsystem Distribution Header 1201 AF 02 No Division B batteries, equipment & penetrations; Division A, B, C, and D interdivisional cable VBS - B&D BD-1 1201 AF 03 No Division D batteries, equipment & penetrations; Division B and D cable; Division A, B, C, and D interdivisional cable VBS - B&D BD-2 1201 AF 04 No Division D valves VBS - B&D BD-Common 1200 AF 03 No Division B & D cable only VBS - A&C AC-3 1220 AF 01 No Division B equipment; division B & D cable VBS - A&C AC-3 1201 AF 05 No Division B & D valves & instrumentation VXS Self-contained 1201 AF 06 No Division B & D valves & instrumentation VXS Self-contained 1230 AF 02 No Division B & D cable only VXS - Equip. Room Aux. building 1220 AF 02 Yes Division D valves VAS - Aux/annex Aux. building Ventilation Systems Serving Principal Class 1E Fire Areas Fire Area RCA Class 1E Components Ventilation System - Subsystem Distribution Header 1242 AF 01 No Main control room VBS - MCR/CSA MCR 1232 AF 01 No Remote shutdown room VBS - B&D BD-3 1210 AF 01 No Spare battery fire area VBS - A&C AC-3 1243 AF 01 No Reactor trip switchgear I VXS - Equip. room Aux. building 1243 AF 02 No Reactor trip switchgear II VXS - Equip. room Aux. building 1000 AF 01 Yes Containment/shield building VFS A and B