ML19046A088

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Issuance of Amendments Request for TS Improvement to Revise Actions for One Steam Supply to Turbine Driven Auxiliary Feedwater Pump Inoperable Using the Consolidated Line Item
ML19046A088
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 06/24/2019
From: John Lamb
Plant Licensing Branch II
To: Gayheart C
Southern Nuclear Operating Co
Lamb J, NRR/DORL/LPLII-1, 415-3100
References
EPID L-2018-LLA-0731
Download: ML19046A088 (20)
v • d • e


Text

June 24, 2019 Ms.Cheryl A.Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENTS REGARDING REQUEST FOR TECHNICAL SPECIFICATION IMPROVEMENT TO REVISE ACTIONS FOR ONE STEAM SUPPLY TO TURBINE DRIVEN AUXILIARY FEEDWATER PUMP INOPERABLE USING THE CONSOLIDATED LINE ITEM IMPROVEMENT PROCESS (EPID L-2018-LLA-0731)

Dear Ms. Gayheart:

The U S Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 200 to Renewed Facility Operating License NPF-68 and Amendment No. 183 to Renewed Facility Operating License NPF-81 for the Vogtle Electric Generating Plant, Units 1 and 2, respectively. The amendments consist of changes to the License and Technical Specifications (TSs) in response to your application dated December 19, 2018, as supplemented by letter dated April 30, 2019.

The amendments revise Conditions, Required Actions, and Completion Times in the TS for the Condition where one steam supply to the turbine-driven Auxiliary Feedwater (AFW) pump is inoperable concurrent with an inoperable motor-driven AFW train.

In addition, the amendments revise the TS that establish specific Actions: (1) for when two motor-driven AFW trains are inoperable at the same time and; (2) for when the turbine-driven AFW train is inoperable either (a) due solely to one inoperable steam supply, or (b) due to reasons other than one inoperable steam supply.

The amendments are consistent with NRC-approved Technical Specification Task Force (TSTF)

Traveler, TSTF-412, Revision 3, "Provide Actions for One Steam Supply to Turbine Driven AFW/EFW Pump Inoperable." The availability of this technical specification improvement was announced in the Federal Register on July 17, 2007 as part of the consolidated line item improvement process.

C. Gayheart A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commission's biweekly Federal Register notice.

Sincerely,

. Lamb, SL ... rn,cr-T Pia I t icensing Branch 11-1 Divi on of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosures:

1. Amendment No. 200 to NPF-68
2. Amendment No. 183 to NPF-81
3. Safety Evaluation cc: Listserv

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-424 VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 200 Renewed License No. NPF-68

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Vogtle Electric Generating Plant, Unit 1 (the facility) Renewed Facility Operating License No. NPF-68 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated December 19, 2018, as supplemented April 30, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-68 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 200, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-68 and the Technical Specifications Date of Issuance: June 2 4, 2 O1 9

UNITED STATES SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-425 VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 183 Renewed License No. NPF-81

1. The Nuclear Regulatory Commission (the Commission) has found that:

A The application for amendment to the Vogtle Electric Generating Plant, Unit 2 (the facility) Renewed Facility Operating License No. NPF-81 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated December 19, 2018, as supplemented April 30, 2019, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 2

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-81 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 183, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented within 90 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch 11-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-81 and the Technical Specifications Date of Issuance: June 2 4 , 2 O1 9

ATTACHMENT VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 TO LICENSE AMENDMENT NO. 200 RENEWED FACILITY OPERATING LICENSE NO. NPF-68 DOCKET NO. 50-424 AND TO LICENSE AMENDMENT NO. 183 RENEWED FACILITY OPERATING LICENSE NO. NPF-81 DOCKET NO. 50-425 Replace the following pages of the Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License License No. NPF-68, page 4 License No. NPF-68, page 4 License No. NPF-81, page 3 License No. NPF-81, page 3 3.7.5-1 3.7.5-1 3.7.5-2 3.7.5-2 3.7.5-3 3.7.5-3

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 200, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) Deleted (5) Deleted (6) Deleted (7) Deleted (8) Deleted (9) Deleted (10) Mitigation Strateg~ License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance
2. Assessment of mutual aid fire fighting assets
3. Designated staging areas for equipment and materials
4. Command and control
5. Training and response personnel (b) Operations to mitigate fuel damage considering the following:
1. Protection and use of personnel assets
2. Communications
3. Minimizing fire spread
4. Procedures for Implementing integrated fire response strategy
5. Identification of readily-available pre-staged equipment
6. Training on integrated fire response strategy Renewed Operating License NPF-68 Amendment No. 200

(2) Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia, pursuant to the Act and 10 CFR Part 50, to possess but not operate the facility at the designated location in Burke County, Georgia, in accordance with the procedures and limitations set forth in this license; (3) Southern Nuclear, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6) Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as my be produced by the operation of the facility authorized herein.

C. This license shall be deemed to contain and is subject to the conditions specified in the Commission's regulations set forth in 10 CFR Chapter 1 and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below.

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 183, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance requirements (SRs) contained in the Appendix A Technical Specifications and listed below are not required to be performed immediately upon implementation of Amendment No. 74. The SRs listed below shall be Renewed Operating License NPF-81 Amendment No. 183

AFWSystem 3.7.5

3. 7 PLANT SYSTEMS 3.7.5 Auxiliary Feedwater (AFW) System LCO 3.7.5 Three AFWtrains shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

ACTIONS

NOTE-----------------------------------------------

LCO 3.0.4b is not applicable.

CONDITION REQUIRED ACTION COMPLETION TIME A. Turbine driven AFW A.1 Restore affected equipment 7 days train inoperable due to to OPERABLE status.

one inoperable steam OR supply.

In accordance with OR the Risk Informed Completion Time

NOTE---------- Program Only applicable if MODE 2 has not been entered following refueling.

One turbine driven AFW pump inoperable in MODE 3 following refueling.

(continued)

Vogtle Units 1 and 2 3.7.5-1 Amendment No. 200 (Unit 1)

Amendment No. 183 (Unit 2)

AFWSystem 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME B. One AFW train B.1 Restore AFW train to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> inoperable for reasons OPERABLE status.

other than Condition A. OR In accordance with the Risk Informed Completion Time Program C. Turbine driven AFW C.1 Restore the steam supply to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> train inoperable due to the turbine driven train to one inoperable steam OPERABLE STATUS.

supply.

OR AND C.2 Restore the motor driven 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> One motor driven AFW AFW train to OPERABLE train inoperable.

status.

D. ---------NOTES------- D.1 Restore AFW trains to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />

1. Not applicable when OPERABLE status.

second AFW train OR intentionally made inoperable. In accordance with

2. The following the Risk Informed Section 5.5.22 Completion constraints are Time Program applicable: parts b, c.2, c.3, d, e, f, g, and h.

Two AFW trains inoperable for reasons other than Condition C.

(continued)

Vogtle Units 1 and 2 3.7.5-2 Amendment No. 200 (Unit 1)

Amendment No. 183 (Unit 2)

AFWSystem 3.7.5 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME E. Required Action and E.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time of Condition A, AND B, C, or D not met.

E.2 Be in MODE4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> F. Three AFW trains F.1 -----------NOl"E------------

inoperable. LCO 3.0.3 and all other LCO Required Actions requiring MODE changes are suspended until one AFW train is restored to OPERABLE status.

Initiate action to restore one Immediately AFW train to OPERABLE status.

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.5.1 -----------------------------NOl"E-----------------------

AFW train(s) may be considered OPERABLE during alignment and operation for steam generator level control, if it is capable of being manually realigned to the AFW mode of operation.

Verify each AFW manual, power operated, and In accordance with automatic valve in each water flow path, and in the Surveillance both steam supply flow paths to the steam turbine Frequency Control driven pump, that is not locked, sealed, or Program otherwise secured in position, is in the correct position.

(continued)

Vogtle Units 1 and 2 3.7.5-3 Amendment No. 200 (Unit 1)

Amendment No. 183 (Unit 2)

UNITED STATES SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 200 TO RENEWED FACILITY OPERATING LICENSE NPF-68 AND AMENDMENT NO. 183 TO RENEWED FACILITY OPERATING LICENSE NPF-81 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425

1.0 INTRODUCTION

By application dated December 19, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML183538056), as supplemented by letter dated April 30, 2019 (ADAMS Accession No. ML19120A210), Southern Nuclear Operating Company, Inc.

(SNC, the licensee), requested changes to the Technical Specifications (TSs) for the Vogtle Electric Generating Plant, Units 1 and 2 (Vogtle 1 and 2).

The requested changes adopt Technical Specification Task Force (TSTF) Traveler, TSTF-412, Revision 3, "Provide Actions for One Steam Supply to the Turbine Driven AFW/EFW Pump Inoperable." The U.S. Nuclear Regulatory Commission (NRC) approval of these changes was announced in the Federal Register on July 17, 2007 (72 FR 39089) as part of the consolidated line item improvement process. The requested change would establish a Completion Time for the Condition where one steam supply to the turbine-driven auxiliary feedwater (AFW) pump is inoperable concurrently with an inoperable motor-driven AFW train and establish specific Conditions and Required Actions: (1) When two motor-driven AFW trains are inoperable at the same time and; (2) when the turbine-driven AFW train is inoperable either (a) due solely to one inoperable steam supply, or (b) due to reasons other than one inoperable steam supply.

By letter dated August 8, 2017 (ADAMS Accession No. ML15127A669), the NRC issued Amendment Nos. 188 and 171 to Vogtle 1 and 2 that modified the TSs to permit use of Risk-Informed Completion Times (RICTs). SNC is not proposing any changes to the previously approved RICTs.

Enclosure 3

The supplement dated April 30, 2019, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the NRC staff's original proposed no significant hazards consideration determination as published the Federal Register on March 12, 2019 (84 FR 8911 ).

2.0 REGULATORY EVALUATION

2.1 System Description The AFW System is designed to automatically supply sufficient water to the steam generators (SGs) to remove decay heat upon the loss of normal feedwater supply with SG pressure at the set point of the Main Steam Safety Valves (MSSVs). Subsequently, the AFW System supplies sufficient water to cool the unit to Residual Heat Removal (RHR) System entry conditions, with steam being released through the Atmospheric Dump Valves (ADVs).

AFW System at Vogtle 1 and 2 consist of two motor-driven AFW pumps and one steam-turbine driven pump configured into three trains. Each motor-driven pump is sized to supply the feedwater flow required for removal of 100 percent of the decay heat from the reactor. The turbine-driven pump is sized to supply up to twice the capacity of a motor-driven pump. The steam turbine-driven pump receives steam from two main steam (MS) lines upstream of the main steam isolation valves (MSIVs). Each of the steam feed lines will supply 100-perent of the requirements of the turbine-driven AFW pump.

2.2 Proposed TS Changes The TS 3.7.5 LCO statement requires three AFW trains to be OPERABLE. The LCO applies during MODES 1, 2 and 3. Condition A describes two situations when the LCO is not met due to an inoperable turbine driven AFW pump. The fist situation is currently described as "One steam supply to turbine driven AFW pump inoperable." The licensee proposed revising the description of the situation to "Turbine driven AFW train inoperable due to one inoperable steam supply."

The licensee proposed adding new Condition C to describe the situation when the LCO is not met due to the turbine driven AFW train being rendered inoperable by one inoperable steam supply concurrent with one inoperable motor driven AFW train. Proposed Required Action C.1 would require restoring the inoperable steam supply to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Proposed Required Action C.2 would require restoring the inoperable motor driven AFW train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. The required Actions would be separated by a logical OR operator which have the effect of allowing continued operation once one of the required actions is completed within the respective Completion Time.

Current Condition C describes the situation when the LCO is not met because two AFW trains are inoperable. It simply states 'Two AFW trains inoperable." The licensee proposed revising the description of current Condition C to state "Two AFW trains inoperable for reasons other than Condition C."

The licensee also proposed re-lettering current Conditions C, D and E along with their associated actions to Conditions and associated actions D, E and F, respectively.

2.3 Guidance and Requirements Considered by NRC Staff In Title 10 of the Code of Federal Regulations ( 10 CFR), Part 50, Section 50.36, the Commission established its regulatory requirements related to the content of Technical Specifications (TS). Pursuant to 10 CFR 50.36(c), TS are required to include items in the following categories: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls.

10 CFR 50.36(c)(2) states, in part: "Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shutdown the reactor or follow any remedial action permitted by the technical specifications until the condition can be met." The remedial actions must provide reasonable assurance that the applicant will comply with the Commission's regulations, and that the health and safety of the public will not be endangered.

Guidance for NRC staff review of TSs is contained in NUREG-0800, "Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR Edition," Section 16.0, "Technical Specifications." The Nuclear Regulatory Commission (NRC) staff has prepared standard technical specifications (STS) for each of the light-water reactor nuclear steam supply systems and associated balance-of-plant equipment systems. The guidance specifies that the staff review whether content and format of proposed TS are consistent with the applicable STS.

Where TS provisions depart from the reference TSs, the staff determines whether proposed differences are justified by uniqueness in plant design or other considerations. The applicable current STS for Vogtle are contained in NUREG-1431, "Standard Technical Specifications -

Westinghouse Plants," Revision 4.0. TSTF-412, Rev 3 was approved by NRC prior to issuance of Revision 4.0 of NUREG-1431. TSTF-412 has been incorporated into Revision 4 of NUREG-1431.

3.0 TECHNICAL EVALUATION

3.1 Method of Review The NRC staff reviewed the licensee's proposed changes to the TS, as well as the justifications and evaluations provided in the license amendment request (LAR) and supplemental letter. To perform the review, the NRC staff compared the licensee's proposal to the standard language in NUREG-1431, and the NRC staff also compared the licensee's proposal to the request for, and approval of, TSTF-412. As explained below, the NRC staff determined that Vogtle TS differ from NUREG-1431, "Standard Technical Specifications -Westinghouse Plants," Revision 4.0 in two significant ways. However, for reasons below, the proposal TS continued to provide reasonable assurance.

3.2 TS 3. 7.5, Applicability The NRC staff reviewed the licensee's proposed changes to the TS, as well as the justifications and evaluations provided in the LAR and supplemental letter. The NRC staff determined that Vogtle TS differ from NUREG-1431, "Standard Technical Specifications - Westinghouse Plants," Revision 4.0 in two significant ways.

Vogtle 1 and 2 TS differ from NUREG-1431, because the LCO for Vogtle 1 and 2 TS 3.7.5 does not apply in MODE 4. The licensee acknowledged this difference in its supplemental later by stating:

[Vogtle Electric Generating Plant] VEGP TS 3.7.5 does not have an Applicability of "Mode 4 when steam generator is relied upon for heat removal." As a result, current VEGP Conditions B, C and E do not specify the Mode Applicability and the STS condition for required AFW train inoperable in Mode 4 is not necessary.

The VEGP TS differences in the Mode 4 Applicability do not affect the applicability of TSTF-412 to the VEGP TS.

The NRC staff determined that the difference above is acceptable since the operability of the AFW system in MODE 4 is not assumed in the safety analysis for Vogtle 1 and 2.

The other way in which Vogtle 1 and 2 TSs differ from NUREG-1431 is that Vogtle TS permit use of optional Risk-Informed CTs for current Conditions A, Band C. Section 3.4 discusses this difference in more detail.

3.3 LCO 3.7.5 Condition A (as proposed)

Condition A is modified to refer to the inoperability of a turbine-driven AFW train due to an inoperable steam supply, instead of referring to the inoperability of a turbine-driven AFW pump.

The proposed change has the effect of making Condition A train-oriented instead of component-oriented, consistent with the other Conditions that are included in NUREG-1431 STS 3.7.5. The NRC staff determined the train-oriented approach is consistent with the preferred approach that is generally reflected in the STS, and, therefore, the proposed change is acceptable.

3.4 New TS 3. 7.5, Condition C NUREG-1431 typically allows a 72-hour or longer CT for Conditions where the remaining operable equipment is able to mitigate postulated accidents without assuming a concurrent single active failure. TSTF-412, as approved by the staff, only allows a 24-hour CT for the situation where the AFW system would be able to perform its function for most postulated events and would only be challenged by a main steam line break (MSLB) or feedwater line break (FLB) that renders the remaining operable steam supply to the turbine-driven AFW pump inoperable. Additionally, depending on the capacity of the operable motor-driven AFW pump, it may be able to mitigate MSLB and FLB accidents during those instances when it is not aligned to the faulted SG. The selection of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> for the CT during development of TSTF-412 was based on the remaining operable steam supply to the turbine-driven AFW pump and the continued functionality of the turbine-driven AFW train, the remaining operable motor-driven AFW train, and the low likelihood of an event occurring during this 24-hour period that would challenge the capability of the AFW system to provide feedwater to the SGs. The CT for this particular situation is consistent with what was approved for Waterford 3 by License Amendment 173 for a similar Condition (ADAMS Accession No. ML012840538), and it is consistent with the

STS in that the proposed CT is much less than the 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> that is allowed for the situation where accident mitigation capability is maintained. SNC proposed a new Condition C, consistent with TSTF-412, with two possible Required Actions (C.1 OR C.2) for the situation when the turbine-driven AFW train is inoperable due to one inoperable steam supply and one motor-driven AFW train is inoperable at the same time. Required Action C.1 requires restoration of the affected steam supply to the turbine-driven train to operable status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Alternatively, Required Action C.2 requires restoration of the inoperable motor-driven AFW train within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

New Condition C provides two proposed CTs that are dependent upon the capacity of the remaining operable motor driven AFW train to provide AFW to the SGs. A proposed 24-hour CT is applicable to plants that may provide insufficient flow to the SGs in accordance with accident analyses assumptions if a MSLB or FLB were to occur that renders the remaining steam supply to the turbine-driven AFW pump inoperable (a concurrent single failure is not assumed). Insufficient feedwater flow could result, for example, if a single motor-driven AFW train does not have sufficient capacity to satisfy accident analyses assumptions, or if the operable pump is feeding the faulted SG (i.e. the SG that is aligned to the operable steam supply for the turbine-driven AFW pump). This would typically apply to plants with each AFW motor-driven pump having less than 100 percent of the required flow. The 24-hour CT is reasonable based on the remaining OPERABLE steam supply to the turbine-driven AFW pump, the availability of the remaining OPERABLE motor-driven AFW pump, and the low probability of an event occurring that would require the inoperable steam supply to be available for the turbine-driven AFW pump. Therefore, the NRC staff agrees that the proposed 24-hour CT is acceptable for this particular situation.

By letter dated August 8, 2017 (ADAMS Accession No. ML15127A669), the NRC issued Amendment Nos. 188 and 171 to Vogtle 1 and 2 that modified the TSs to permit use of Risk-Informed Completion Times (RICTs}. SNC is proposing changes to the previously approved Condition C which contained an option to rely on a RICT for the situation where two AFW trains are inoperable for any reason. As stated in the licensee's supplemental letter dated April 30, 2019 (ADAMS Accession No. ML19120A210), use of the RICT for existing Condition C comes with the following constraints:

The provisions required to enter existing Condition C, which is proposed to be new Condition D with modification, contain limitations (identified in the Note of existing Condition C) not present in the new Condition C, for example:

  • A RICT may only be utilized in Modes 1 and 2 (VEGP TS Section 5.5.22, Constraint b ), which would therefore necessitate a 1-hour Completion Time when the plant is in Mode 3;
  • A RICT must be calculated within the 1-hour Completion Time for emergent conditions (VEGP TS Section 5.5.2, Constraint c.2); and
  • The calculated RICT is limited to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (VEGP TS Section 5.5.2, Constraint e) whereas 24-hours is the standard Completion Time for the proposed Condition C.

Therefore, proposed Condition C provides a predetermined Completion Time appropriate for the condition without invoking the requirements and constraints of the RICT Program inherent in existing Condition C.

The NRC staff evaluated the difference between NUREG-1431 and Vogtle 1 and 2 TS.

While the staff determined that adoption of the TSTF-412 changes would be less restrictive than current Vogtle 1 and 2 TS, because it would allow a longer time to be in a situation where two AFW trains are inoperable than is allowed by current TS, the staff concluded that the adoption is appropriate because it properly adopts the STS, as modified by TSTF-412.

3.5 Re-lettered TS 3.7.5, Condition D The current Condition C and Required Action are re-lettered as Condition D and Required Action D.1. The Condition description has been modified to account for new Condition C. The Condition description is modified from "Two AFW trains inoperable" to "Two AFW trains inoperable for reasons other than Condition C." This change is necessary to recognize the situation specified by new Condition C, where one motor-driven AFW train is allowed to be inoperable at the same time that the turbine-driven AFW train is inoperable due to an inoperable steam supply to the pump turbine. Therefore, the NRC staff finds the proposed change to be acceptable 3.6 Re-lettered TS 3.7.5 Condition E The current Condition D and Required Action D.1 and D.2 are re-lettered as Condition E and Required Action E.1 and E.2. The Condition description has been modified to account for addition of new Condition C and related changes as well as to adopt NUREG-1431 language.

The Condition description now states: "Required Acton and associated Completion Time of Condition A, B, C or D not met". The Required Actions associated with this Condition were renamed from D.1 and D.2 to E.1 and E.2 but not otherwise changed. The NRC staff finds these changes editorial and necessary for internal consistency of TS 3.7.5 as amended. Therefore, the NRC staff determined the proposed change is acceptable

3. 7 Re-lettered TS 3. 7.5 Condition F The current Condition E and Required Action are re-lettered as Condition F and Required Action F.1. The NRC staff determined this change is editorial since no other changes are involved.

Therefore, the NRC staff determined the proposed change is acceptable.

3.8 Re-lettered TS 3.7.5 Condition F (as proposed)

Because current Condition D is renamed as Condition E, current Condition E is renamed as Condition F. This change is editorial as no other changes are involved. Therefore, the proposed change is acceptable.

3.9 Technical Conclusion The NRC staff reviewed the proposed changes as well as the licensee's justifications for the changes. In accordance with NUREG-0800, the NRC staff determined that the content and format of proposed TS are generally consistent with the NUREG-1431. Where TS provisions depart from NUREG-1431, the NRC staff determined the proposed differences are justified by uniqueness in plant design and licensing basis. The NRC staff determined that Vogtle Unit 1 and 2 TS, as modified by the proposed changes to the remedial actions, will continue to meet

the regulatory requirements of 10 CFR 50.36(c)(2). Therefore, the NRC staff determined the proposed changes are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendments on April 1, 2019. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change a requirement with respect to the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and change surveillance requirements. The NRC staff has determined that the amendments involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been [(1) no public comment on such finding (2) the following comments with subsequent disposition by the NRC staff (84 FR 8911, March 12, 2019). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributor: J. Lamb M. Hamm Date: June 24, 2019

ML19046A088 *via email **via memo OFFICE NRR/D0RL/LPL2-1/PM NRR/DORL/LPL2-1 /LA NRR/DORL/LPL2-1 /LAit NRR/DSS/STSB/BC NAME Jlamb KGoldstein KZeleznock PSnyder (A)**

DATE 02/14/19 03/26/19 03/07/19 06/13/19 OFFICE NRR/DSS/SCPB/BC OGC-NLO NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1 /PM NAME SAnderson* DRoth* MMarkley Jlamb DATE 05/16/19 05/17/19 06/21/19 06/24/19

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