ML19189A183
| ML19189A183 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/08/2019 |
| From: | Southern Nuclear Operating Co |
| To: | Office of New Reactors |
| Shared Package | |
| ML19189A180 | List: |
| References | |
| ND-19-0764 | |
| Download: ML19189A183 (7) | |
Text
Southern Nuclear Operating Company ND-19-0764 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Exemption Request:
Functional Arrangement ITAAC Optimization (LAR-19-002)
(This Enclosure consists of 7 pages, Including this cover page.)
ND-19-0764 Exemption Request; Functional Arrangement ITAAC Optimization (LAR-19-002) 1.0 Purpose Southern Nuclear Operating Company (SNC), the Licensee, requests a permanent exemption from the provisions of 10 CFR 52, Appendix D, Section III.B, "Design Certification Rule for the API 000 Design, Scope and Contents," to allow a departure from elements of the certified information in Tier 1 of the generic API 000 Design Control Document (DCD).
The regulation, 10 CFR 52, Appendix D, Section III.B, requires an applicant or licensee referencing Appendix D to 10 CFR Part 52 to incorporate by reference and comply with the requirements of Appendix D, including certification information in DCD Tier 1. Tier 1 includes ITAAC that must be satisfactorily performed prior to fuel load. The design details to be verified by these ITAAC are specified in the text, tables, and figures that are referenced in each individual ITAAC. The generic Tier 1 information from which an exemption is requested includes the plant-specific Tier 1 information, described below, for the proposed changes:
The following plant-specific identified plant-specific Tier
- 1. Tier 1 Table 2.1.1-1,
- 2. Tier 1 Table 2.3.1-2,
- 3. Tier 1 Table 2.3.2-4,
- 4. Tier 1 Table 2.3.3-2,
- 5. Tier 1 Table 2.3.4-2,
- 6. Tier 1 Table 2.3.5-2,
- 7. Tier 1 Table 2.3.6-4,
- 8. Tier 1 Table 2.3.7-4,
- 9. Tier 1 Table 2.3.8-2,
- 10. Tierl Table 2.3.9-3,
- 11. Tierl Table2.3.10-4
- 12. Tierl Table2.3.11-2
- 13. Tierl Table2.3.12-2
- 14. Tierl Table2.3.13-3
- 15. Tierl Table2.3.14-2
- 16. Tierl Table2.3.15-2
- 17. Tier 1 Table 2.3.29-1
- 18. Tierl Table2.4.1-2,
- 19. Tier 1 Table 2.4.2-1,
- 20. Tier 1 Table 2.4.6-2,
- 21. Tier 1 Table 2.5.5-2,
- 22. Tierl Table2.5.6-1,
- 23. Tierl Table2.5.9-1,
- 24. Tier 1 Table 2.6.1-4,
- 25. Tierl Table2.6.4-14
- 26. Tier 1 Table 2.7.1-4,
- 27. Tier 1 Table 2.7.2-2,
- 28. Tier 1 Table 2.7.3-24
- 29. Tier 1 Table 2.7.4-2,
- 30. Tier 1 Table 2.7.5-2, ITAAC items are proposed to be identified as "Not Used" in the 1 tables, as shown in Enclosure 3 of this letter:
TAAC Item 1 - FHS Functional Arrangement TAAC Item 1 - CCS Functional Arrangement TAAC Item 1 -
CVS Functional Arrangement TAAC Item 1 - DOS Functional Arrangement TAAC Item 1 -
FPS Functional Arrangement TAAC Item 1 - MRS Functional Arrangement TAAC Item 1 - RNS Functional Arrangement TAAC Item 1 -SFS Functional Arrangement TAAC Item 1 - SWS Functional Arrangement TAAC Item 1 -
VLB Functional Arrangement ITAAC Item 1 - WLS Functional Arrangement ITAAC Item 1 - WGS Functional Arrangement ITAAC Item 1 - WSS Functional Arrangement ITAAC Item 1 - PSS Functional Arrangement ITAAC Item 1 - DWS Functional Arrangement ITAAC Item 1 - CAS Functional Arrangement ITAAC Item 1 - WRS Functional Arrangement TAAC Item 1 - FWS Functional Arrangement TAAC Item 1 - MTS Functional Arrangement TAAC Item 1 - CDS Functional Arrangement TAAC Item 1 -
IIS Functional Arrangement TAAC Item 1 -
SMS Functional Arrangement TAAC Item 1 -
SJS Functional Arrangement TAAC Item 1 - ECS Functional Arrangement ITAAC Item 1 -
ZDS Functional Arrangement TAAC Item 1 - VBS Functional Arrangement TAAC Item 1 - VWS Functional Arrangement ITAAC Item 1 - VXS Functional Arrangement TAAC Item 1 -
VZS Functional Arrangement TAAC Item 1 - VAS Functional Arrangement Page 2 of 7
ND-19-0764 Exemption Request; Functional Arrangement ITAAC Optimization (U\\R-19-002)
- 31. Tier 1 Table 2.7.6-1, ITAAC Item 1 -
VPS Functional Arrangement
- 32. Tier 1 Table 2.7.7-2, ITAAC Item 1 -
VCS Functional Arrangement This request for exemption provides the technical and regulatory basis to demonstrate that 10 CFR 52.63, §52.7, and §50.12 requirements are met and will apply the requirements of 10 CFR 52, Appendix D, Section VIII.A.4 to allow departures from generic Tier 1 information due to proposed elimination of ITAAC.
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 API000 nuclear plants, named Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively. The proposed changes would remove a number of functional arrangement ITAAC contained in plant-specific Tier 1.
During preparation and submittal of ITAAC Closure Notifications (ICNs), SNC identified efficiencies to the ICN submittal process, including ITAAC which contain redundant information or have been determined to be verified through other means commensurate with its safety significance and are proposed to be removed. Submittal of ICNs based upon the current plant-specific Tier 1 information creates additional regulatory burden on the Licensee and the NRC staff. The identified efficiencies would remove a number of functional arrangement ITAAC to improve efficiency of the ITAAC completion and closure process.
This activity requests an exemption from the Generic DCD Tier 1 tables which support the associated COL Appendix C ITAAC.
An exemption from elements of the AP1000 certified (Tier 1) design information is requested to allow plant-specific departures to be taken from the Tier 1 ITAAC Tables listed in Section 1.0 of this Enclosure.
3.0 Technical Justification of Acceptabiiity An exemption is requested to depart from API 000 Generic DCD Tier 1 material in regard to the API 000 by removing ITAAC that contain redundant information or have been determined to be verified through other means commensurate with its safety significance.
The proposed ITAAC optimization continues to meet the intent of 10 CFR Part 52 Appendix D and plant-specific Tier 1 design descriptions, tables and figures. The proposed exemption would allow a change to the plant-specific Tier 1 ITAAC information consistent with existing plant-specific DCD Tier 2 information. The proposed changes to the description information presented in plant-specific Tier 1 are at a level of detail that is consistent with the information currently provided therein.
The proposed changes neither adversely impact the ability to meet the design functions of the SSCs nor involve a significant decrease in the level of safety provided by the structures, systems, or components. Because the proposed changes are consistent with plant-specific DCD Tier 2 information and the design, the changes do not affect a structure, system or component. The proposed changes to information in plant-specific DCD Tier 1 continue to provide the detail necessary to implement the corresponding ITAAC.
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ND-19-0764 Exemption Request: Functional Arrangement ITAAC Optimization (LAR-19-002)
Detailed technical justification supporting this request for exemption is provided in Section 2
of the associated License Amendment Request in Enclosure 1 of this letter 4.0 Justification of Exemption 10 CFR 52, Appendix D, Section VIII.A.4, 10 CFR 52.63(b)(1), and 52.98(f) govern the issuance of exemptions from elements of the certified design information for API 000 nuclear power plants. Since SNC has identified changes to the Tier 1 information based on a review of other ITAAC that would demonstrate the system functional arrangement, an exemption to the certified design information in Tier 1 is needed.
10 CFR 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)(ii)]; 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 Commission's regulations.
Accordingly, this requested exemption is "authorized by law," as required by 10 CFR 50.12(a)(1).
- 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 DCD Tier 1 to depart from the API 000 certified (Tier 1) design information. The plant-specific DCD Tier 1 will continue to reflect the approved licensing basis for VEGP Units 3 and 4 and will maintain a consistent level of detail with that which is currently provided elsewhere in Tier 1 of the DCD. Therefore, the affected plant-specific DCD Tier 1 ITAAC will continue to serve its required purpose.
These changes will not impact the ability of the SSCs to perform their design functions.
Because the changes will not alter the operation of any plant equipment or systems, these changes do not present an undue risk to existing equipment or systems. The removal of functional arrangement ITAAC that is demonstrated by other ITAAC or Page 4 of 7
ND-19-0764 Exemption Request: Functional Arrangement ITAAC Optimization (l_AR-19-002) demonstrated by other means commensurate with its safety significance does 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 that are intended to mitigate any existing on-site hazards.
Furthermore, the proposed changes 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 significant fuel cladding failures. Accordingly, these changes do not present an undue risk from any new 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 DCD Tier 1 design information. The requested exemption does not alter the design, function, or operation of any structure or plant equipment that is necessary to maintain a safe and secure status of the plant. The requested exemption has no impact on plant security or safeguards procedures.
Therefore, the requested exemption is consistent with the common defense and security.
- 4. Special circumstances are present 10 CFR 50.12(a)(2) lists six "special circumstances" for which an exemption may be granted.
Pursuant to the regulation, it is necessary for one of these special circumstances to be present in order for the NRC to consider granting an exemption request. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subsection defines special circumstances as when "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."
The rule under consideration in this request for exemption is 10 CFR 52, Appendix D, Section III.B, which requires that a licensee referencing the API 000 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 API 000 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 API 000 design certification, and to require compliance with the design certification information in Appendix D.
The proposed change to remove redundant functional arrangement ITAAC where the system functional arrangement is verified by other ITAAC or by other means commensurate with its safety significance will maintain the design functions of these systems. This change does not impact the ability of any SSCs to perform their functions or negatively impact safety.
Accordingly, this exemption from the certification information will enable the licensee to safely construct and operate the API 000 facility consistent with the design certified by the NRC in 10 CFR 52, Appendix D.
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ND-19-0764 Exemption Request: Functional Arrangement ITAAC Optimization (LAR-19-002)
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 to remove redundant functional arrangement ITAAC and the understanding that these changes are not changing system design descriptions and functions, these changes will not have a negative impact. Nevertheless, if other API 000 licensees do not elect to request this exemption, the special circumstances continue to outweigh any decrease in safety from the reduction in standardization because the key design functions associated with this request will continue to be maintained. This exemption request and the associated marked-up table demonstrate that there is a minimal change from the generic API ODD DCD, minimizing the reduction in standardization and, consequently, the safety impact from the reduction.
Therefore, the special circumstances associated with the requested exemption outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.
- 6. The design change will not result in a significant decrease in the level of safety The proposed exemption would allow changes to remove ITAAC that contain redundant information in plant-specific Tier 1. The changes will not impact the functional capabilities of the components identified in the affected ITAAC. Because the removal of the ITAAC associated with this exemption request will not modify the design or operation of any systems or equipment, there are no new failure modes introduced by these changes and the level of safety provided by the current structures, systems, and components will be unchanged.
Because the proposed changes to functional arrangement ITAAC will not adversely affect the ability of the structures, systems or components to perform their design functions and the level of safety provided by the structures, systems, and components is unchanged, it is concluded that the changes associated with this proposed exemption will not result in a significant decrease 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 None.
7.0 ENVIRONMENTAL CONSIDERATION
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ND-19-0764 Exemption Request: Functional Arrangement ITAAC Optimization (LAR-19-002)
The Licensee requests a departure from elements of the certified information in Tier 1 of the generic AP1000 DCD. The Licensee has determined that the proposed departure would require a permanent exemption from the requirements of 10 CFR 52, Appendix D, Section ill.B, Design Certification Rule for the API 000 Design, Scope and Contents, with respect to reducing ITAAC; however, the Licensee evaluation of the proposed exemption has determined that the proposed exemption meets the eligibiiity criteria for categoricai 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 (ill) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed exemption meets the eligibility criteria for categoricai exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmentai 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 Enciosure 1 of this ietter.
8.0 CONCLUSION
The proposed changes to Tier 1 are necessary to optimize information in iTAAC Tables in plant-specific DCD Tier 1 to improve efficiency of the ITAAC completion and ciosure process. The exemption request meets the requirements of 10 CFR 52.63, "Finaiity of Design Certifications," 10 CFR 52.7, "Specific Exemptions," 10 CFR 50.12, "Specific Exemptions," and 10 CFR 52 Appendix D, "Design Certification Ruie for the API 000."
Specificaiiy, 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 API 000 Design Certification Ruie, and does not present a significant decrease in safety as a result of a reduction in standardization.
9.0 REFERENCES
None.
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