ML19337B326

Safety Evaluation - Vogtle Electric Generating Plant Units 3 and 4 (LAR 19-002)

ML19337B326
Person / Time
Site:	Vogtle
Issue date:	12/27/2019
From:	Chandu Patel NRC/NRR/VPOB
To:	City of Dalton, GA, Georgia Power Co, MEAG Power, Oglethorpe Power Corp, Southern Nuclear Operating Co
Patel C
Shared Package
ML19337A667	List: ML19337A713 ML19337A741 ML19337A926 ML19337B139 ML19337B183 ML19337B326 ML19339C595 ML19339C638
References
LAR 19-002
Download: ML19337B326 (25)

Text

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 170 AND 168 TO THE COMBINED LICENSE NOS. NPF-91 AND NPF-92, RESPECTIVELY SOUTHERN NUCLEAR OPERATING COMPANY, INC.

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

1.0 INTRODUCTION

By letter dated July 8, 2019 (Agencywide Documents Access and Management System (ADAMS) Accession Nos. ML19189A181, ML19189A182, ML19189A183, and ML19189A184),

Southern Nuclear Operating Company, Inc. (SNC) requested that the U.S. Nuclear Regulatory Commission (NRC or Commission) amend the Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Combined License (COL) Nos. NPF-91 and NPF-92, respectively. The License Amendment Request (LAR)19-002 requested changes to Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) in COL Appendix C and corresponding plant-specific design control document (PS-DCD) Tier 1 information to remove a number of functional arrangement ITAAC, whose design commitments are verified via other ITAAC or otherwise verified by other means.

Pursuant to Section 52.63(b)(1) of Title 10 of the Code of Federal Regulations (10 CFR), SNC also requested an exemption from the provisions of 10 CFR Part 52, Appendix D, Design Certification Rule for the AP1000 Design,Section III.B, Scope and Contents. The requested exemption would allow a departure from the corresponding portions of the certified information

in Tier 1 of the generic DCD.1 In order to modify the PS-DCD Tier 1 information, the NRC must find SNCs exemption request included in its submittal for the LAR to be acceptable. The staffs review of the exemption request, as well as the LAR, is included in this safety evaluation.

2.0 REGULATORY EVALUATION

LAR 19-002 proposes to remove a number of functional arrangement ITAAC, whose design commitments are verified via other ITAAC or otherwise verified by other means. The staff considered the following regulatory requirements in reviewing the LAR that included the proposed changes:

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

10 CFR 52.63(b)(1) allows the licensee who references a design certification rule to request NRC approval for an exemption from one or more elements of the certification information. The Commission may only grant such a request if it determines that the exemption will comply with the requirements of 10 CFR 52.7, which, in turn, points to the requirements listed in 10 CFR 50.12 for specific exemptions. In addition to the factors listed in 10 CFR 52.7, the Commission shall consider whether the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption. Therefore, any exemption from the Tier 1 information certified by Appendix D to 10 CFR Part 52 must meet the requirements of 10 CFR 50.12, 52.7, and 52.63(b)(1).

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

Therefore, NRC approval is required prior to making the plant specific proposed changes in this LAR.

10 CFR 52.97(b) requires that the COL identify the ITAAC, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will operate in conformity with the license, the provisions of the Atomic Energy Act of 1954, as amended (AEA), and the Commissions rules and regulations.

10 CFR 50.34a(d) as it relates to equipment necessary to control releases of radioactive effluents to the environment.

1 While SNC describes the requested exemption as being from Section III.B of 10 CFR Part 52, Appendix D, the entirety of the exemption pertains to proposed departures from Tier 1 information in the PS-DCD.

In the remainder of this evaluation, the NRC will refer to the exemption as an exemption from Tier 1 information to match the language of Section VIII.A.4 of 10 CFR Part 52, Appendix D, which specifically governs the granting of exemptions from Tier 1 information.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 3, as it relates to minimizing the probability and effect of explosions.

10 CFR Part 50, Appendix A, GDC 60 as it relates to the ability of the liquid waste system (WLS) and the gaseous radwaste system (WGS) to control releases of radioactive materials to the environment during normal reactor operation, including anticipated operational occurrences.

10 CFR Part 50, Appendix A, GDC 61 as it relates to the ability of the solid radwaste system (WSS) to provide storage volumes for expected levels of waste generated during operations.

10 CFR Part 50, Appendix A, GDC 64 as it relates to monitoring liquid and gaseous effluent releases from the plant during normal operations, including anticipated operational occurrences, and from postulated accidents.

3.0 TECHNICAL EVALUATION

3.1 EVALUATION OF THE REQUESTED CHANGES As described in LAR-19-002, SNC proposed to amend Appendix C of the VEGP Units 3 and 4 COLs by removing ITAAC verifying the functional arrangement of systems, by showing that the design commitment (DC) for the ITAAC is verified by other ITAAC or is otherwise verified by other means. Appendix C of the VEGP Units 3 and 4 COLs defines functional arrangement (for a system) as the physical arrangement of systems and components to provide the service for which the system is intended, and which is described in the system design description.

The functional arrangement ITAAC require the performance of inspections of the as-built system to verify the as-built system conforms with the functional arrangement, as described in the Tier 1 Design Description. The purpose and scope of functional arrangement ITAAC are discussed in Nuclear Energy Institute (NEI) 08-01, Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52, Revision 5 - Corrected, which is approved for use by Regulatory Guide 1.215, Revision 2, with certain exceptions and additional guidance not relevant to this LAR. Section 10.5 of NEI 08-01 indicates that functional arrangement ITAAC verify (1) that components are physically arranged as shown in any referenced figure, and located as identified in any referenced table, if the ITAAC refers to a Tier 1 figure or table; and (2) that system components identified in the Tier 1 Design Descriptions are physically arranged as specified by the design. Thus, the functional arrangement ITAAC for a system is limited to the components identified by the Tier 1 design description for the system, including any referenced tables and figures.

SNC states that for each of the functional arrangement ITAAC proposed to be removed, the Tier 1 Design Description (including tables and figures) and associated updated final safety analysis report (UFSAR) design information is not proposed to be changed and remains consistent with the current plant design. Therefore, no structure, system, or component (SSC), design function, or analysis, as described in the UFSAR, is affected by the proposed changes. The staff agrees with SNC that the proposed LAR does not affect any aspects of the plant design or operation.

In general terms, SNC proposes to remove functional arrangement ITAAC because systems with functional arrangement ITAAC:

may also include other ITAAC that demonstrate functionality of the system or verify that they are functionally arranged, including the same components and piping identified in the figures and / or tables referenced in the ITAAC. Testing and inspection of the components, piping, and interfaces through these other

ITAAC confirms [the] existence of the components in their correct arrangement.

As such, the scope of functional arrangement ITAAC is bounded by the ITAAC demonstrating the functionality, or otherwise verified by other means, and the functional arrangement ITAAC in and of themselves do not verify any unique design attributes.

For each ITAAC SNC proposes to remove, the application describes what the functional arrangement ITAAC verifies the relevant system. The application, provides the basis for concluding that other ITAAC adequately verify the functional arrangement for that system in whole or in part. The application specifically describes these other ITAAC and how they indirectly contribute to verifying the systems functional arrangement.

The staff evaluated the proposed changes to determine whether each of the ITAAC functional arrangement proposed to be removed is bounded by other ITAAC (that is, whether the other ITAAC indirectly demonstrate that the relevant Tier 1 SSCs are physically arranged to provide the service for which the system is intended, as described in the Tier 1 design description for the system). To the extent a functional arrangement ITAAC is not bounded by other ITAAC, the staff determined whether the unbounded portions of the functional arrangement ITAAC are required to be included as ITAAC in accordance with 10 CFR 52.97(b). In deciding whether the other ITAAC are sufficient per 10 CFR 52.97(b) to provide reasonable assurance that the facility has been constructed and will be operated in accordance with the license, the AEA, and NRC rules and regulations, the following considerations apply:

If an SSC is not needed to meet the regulations and is otherwise not safety-significant, then an ITAAC on that SSC is not required.

The safety significance of the system and pertinent components is relevant to determining how much assurance the ITAAC must provide (i.e., whether the ITAAC provide the reasonable assurance required by 10 CFR 52.97(b).

Even if a portion of a functional arrangement ITAAC is not bounded by other ITAAC, those other ITAAC might still be sufficient to satisfy 10 CFR 52.97(b) by verifying that the system functions in accordance with the regulations by other means. For example, showing by testing that the system functions as required even if the test does not verify the physical arrangement of certain Tier 1 components.

SNC notes that some Tier 1 SSCs covered by the functional arrangement ITAAC are not verified by other ITAAC. However, SNC proposed that, it is still acceptable to eliminate the functional arrangement ITAAC because the initial test program (ITP) verifies the functional arrangement of these SSCs. The staff did not rely on this point because 10 CFR 52.97(b) requires that the ITAAC be sufficient to provide the requisite reasonable assurance. Thus, a finding on whether 10 CFR 52.97(b) is met depends on what the ITAAC verify, not on whether some other program verifies something that the ITAAC do not verify.

Each of the functional arrangement ITAAC proposed to be removed is evaluated below.

3.1.1 Fuel Handling and Refueling System (FHS)

In LAR 19-002, SNC proposes to remove the FHS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.1.1-1, ITAAC Index No. 1 (ITAAC 2.1.01.01). SNCs justification is that the FHS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the FHS functional arrangement ITAAC is verified by the integrated system inspections and testing ITAAC (ITAAC

Index No. 4 (ITAAC 2.1.01.04) and ITAAC Index No. 107 (ITAAC 2.2.01.07.1)). Therefore, the staff finds the proposed removal of the functional arrangement ITAAC acceptable, because the functional arrangement ITAAC proposed to be removed is bounded by other ITAAC.

3.1.2 Component Cooling System (CCS)

In LAR 19-002, SNC proposes to remove the CCS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.1-2, ITAAC Index No. 278 (ITAAC 2.3.01.01). SNCs justification is that the CCS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the CCS functional arrangement ITAAC is verified by other ITAAC (ITAAC Index No. 281 (ITAAC 2.3.01.03.ii) and ITAAC Index No. 108 (ITAAC 2.2.01.07.ii - associated with containment isolation)). Therefore, the staff finds the proposed removal of the CCS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is bounded by other ITAAC.

3.1.3 Chemical and Volume Control System (CVS)

In LAR 19-002 SNC requests removing the CVS functional arrangement ITAAC COL Appendix C, and plant-specific Tier 1, Table 2.3.2-4, ITAAC Index No. 284 (ITAAC No. 2.3.02.01). In LAR 19-002, SNC asserts that other ITAAC confirms [the] existence of the components in their correct arrangement, obviating the need for functional arrangement ITAAC for certain systems.

SNC considers three categories of ITAAC as applicable: American Society of Mechanical Engineers Boiler & Pressure Vessel (ASME B&PV) Code ITAAC, equipment qualification ITAAC, and functional testing ITAAC.

While the ASME B&PV Code does require an inspection of as-built components and a report which certifies that components are constructed in accordance with ASME B&PV Code requirements, it does not encompass the entirety of the design requirements for a system. The ASME B&PV Code is a pressure integrity code-it provides rules of safety relating only to pressure integrity, as indicated in the Foreword to the ASME BPV Code, - the design requirements ensure that a system retains pressure but does not provide any assurance of system function beyond pressure retention. Therefore, the staff does not agree with statements made by SNC, such as The location and function of these valves are verified through this

[ASME BPV Code] ITAAC; no additional information is verified by completion of the functional arrangement ITAAC. It is inaccurate to state that when an ASME report covers the same components as the functional arrangement ITAAC, no additional information is verified by the completion of that functional arrangement ITAAC, because attributes that are necessary to a systems ability to provide the service for which it is intended, such as pipe slope or check valve orientation, would not necessarily be verified through an ASME report, as the system would still maintain pressure integrity.

SNC also asserts that equipment qualification ITAAC bound the scope of functional arrangement ITAAC. These equipment qualification ITAAC are closed through submittal of an equipment qualification data package, which contains information related to equipment identification and installation requirements. This data package includes installation attributes such as component orientation, bolting requirements, and wiring configurations, which are verified as part of the as-built walkdowns required by the ITAAC. Similar to the discussion above regarding ASME B&PV Code ITAAC, the staff disagrees with SNCs statement that when EQ as-built ITAAC covers the same components as the functional arrangement ITAAC, no additional information is verified by completion of that functional arrangement ITAAC.

Aspects of functional arrangement ITAAC can be verified through activities completed as part of the equipment qualification (EQ) as-built ITAAC, but SNCs statement appears to indicate a one-to-one correspondence, (i.e., the entire scope of functional arrangement is covered by the single category of EQ as-built ITAAC). Attributes that could affect a systems ability to provide the service for which it is intended, but are not important to equipment qualification, such as pipe slope, might not be captured during completion of an EQ as-built ITAAC.

SNC notes that the functional testing ITAAC requires a pre-test walkdown to confirm the as-built system configuration matches the detailed system drawings. It is also noted that the actual testing verifies the functionality of the component and/or integrated system, which validates that the system is arranged such that functions can be achieved as designed. SNC notes that when functional testing ITAAC cover the same components as the functional arrangement ITAAC, no additional information is verified by completion of that functional arrangement ITAAC. Similar to the discussion above, aspects of functional arrangement ITAAC can be verified through activities completed as part of the functional testing ITAAC, but the SNCs statement appears to indicate a one-to-one correspondence (i.e., the entire scope of functional arrangement is covered by the single category of functional testing ITAAC.) Attributes that could affect a systems ability to provide the service for which it is intended but are not important to meeting the acceptance criteria of the functional test might not be captured during completion of a functional testing ITAAC.

While the staff disagrees with the SNCs assertions of one-to-one correspondence between functional arrangement ITAAC and ASME B&PV Code, EQ as-built, and functional testing ITAAC, respectively, the staff does acknowledge that overlap can exist between the functional arrangement ITAAC and those other categories of ITAAC mentioned in the LAR. The staff believes that satisfaction of ASME B&PV Code, EQ as-built, and functional testing ITAAC, collectively, can be used to demonstrate satisfaction of functional arrangement ITAAC for the CVS. In the case of this proposed system, demonstration of acceptable results for the attributes verified through ASME B&PV Code, EQ as-built, and functional testing provides reasonable assurance that the proposed system can provide the service for which it is intended without the need for a specific functional arrangement ITAAC. The staff considers this acceptable because the proposed system is of lesser safety significance and would therefore require less rigor in the demonstration of functional arrangement, permitting satisfaction through the combination of existing ITAAC as proposed in this LAR.

LAR 19-002 provides the following key attributes from the COL Appendix C Section 2.3.2 design description for the CVS:

The CVS provides reactor coolant system (RCS) purification, RCS inventory control and makeup, chemical shim and chemical control, oxygen control, and auxiliary pressurizer spray.

The CVS is as shown in Figure 2.3.2-1 and the component locations of the CVS are as shown in Table 2.3.2-5.

SNC states that the DC for ITAAC No. 2.3.02.01 (ITAAC Index No. 284) is demonstrated through the [Inspections, Tests, Analyses (ITA)] and [Acceptance Criteria] of other ITAAC, specifically the testing and inspections performed for CVS, which include functional testing and integrated system inspections that demonstrate the required components exist and that they are connected in a manner to perform the intended function. SNC lists the following functional ITAAC associated with CVS components in Figure 2.3.2-1 and Table 2.3.2-5 that show the design commitment of the CVS functional arrangement ITAAC, ITAAC No. 2.3.02.01 (ITAAC

Index No. 284): ITAAC No. 2.2.01.07.ii (ITAAC Index No.108), ITAAC No. 2.3.02.02a (ITAAC Index No.285), ITAAC No. 2.3.02.08a.i (ITAAC Index No.301), ITAAC No. 2.3.02.08a.iii (ITAAC Index No.303).

The staff reviewed the proposed changes to remove ITAAC Index No. 284 (ITAAC No.

2.3.02.01) from the associated ITAAC table and confirmed that its DC would be sufficiently verified by the remaining ITAAC. Therefore, the staff agrees to remove CVS functional arrangement ITAAC.

3.1.4 Standby Diesel Fuel Oil System (DOS)

In LAR 19-002, SNC proposes to remove the DOS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.3-2, ITAAC Index No. 318 (ITAAC 2.3.03.01). SNCs justification is that the DOS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of DOS functional arrangement ITAAC is verified by other ITAAC (ITAAC Index No. 322 (ITAAC 2.3.03.03c),

ITAAC Index No. 319 (ITAAC 2.3.03.02), ITAAC Index No. 320 (ITAAC 2.3.03.03a), ITAAC Index No. 321 (ITAAC 2.3.03.03b), ITAAC Index No. 323 (ITAAC 2.3.03.03d), and ITAAC Index No. 324 (ITAAC 2.3.03.04)). Therefore, the staff finds the proposed removal of DOS functional arrangement ITAAC acceptable, because the functional arrangement ITAAC proposed to be removed is bounded by other ITAAC.

3.1.5 Fire Protection System (FPS)

In LAR 19-002, SNC proposes to remove the FPS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.4-2, ITAAC Index No. 326 (ITAAC 2.3.04.01). SNCs justification is that the FPS functional arrangement design commitment is largely verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of FPS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index No. 107 (ITAAC 2.2.01.07.i), ITAAC Index No. 327 (ITAAC 2.3.04.02.i), ITAAC Index No. 330 parts 4, 6, and 7 (ITAAC 2.3.04.04.i), ITAAC Index No. 331 (ITAAC 2.3.04.04.ii), ITAAC Index No. 332 (ITAAC 2.3.04.05), ITAAC Index No. 336 (ITAAC 2.3.04.09), ITAAC Index No. 337 (ITAAC 2.3.04.10),

and ITAAC Index No. 338 (ITAAC 2.3.04.11)). The staff concludes that the combination of all the above ITAAC demonstrates with reasonable assurance the functional arrangement of the FPS prior to initial fuel load. The staff finds that 10 CFR 52.97(b), as it relates to ITAAC for the VEGP Units 3 and 4 FPS, is met without the functional arrangement ITAAC Index No. 326 (ITAAC 2.3.04.01). Therefore, the staff finds the proposed removal of FPS functional arrangement ITAAC acceptable.

3.1.6 Mechanical Handling System (MHS)

In LAR 19-002, SNC proposes to remove the MHS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.5-2, ITAAC Index No. 339 (ITAAC 2.3.05.01). SNCs justification is that the MHS functional arrangement DC is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of MHS functional arrangement ITAAC is verified by the following functional ITAAC (i.e., ITAAC verifying the systems functions): ITAAC Index No. 340 (ITAAC 2.3.05.02.1) and ITAAC Index No. 344 (ITAAC 2.3.05.03a.ii). These ITAAC are associated with MHS components and demonstrate the required components exist and are arranged to perform the intended function. Therefore, the staff finds the proposed removal of MHS functional arrangement ITAAC acceptable, because the functional arrangement ITAAC proposed to be removed is bounded by other ITAAC.

3.1.7 Normal Residual Heat Removal System (RNS)

LAR 19-002 requests removing the RNS functional arrangement ITAAC in COL Appendix C, and plant-specific Tier 1, Table 2.3.6-4, ITAAC Index No. 354 (ITAAC No. 2.3.06.01). The staffs evaluation in Section 3.1.3 of SNCs assertion that other ITAAC (ASME B&PV Code ITAAC, equipment qualification ITAAC, and functional testing ITAAC) confirm functional arrangement for the CVS is also applicable to the RNS.

LAR 19-002 provides the following key attributes from the COL Appendix C, Section 2.3.6 design description for the RNS:

The RNS removes heat from the core and RCS and provides RCS low temperature over-pressure (LTOP) protection at reduced RCS pressure and temperature conditions after shutdown. The RNS also provides a means for cooling the in-containment refueling water storage tank (IRWST) during normal plant operation.

The RNS is as shown in Figure 2.3.6-1, and the RNS component locations are as shown in Table 2.3.6-5.

SNC states that the DC for ITAAC No. 2.3.06.01 (ITAAC Index No. 354) is demonstrated through the inspection, tests, and analyses (ITA) and AC of other ITAAC. SNC lists the following functional ITAAC associated with RNS components in Figure 2.3.6-1 and Table 2.3.6-5 that verify the design commitment of the RNS functional arrangement ITAAC, ITAAC No. 2.3.06.01 (ITAAC Index No. 354): ITAAC No. 2.2.01.07.11 (ITAAC Index No.

108), ITAAC No. 2.3.06.02a (ITAAC Index No. 355), ITAAC No. 2.3.06.05a.i (ITAAC Index No. 361), ITAAC No. 2.3.06.07b (ITAAC Index No. 368), and ITAAC No. 2.3.06.09b.ii (ITAAC Index No. 375).

The staff reviewed the proposed changes to remove ITAAC No. 2.3.06.01 (ITAAC Index No. 354) from the associated ITAAC table and confirmed that its DC would be sufficiently verified by the remaining ITAAC. Therefore, the removal of ITAAC Index No. 354 (ITAAC No.

2.3.06.01) is acceptable.

3.1.8 Spent Fuel Pool Cooling System (SFS)

In LAR 19-002, SNC proposes to remove the SFS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.7-4, ITAAC Index No. 391 (ITAAC 2.3.07.01). SNCs justification is that the SFS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the design commitment of SFS functional arrangement ITAAC is verified by other ITAAC: (ITAAC Index No. 408 (ITAAC

2.3.07.07c), ITAAC Index No. 399 (ITAAC 2.3.07.06a), ITAAC Index No. 145 (ITAAC 2.2.02.07f.i), ITAAC Index No. 881 (ITAAC 2.3.07.07b.vii), ITAAC Index No. 402 (ITAAC 2.3.07.07b.i), ITAAC Index No. 403 (ITAAC 2.3.07.07b.ii), ITAAC Index No. 392 (ITAAC 2.3.07.02a), ITAAC Index No. 396 (ITAAC 2.3.07.05.i), ITAAC Index No. 108 (ITAAC 2.2.01.07.ii), ITAAC Index No. 117 (ITAAC 2.2.01.11a.iv), and ITAAC Index No. 98 (ITAAC 2.2.01.05.i)). These ITAAC demonstrate that the required components exist and are arranged to perform the intended safety-related and defense-in depth function. Regarding the two SFS demineralizers and filters not covered by other ITAAC, these components have no safety-related or defense-in-depth function. These components (i.e., SFS demineralizers and filters) are located on a piping segment that can be isolated from the main SFS piping. Therefore, the staff finds the proposed removal of functional arrangement ITAAC acceptable, because the functional arrangement ITAAC proposed to be removed is bounded by other ITAAC.

3.1.9 Service Water System (SWS)

In LAR 19-002, SNC proposes to remove the SWS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.8-2, ITAAC Index No. 414 (ITAAC 2.3.08.01). SNCs justification is that the SWS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the design commitment of the SWS functional arrangement ITAAC is verified by other ITAAC (ITAAC Index No. 415 (ITAAC 2.3.08.02.i) and ITAAC Index No. 417 (ITAAC 2.3.08.02.iii)). Therefore, the staff finds the proposed removal of SWS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is bounded by other ITAAC.

3.1.10 Containment Hydrogen Control System (VLS)

In LAR 19-002, SNC proposes to remove the VLS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.9-3, ITAAC Index No. 420 (ITAAC 2.3.09.01). SNCs justification is that the VLS functional arrangement design commitment is largely verified by other ITAAC and verified by the ITP for VLS components described in the Tier 1 Design Description (i.e., recombiners) that do not have corresponding ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the design commitment of the VLS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index No. 421 (ITAAC 2.3.09.02.a); ITAAC Index No. 422 (ITAAC 2.3.09.02.b); ITAAC Index No. 425 (ITAAC 2.3.09.03.iii); and ITAAC Index No. 426 (ITAAC 2.3.09.03.iv)). SNC states that the VLS contains two catalytic hydrogen recombiners not listed in the above table, which are outside the scope of other ITAAC. The VLS performs no safety-related functions, and the defense-in-depth functions do not rely on the recombiners.SNC states that these components are not used to satisfy any requirements in 10 CFR 50.34(f) or 10 CFR 50.44. Therefore, the staff finds the proposed removal of VLS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is largely bounded by other ITAAC, and the two hydrogen recombiners not covered by other ITAAC are not needed to meet the regulations and are otherwise not safety-significant.

3.1.11 Liquid Radwaste System (WLS)

In LAR 19-002, SNC proposes to remove the WLS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.10-4, ITAAC Index No. 430 (ITAAC

2.3.10.01). SNCs justification is that the WLS functional arrangement design commitment is largely verified by other ITAAC, and that non-safety significant components not verified by ITAAC are verified by the ITP.

The staff reviewed the information in LAR 19-002 and finds that the DC of the WLS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index Nos. 108, 431, 437, 444, and 878). The UFSAR Section 11.2.1.1 describes the WLS as having the safety-related functions of containment isolation and having back flow prevention check valves in the drain lines from the CVS compartment and the passive core cooling system compartments to the containment sump. SNC describes alternative ITAAC for the functional arrangement ITAAC (ITAAC Index Nos. 108, 431, 437, 444, and 878). These ITAAC ensure that the stated safety-related functions of the WLS are still addressed by other ITAAC. In addition, the NRC staff verified that the liquid effluent radiation monitors and isolation valve ITAAC (ITAAC Index No.

444) contains tests to verify that the monitors and isolation valve can to prevent releases to the environment. The radiation monitors and isolation valves serve to monitor andcontrol releases, as required by 10 CFR Part 50, Appendix A GDC 60 and 64. The staff verified that the applicable requirements discussed above are being met through the referenced ITAAC and that these ITAAC verify that the relevant components exist and are arranged to perform the intended function.

To address the remainder of the WLS functional arrangement not addressed by other ITAAC, the staff refers to the components of the WLS. Components not specifically tested would be the WLS degasifier column, effluent holdup tanks, waste holdup tanks, pre-filters, ion exchangers, after-filters, and monitoring tanks. These components are not safety significant, and the WLS limits releases processed by this system by providing the ability to detect and isolate releases to the environment as verified by ITAAC Index No. 444. In addition, ITAAC Index No. 437 verifies that the installed safety-significant equipment is subject to the seismic design requirements and is installed. 10 CFR 50.34a requires that an applicant describe the equipment and procedures for the control of gaseous and liquid effluents and for the maintenance and use of equipment installed in radioactive waste systems. The staffs assessment is that the descriptions of the WLS system are provided in UFSAR Tier 2 Sections 11.2 and 14.2.9.3.1. The most safety-significant features are tied directly to other regulatory requirements (e.g., GDC 60 and 64), and the staff determined that SNC has ITAAC to satisfy those requirements. In addition, SNC provides ITAAC to satisfy those features of the WLS which are safety-related.

Therefore, the staff finds the proposed removal of WLS functional arrangement ITAAC listed in Tier 1 Table 2.3.10.10-4 acceptable, because the functional arrangement of the relevant components is largely bounded by other ITAAC, and for those SSC where other ITAAC does not cover functional arrangement, the staff finds that those SSC are not safety significant and that the ITAAC being used to verify GDC 60 and 64, and 10 CFR 50.34a, verify that the liquid effluent discharges are monitored and will not be in excess of the limits.

3.1.12 Gaseous Radwaste System (WGS)

In LAR 19-002, SNC proposes to remove the WGS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.11-2, ITAAC Index No. 449 (ITAAC 2.3.11.01). SNCs justification is that the WGS functional arrangement design commitment is largely verified by other ITAAC and that non-safety significant components not verified by ITAAC are verified by the ITP.

The staff reviewed the information in LAR 19-002 and finds that the DC of the WGS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index Nos. 450, 454, and 455).

The WGS has no safety related functions discussed in the UFSAR Section 11.3.1.1. The licensee describes alternative ITAAC for the functional arrangement ITAAC (ITAAC Index Nos.

450, 454, and 455). ITAAC Index No. 450 verifies that listed equipment subject to seismic design requirements is installed. ITAAC Index No. 454 tests to confirm that a simulated high radiation signal from the discharge radiation monitors will cause the liquid effluent discharge valves to close, in accordance with 10 CFR Part 50, Appendix A GDC 60 and 64, as it relates to the requirements to control and monitor radioactive releases to the public. ITAAC Index No.

455 tests to confirm that simulated high oxygen levels will initiate nitrogen purge of the WGS, in accordance with 10 CFR Part 50, Appendix A GDC 3, as it relates to the design requirements of the WGS treatment systems to minimize the generation of explosive gas mixtures. The staff verified that the applicable requirements discussed above are being met through the referenced ITAAC and that these ITAAC verify that the relevant components exist and are arranged to perform the intended function.

To address the remainder of the WGS functional arrangement not addressed by other ITAAC the staff refers to the components of the WGS. Components not specifically tested would be the WGS gas cooler, moisture separators, and the guard beds. These components are not safety significant, and the WGS limits releases processed by this system by providing the ability to detect and isolate releases to the environment, as verified by ITAAC Index No. 454. In addition, ITAAC Index No. 450 verifies that the installed safety-significant equipment is subject to the seismic design requirements and is installed. 10 CFR 50.34a requires that an applicant describe the equipment and procedures for the control of gaseous and liquid effluents and for the maintenance and use of equipment installed in radioactive waste systems. The staffs assessment is that the descriptions of the WGS system are provided in UFSAR Tier 2 Sections 11.3 and 14.2.9.3.2. The most safety-significant features are tied directly to other regulatory requirements (e.g., GDC 3, 60, and 64), the staff determined that SNC has ITAAC to satisfy those requirements.

Therefore, the staff finds the proposed removal of WGS functional arrangement ITAAC listed in Tier 1 Table 2.3.11-2 acceptable, because the functional arrangement of the relevant components is largely bounded by other ITAAC. For those areas where other ITAAC does not cover functional arrangement, the staff finds that those parts are not safety significant and that the ITAAC being used to verify GDC 3, 60, and 64 verify that the gaseous effluent discharges are monitored and will not be in excess of the limits and verify WGS features to minimize the generation of explosive gas mixtures.

3.1.13 Solid Radwaste System (WSS)

In LAR 19-002, SNC proposes to remove the WSS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.12-2, ITAAC Index No. 456 (ITAAC 2.3.12.01). SNC states that the WSS functional arrangement design description is not verified by other ITAAC, but [t]he WSS has no safety-related or defense-in-depth functions. The WSS components are not required for any features or functions credited for mitigation of design basis events, nor are there any WSS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3. In addition, SNC states that there are ITP provisions to test the various components of the WSS.

In LAR 19-002 Section 2.13 the staff verified that SNC has appropriately justified the removal of the WSS functional arrangement ITAAC. The WSS has no safety-related functions discussed in UFSAR Section 11.4.1.1. Unlike the WLS and WGS, the WSS has no direct release pathway to the environment. As such there are no requirement to monitor and test isolation functions. The WSS functional arrangement ITAAC verifies that the Spent Resin Storage Tanks (SRST) A and B are installed in the Auxiliary Building. These tanks are used to store solid waste prior to shipment offsite. Since the functional arrangement ITAAC only appears to verify that the two spent resin storage tanks are installed, the staff agrees that no significant details are lost with the removal of this ITAAC, because ITAAC Index No. 457 verifies that each of the SRST exist and provide at least 250 ft3 of storage for radwaste materials to meet the requirements of 10 CFR Part 50, Appendix A GDC 61.

3.1.14 Primary Sampling System (PSS)

The LAR proposed removing the functional arrangement ITAAC for the PSS. This is COL Appendix C, Table 2.3.13-3, ITAAC Index No. 458 (ITAAC 2.3.13.01).

COL Appendix C, Section 2.3.13 contains the Design Description for the PSS. The PSS collects samples of fluids in the RCS and the containment atmosphere during normal operations. The PSS is shown in Figure 2.3.13-1. The PSS Grab Sampling Unit (PSS-MS-01) is in the Auxiliary Building.

The PSS has one safety-related function, which is containment isolation. That function is addressed by ITAAC 2.2.01.07.ii, which demonstrates the containment isolation valves (CIVs) in the PSS close within the required time. LAR-19-002 does not propose changes to ITAAC 2.2.01.07.ii.

The functional arrangement is made up of the following, from the description in Section 2.3.13:

o Tier 1 Figure 2.3.13-1, which shows the arrangement of sampling lines, return lines, PSS Grab Sampling Unit, eight CIVs, and two hot leg sample isolation valves o The function is to collect samples of fluids in the RCS and the containment atmosphere during normal operations o The PSS Grab Sampling Unit is in the Auxiliary Building LAR Enclosure 1, Section 2.14, Primary Sampling System (PSS), contains SNCs basis for proposing to remove the PSS functional arrangement ITAAC in COL Appendix C, Table 2.3.13-3, ITAAC No. 458 (ITAAC 2.3.13.01). The basis is that other ITAAC collectively provide the same verification. SNC does not request deleting the associated Tier 1 Section 2.3.13 design description or Figure 2.3.13-1, Primary Sampling System.

SNC listed the following ITAAC as collectively provide the same verification as the functional arrangement ITAAC No. 458 (ITAAC 2.3.13.01):

ITAAC Index No. 108 (2.2.01.07.ii) tests remotely operated CIVs to ensure they close within required response times.

ITAAC Index No. 459 (2.3.13.02), the portion of the ITAAC verifying Design Commitment 2, verifies that ASME Code Section III components in Table 2.3.13-1 are design and constructed to ASME Code requirements.

ITAAC Index No. 462 (2.2.13.05.i), the portion of the ITAAC verifying Design Commitment 5i, verifies that seismic Category I equipment in Table 2.3.13-1 is installed in the correct location (note: the location is the nuclear island).

ITAAC Index No. 467 (2.3.13.06b) verifies that when a simulated test signal is provided to each Class 1E Division, the signal exists at the Class 1E equipment in Table 2.3.13-1 for that division.

ITAAC Index No. 470 (2.3.13.08), the portion of the ITAAC verifying Design Commitment 8, verifies that samples of the reactor coolant and containment atmosphere can be obtained.

ITAAC Index No. 470 (2.3.13.08), the portion of the ITAAC verifying Design Commitments 9, 10a, 10b, and 11, ensure displays can be retrieved in the main control room (MCR),

performs stroke testing of the remotely operated valves using MCR controls and simulated signals into the Protection and Safety Monitoring System, and tests to ensure remotely operated valves assume proper position on loss of power.

ITAAC Index No. 470 (2.3.13.08), the portion of the ITAAC verifying Design Commitment 12, tests the components in Table 2.3.13-2 using controls in the MCR.

The staff evaluated the proposed change with respect to maintaining compliance with 10 CFR 52.97(b) regulations if the functional arrangement ITAAC is eliminated for the PSS.

The regulatory bases of the PSS design as described in the AP1000 design certification and the staffs corresponding Safety Evaluation Report (NUREG-1793, Final Safety Evaluation Report Related to Certification of the AP1000 Standard Design) are not affected because the LAR proposes no change to the system design. Similarly, the regulatory basis of the safety-related containment isolation function is not affected because the LAR proposes no change to the associated ITAAC 2.2.01.07.ii.

The LAR identified ITAAC 2.3.13.08 (Index No. 470), Design Commitment 8, as one of the ITAAC that would verify functional arrangement of the PSS. The staff determined that this ITAAC contributes to verifying functional arrangement by obtaining samples of the reactor coolant and the containment atmosphere. This requires flow through the sampling CIVs listed in the Tier 1 design description, to the PSS Grab Sampling Unit. The ability to collect the required samples will show that the system is arranged to perform the sampling function as described in the design.

The staff considered the other ITAAC identified in the LAR. Some of these do not demonstrate functional arrangement of the entire system, but they do contribute by demonstrating correct arrangement of elements essential to the function of the system. These include the Class 1E power divisions, communications with the MCR, and communications between components as follows. ITAAC Index No. 467 (ITAAC 2.2.13.06b) verifies correct delivery of Class 1E power in each division. The portion of ITAAC Index No. 470 (ITAAC 2.3.13.08) verifying Design commitments 9, 10a, 10b, and 12, verify communications and controls between the main control room (MCR), valves, and safety-related displays. The portion of ITAAC Index No. 470 (ITAAC 2.3.13.08) verifying Design commitment 11, verifies valve position upon loss of motive power.

The staff considered the other two ITAAC listed in the LAR for functional arrangement of the PSS and concluded they do not contribute significantly to demonstrating functional arrangement. ITAAC Index No. 459 (2.3.13.02), Design Commitment 2, documents that components are designed in accordance with ASME Code Section III requirements and not arrangement within the system. ITAAC Index No. 462 (2.2.13.05.i) verifies installation in the

correct location, but the location (nuclear island) is not specific enough to demonstrate functional arrangement.

The staff concludes that the combination of ITAAC Index No. 467 (ITAAC 2.2.13.06b) and ITAAC Index No. 470 (ITAAC 2.3.13.08, Design Commitments 8, 9, 10a, 10b, 11 and 12) demonstrates with reasonable assurance the functional arrangement of the PSS prior to initial fuel load. Therefore, the staff finds that 10 CFR 52.97(b), as it relates to ITAAC for the VEGP Units 3 and 4 PSS, is met without the functional arrangement ITAAC Index No. 458(ITAAC 2.3.13.01).

3.1.15 Demineralized Water Transfer and Storage System (DWS)

In LAR 19-002, SNC proposed to remove the DWS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.14-2, ITAAC Index No. 477 (ITAAC 2.3.14.01). SNCs justification is that DWS functional arrangement design commitment is largely verified by other ITAAC and that the DWS has only one safety-related function of containment isolation, which is verified via CNS system ITAAC. SNC also states that the other function of the DWS is to provide water from the CST to the FWS startup pumps and is verified via other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the DWS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index No. 479 (ITAAC 2.3.14.03);

ITAAC Index No. 480 (ITAAC 2.3.14.04); and ITAAC Index No. 107 (ITAAC 2.2.01.07.i) in Table 2.3.14-3. which demonstrate the required components exist and are arranged to perform the intended function. The staff confirmed that ITAAC Index No. 479 verifies the DWS provides water from the CST to the FWS startup pumps. SNC states that the remaining components not being covered by other ITAAC are not needed to meet the regulations and are otherwise not safety-related.

Therefore, the staff finds the proposed removal of DWS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is largely bounded by other ITAAC and those components not being covered by other ITAAC are not needed to meet the regulations and are otherwise not safety-related.

3.1.16 Compressed and Instrumentation Air System (CAS)

In LAR 19-002, SNC proposed to remove the CAS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.15-2, ITAAC Index No. 481 (ITAAC 2.3.15.01). SNCs justification is that CAS functional arrangement design commitment is partially verified by other ITAAC and that the functional arrangement of the remaining portions of the CAS do not need to be verified by ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the CAS functional arrangement ITAAC is partially verified by other ITAAC (ITAAC Index No. 483 (ITAAC 2.3.15.03), and ITAAC Index No. 108 (ITAAC 2.2.01.07.11)). The CAS components credited for containment isolation (a safety-related function), are verified via CNS system ITAAC. The remaining components of the CAS have no safety-related or defense-In-depth functions and are not required to meet NRC regulations, nor are there any CAS features or functions that have been identified for additional regulatory oversight per UFSAR Section 16.3. Therefore, the staff finds the proposed removal of functional arrangement ITAAC acceptable, because the functional arrangement of the safety-significant components is bounded by other ITAAC.

3.1.17 Radioactive Waste Drain System (WRS)

In LAR 19-002, SNC proposes to remove the WRS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.3.29-1, ITAAC Index No. 488 (ITAAC 2.3.29.01). SNCs justification is that the WRS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the WRS functional arrangement ITAAC is verified by other ITAAC (Index Nos. 444, 489, and 491). ITAAC Index No. 489 verifies that the WRS system in the auxiliary and annex buildings can transfer radioactive waste to the WLS. ITAAC Index No. 491 tests that the turbine building sump discharge will stop on a simulated high radiation signal. This prevents the spread of radioactive material outside of the turbine building. ITAAC Index No. 444 is a test to check the WLS containment sump levels and ensures that the safety related functions of the WLS are being tested. In review of the ITAAC information provided in UFSAR Tier 1 Section 2.3.29, the staff verified that the details of the functional arrangement ITAAC are encompassed by the ITAAC the licensee describes in LAR 19-002 by comparison to the functional arrangement figures and discussions provided in Tier 1 Section 2.3.29.

Therefore, the staff finds the proposed removal of WRS functional arrangement ITAAC acceptable, because the functional arrangement of the relevant components is bounded by other ITAAC.

3.1.18 Main and Startup Feedwater System (FWS)

In LAR 19-002, SNC proposes to remove the FWS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.4.1-2, ITAAC Index No. 492 (ITAAC 2.4.01.01). SNCs justification is that FWS functional arrangement DC is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 along with FWS design information in Section 10.4.7 and 10.4.9 of the UFSAR and finds that the DC of the FWS functional arrangement ITAAC is verified by other ITAAC (No. 493, ITAAC 2.4.01.02; and No. 219, ITAAC 2.2.04.01, associated with the Steam Generator System). Since the functional arrangement for FWS components including feedwater control and isolation valves, and feedwater pumps are verified in steam generator system ITAAC 2.2.04.01 and ITAAC 2.4.01.02, the staff finds the proposed removal of FWS functional arrangement ITAAC acceptable.

3.1.19 Main Turbine System (MTS)

In LAR 19-002, SNC proposes to remove the MTS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.4.2-1, ITAAC Index No. 496 (ITAAC 2.4.02.01). SNCs justification is that the MTS functional arrangement design commitment is largely verified by other ITAAC and is otherwise verified by the ITP.

The staff reviewed the information in LAR 19-002 and finds that the DC of the MTS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index No. 497 (ITAAC 2.4.02.02a) and ITAAC Index No. 498 (ITAAC 2.4.02.02b)). There are three components in

Gland Seal system that are not covered by above ITAAC. These components have no safety-related or defense-in-depth functions and these components are not required for any features or functions credited for mitigation of design basis events. ITAAC are not required for these components. The staff concludes that the combination of ITAAC Index No. 497 (ITAAC 2.4.02.02a parts 2.a, 2.c, and 3) and ITAAC Index No. 498 (ITAAC 2.4.02.02b) demonstrate with reasonable assurance the functional arrangement of the MTS prior to initial fuel load.

Therefore, the staff finds that 10 CFR 52.97(b), as it relates to ITAAC for the VEGP Units 3 and 4 MTS, is met without the functional arrangement ITAAC (Index No. 496, ITAAC 2.4.02.01).

Therefore, the staff finds the proposed removal of MTS functional arrangement ITAAC acceptable.

3.1.20 Condensate System (CDS)

In LAR 19-002, SNC proposes to remove the CDS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.4.6-2, ITAAC Index No. 503 (ITAAC 2.4.06.01). SNC states that the design commitment for the ITAAC is not demonstrated through the inspection, tests, and analysis (ITA) and AC of other ITAAC with the exception of ITAAC Index No. 504 (ITAAC 2.4.06.02) that performs an inspection of the Condenser Backpressures in the MCR as listed in Table 2.4.6-1. However, because the CDS has no safety-related or defense-in-depth functions it is appropriate to remove the functional arrangement ITAAC for the CDS. SNC also states that the CDS components are tested in the ITP which provides verification that the as-installed system properly functions.

The staff reviewed the information in LAR 19-002 along with CDS design information in Section 10.4.7 of the UFSAR and confirmed that the CDS is not important to safety or otherwise provide defense-in-depth functions. Further, the staff finds that the CDS is not required to meet the regulations and is not safety-significant. Therefore, the staff finds the proposed removal of CDS functional arrangement ITAAC acceptable.

3.1.21 In-Core Instrumentation System (IIS)

The IIS for the VEGP Units 3 and 4 is designed to provide safety-related core exit thermocouple signals to the protection and safety monitoring system. The IIS also provides non-safety-related core exit thermocouple signals to the diverse actuation system. The core exit thermocouples are housed in the core instrument assemblies.

In LAR 19-002, SNC proposes to remove ITAAC 2.5.05.01 (Index No. 564), in COL Appendix C, and plant-specific Tier 1. This ITAAC was included to verify the functional arrangement of the IIS as described in its design description. However, for safety-related in-core instruments, ITAAC 2.5.05.04 (Index No. 572) includes testing of the retrievability of their parameters in the main control room (MCR). Their displays can be retrieved in the MCR, including verification of the number of assemblies in each core quadrant. ITAAC 2.5.05.02.i (Index No. 565), Part 2 includes inspection of safety-related, as-built in-core thimble assembly location and verifies that associated anchorage is seismically bounded by the tested or analyzed conditions. Part 3.a of this ITAAC verifies safety-related, as-built wiring, cables, and terminations to ensure that they are bounded by equipment qualification type tests and/or analyses. ITAAC 2.5.05.03b (Index No. 570) is an inspection on the as-built cables between the in-core thermocouple elements and the connector boxes on the integrated head package to verify that they have sheaths.

For the non-safety-related in-core instruments, ITAAC 2.5.05.02.i (Index No. 565), Part 2 includes inspection of non-safety-related, as-built in-core thimble assembly location and verifies

that associated anchorage is seismically bounded by tested or analyzed conditions. ITAAC 2.5.05.03b (Index No. 570) requires inspection of the as-built cables between the in-core thermocouple elements and the connector boxes on the integrated head package to verify they have sheaths for the non-safety-related in-core instruments.

As stated above, meeting the requirements in ITAAC items 2.5.05.04, 2.5.05.02.i, and 2.5.05.03b, verifies that the Tier 1 components of the IIS are physically arranged to provide the service for which the system is intended. Therefore, the NRC staff finds that the DC and verification of the IIS functional arrangement are already covered by other ITAAC items as evaluated above and therefore, the proposed removal of ITAAC 2.5.05.01 is acceptable.

3.1.22 Special Monitoring System (SMS)

The SMS for the VEGP Units 3 and 4 is designed to monitor the reactor coolant system for the occurrence of impacts characteristic of metallic loose parts. Metal impact monitoring sensors are provided to monitor the RCS at the upper and lower head region of the reactor pressure vessel, and at the reactor coolant inlet region of each steam generator.

SNC proposes to remove ITAAC 2.5.06.01 (Index No. 573) for the SMS in COL Appendix C, and plant-specific Tier 1. This ITAAC verifies that the as-built SMS conforms to the functional arrangement as described in its design description. However, another ITAAC 2.5.06.02 (Index No. 574) is included to verify that data from the metal impact sensors can be retrieved in the MCR. Therefore, meeting ITAAC 2.5.06.02 shows that the SMS components physically arranged to provide the service for which the system is intended. Hence, the NRC staff finds that the DC for ITAAC 2.5.06.01 on the functional arrangement of the SMS is demonstrated through the ITA and acceptance criteria of ITAAC 2.5.06.02. Therefore, the NRC staff concludes that the proposed removal of ITAAC 2.5.06.01 for the functional arrangement of the SMS is acceptable.

3.1.23 Seismic Monitoring System (SJS)

The SJS for the VEGP Units 3 and 4 provides for the collection of seismic data in digital format, analysis of seismic data, notification of the operator if the ground motion exceeds a threshold value, and notification of the operator, after analysis of data, that a predetermined cumulative absolute velocity has been exceeded. The SJS has at least four triaxial acceleration sensor units, a time-history analyzer, and recording system. The time-history analyzer and recording system are in the auxiliary building.

SNC proposes to remove ITAAC Index No. 575 (ITAAC 2.5.09.01), in COL Appendix C (and plant-specific Tier 1). This ITAAC is included for the verification of the functional arrangement of the SJS as described in its design description. Other ITAAC, ITAAC Index No. 576 (ITAAC 2.5.09.02) and ITAAC Index No. 577 (ITAAC 2.5.09.02), verify the functions of the SJS system through tests. Although the functional arrangement ITAAC 2.5.09.01 is not completely bounded by these two other ITAAC items, the staff finds that those two ITAAC items are sufficient to satisfy 10 CFR 52.97(b) by verifying that the SJS system functions as intended. In addition, the SJS has no safety-related or defense-in-depth functions. The SJS components are not required for any features or functions credited for mitigation of design basis events, nor are there any SJS features or functions that have been identified as candidates for additional regulatory oversight. Therefore, the staff concludes that the proposed removal of ITAAC 2.5.09.01 for the functional arrangement of the SJS is acceptable.

3.1.24 Main ac Power System (ECS)

The ECS provides electrical ac power to nonsafety-related loads and non-Class 1E power to the Class 1E battery chargers and regulating transformers during normal and off-normal conditions. SNC proposes to remove ECS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.6.1-4, ITAAC Index No. 578 (ITAAC 2.6.01.01).

SNC stated in its LAR that the DC for this ITAAC is largely demonstrated through the ITA and AC of other ITAAC and provided a table with the other ITAAC that would apply for each equipment. SNC states that there are ECS components that are not verified by these other ITAAC, but SNC also states that the ECS safety-related and defense-in-depth functions do not rely on these components. [t]hese components are not required for any features or functions credited for mitigation of design basis events, nor are there any ECS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.

In addition, SNC states that these ECS components are tested in the [ITP] as described in UFSAR Subsection 14.2.9.2.15, which provides verification that the as-installed system properly functions.

The staff finds that the DC of ECS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index No. 66 (ITAAC 2.1.02.14), ITAAC Index No. 41 (ITAAC 2.1.02.09a),

ITAAC Index No. 281 (ITAAC 2.3.01.03.ii), ITAAC Index No. 206 (ITAAC 2.2.03.10), ITAAC Index No. 493 (ITAAC 2.4.01.02), ITAAC Index No. 497 (ITAAC 2.4.02.02a), ITAAC Index No.

587 (ITAAC 2.6.01.04d), ITAAC Index No. 588 (ITAAC 2.6.01.04e), ITAAC Index No. 603 (ITAAC 2.6.03.04c), ITAAC Index No. 613 (ITAAC 2.6.03.05d.i), ITAAC Index No. 138 (ITAAC 2.2.02.07b.i), ITAAC Index No. 703 (ITAAC 2.7.02.03a), ITAAC Index No. 701 (ITAAC 2.7.03.03), ITAAC Index No. 716 (ITAAC 2.7.04.03), ITAAC Index No. 719 (ITAAC 2.7.05.02.i),

ITAAC Index No. 726 (ITAAC 2.7.06.03i Item 4), ITAAC Index No. 579 (ITAAC 2.6.01.02i), and ITAAC Index No. 582 (ITAAC 2.6.01.03a)). A portion of the functional arrangement ITAAC is not bounded by the above ITAAC. ITAAC Index No. 588 (ITAAC 2.6.01.04e) verifies that the ECS provides the capability for distributing non-Class 1E ac power from onsite sources (ZOS) to non-safety-related loads, and demonstrates the system provides power to its respective loads. Thus, the staff finds that ITAAC Index No. 588 (ITAAC 2.6.01.04e) demonstrates that the ECS system functions as required and provides power to its loads, and that the components not covered by the above list of ITAAC are not needed to be covered by ITAAC since the system function is verified. Therefore, the NRC staff concludes that the proposed removal of ITAAC 2.6.01.01 for the functional arrangement of the ECS is acceptable.

3.1.25 Onsite Standby Power System (ZOS)

SNC proposes to remove the ZOS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.6.4-1, ITAAC Index No. 621 (ITAAC 2.6.04.01). The ZOS provides backup ac electrical power for non-safety loads during normal and off-normal conditions and is a system that is not safety-related. SNC states that the design commitment of this ITAAC is demonstrated through the ITA and Acceptance Criteria of ITAAC No. 622, except for verification that the centerline of the diesel engine exhaust gas discharge is located more than twenty (20) feet higher than that of the combustion air intake. Except as noted by SNC, the NRC staff confirmed that the design commitment of ITAAC Index No. 621 is verified by ITAAC Index No. 622, which confirms that the diesel generator functions as designed, including that it reaches and maintains design voltage and frequency. The functional testing ITAAC will demonstrate that the diesel generators run as required and perform their defense in depth

function and the staff finds that ITAAC No. 622 demonstrates the diesel generators ability to provide power to its loads. Since ITAAC Index No. 622 demonstrates the diesel generators ability to function, the ITAAC will demonstrate that the diesel generator has adequate intake air and therefore, adequate separation between the air intake and exhaust discharge. As a result, adequate separation between the combustion air intake and exhaust gas discharge is demonstrated via confirming the diesel generator functions as designed, and the staff finds that no ITAAC is needed to verify the centerline of the diesel engine exhaust gas discharge is located more than twenty (20) feet higher than that of the combustion air intake. Furthermore, the staff verified that the 20 feet delta between the exhaust discharge and the combustion intake is a design feature that is not affected by this change. Therefore, the staff concludes that removal of ZOS functional arrangement ITAAC is acceptable, since the functionality and design of the diesel generator and support systems are verified.

3.1.26 Nuclear Island Nonradioactive Ventilation System (VBS)

In LAR 19-002, SNC proposes to remove the VBS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.7.1-4, ITAAC Index No. 677 (ITAAC 2.7.01.01). SNCs justification is that the VBS functional arrangement design commitment is verified by other ITAAC except for the PCS valve room vent fan. SNC states that the VBS safety-related and defense-in-depth functions do not rely on this [vent fan] and that this component is not required for any features or functions credited for mitigation of design basis events, nor are there any VBS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3. Further, SNC states that this component is tested in the Initial Test Program (ITP) as described in UFSAR Subsection 14.2.9.2.10, which provides verification that the as-installed system properly functions.

The staff reviewed the information in LAR 19-002 and finds that, except as noted by SNC, the DC of the VBS functional arrangement ITAAC is verified by other ITAAC (ITAAC Index No. 700 (ITAAC 2.7.01.14); ITAAC Index No. 265 (ITAAC 2.2.05.07a.i); ITAAC Index No. 687 (ITAAC 2.7.01.06a); ITAAC Index No. 678 (ITAAC 2.7.01.02.a), and ITAAC Index No. 684 (ITAAC 2.7.01.05.i)). The staff agrees with SNC that the PCS valve room vent fan is not critical for functionality of the VBS and that ITAAC for it are not necessary. The staff concludes that the combination of all ITAAC discussed above demonstrate with reasonable assurance the functional arrangement of the VBS prior to initial fuel load. Therefore, the staff finds that 10 CFR 52.97(b), as it relates to ITAAC for the VEGP Units 3 and 4 VBS, is met without the functional arrangement ITAAC Index No. 677(ITAAC 2.7.01.01). Therefore, the staff finds the proposed removal of the VBS functional arrangement ITAAC acceptable.

3.1.27 Central Chilled Water System (VWS)

In LAR 19-002, SNC proposes to remove the VWS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.7.2-2, ITAAC Index No. 701 (ITAAC 2.7.02.01). The SNCs justification is that VWS functional arrangement design commitment is largely verified by other ITAAC. SNC also states that the VWS contains components that are outside the scope of other ITAAC: two water chillers and their associated pumps. The VWS safety-related and defense-in-depth functions do not rely on these components. These components are not required for any features or functions credited for mitigation of design basis events, nor are there any VWS features or functions that have been identified as candidates for additional regulatory oversight per UFSAR Section 16.3.

The staff reviewed the information in LAR 19-002 and finds that the DC of the VWS functional arrangement ITAAC is largely verified by other ITAAC (ITAAC Index No.703 (ITAAC 2.7.02.03a); and ITAAC Index No. 108 (ITAAC 2.2.01.07.ii)). Therefore, the staff finds the proposed removal of the VWS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is largely bounded by other ITAAC and those components not being covered by other ITAAC are not needed to meet the regulations and are otherwise not safety-related.

3.1.28 Annex / Auxiliary Buildings Nonradioactive Ventilation System (VXS)

In LAR 19-002, SNC proposes to remove the VXS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.7.3-2, ITAAC Index No. 707 (ITAAC 2.7.03.01). SNCs justification is that VXS functional arrangement design commitment is verified by other ITAAC, except for certain Tier 1 VXS components identified by SNC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the VXS functional arrangement ITAAC is largely verified by ITAAC Index No. 710 (ITAAC 2.7.03.03). The VXS does not have any safety-related functions but provides some defense-in-depth function to support the operation of the ZOS. The components tested under ITAAC Index No. 710 (ITAAC 2.7.03.03) provide necessary verification for the defense-in-depth function of the VXS. The staff concludes that ITAAC Index No. 710 (ITAAC 2.7.03.03) demonstrates with reasonable assurance the functional arrangement of the VXS prior to initial fuel load. Therefore, the staff finds that 10 CFR 52.97(b), as it relates to ITAAC for the VEGP Units 3 and 4 VXS, is met without the functional arrangement ITAAC (Index No. 707 (ITAAC 2.7.03.01)).Therefore, the staff finds the proposed removal of VXS functional arrangement ITAAC acceptable.

3.1.29 Diesel Generator Building Ventilation System (VZS)

In LAR 19-002, SNC proposes to remove the VZS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.7.4-2, ITAAC Index No. 712 (ITAAC 2.7.04.01). SNCs justification is that VZS functional arrangement ITAAC is largely verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the VZS functional arrangement ITAAC is largely verified by ITAAC Index No. 716 (ITAAC 2.7.04.03). The VZS does not have any safety-related functions but provides some defense-in-depth function to support the operation of the ZOS. The components tested under ITAAC Index No. 716 (ITAAC 2.7.04.03) provide necessary verification for the defense-in-depth function of the VZS. The staff concludes that ITAAC Index No. 716 (ITAAC 2.7.04.03) demonstrates with reasonable assurance the functional arrangement of the VZS prior to initial fuel load. Therefore, the staff finds that 10 CFR 52.97(b), as it relates to ITAAC for the VEGP Units 3 and 4 VZS, is met without the functional arrangement ITAAC (Index No. 712 (ITAAC 2.7.03.01)). Therefore, the staff finds the proposed removal of VZS functional arrangement ITAAC acceptable.

3.1.30 Radiologically Controlled Area Ventilation System (VAS)

In LAR 19-002, SNC proposes to remove the VAS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.7.5-2, ITAAC Index No. 718 (ITAAC 2.7.05.01). SNCs justification is that VAS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the VAS functional arrangement ITAAC is verified by other ITAAC (ITAAC Index No. 719 (ITAAC 2.7.05.02.i); and ITAAC Index No. 703 (ITAAC 2.7.02.03a)). Therefore, the staff finds the proposed removal of VAS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is covered by other ITAAC.

3.1.31 Containment Air Filtration System (VFS)

In LAR 19-002, SNC proposes to remove the VFS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.7.6-1, ITAAC Index No. 723 (ITAAC 2.7.06.01). SNCs justification is that VFS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the VFS functional arrangement ITAAC is verified by other ITAAC (ITAAC Index No.108 (ITAAC 2.2.01.07.ii);

ITAAC Index No.725 (ITAAC 2.7.06.02.ii); and ITAAC Index No.726 (ITAAC 2.7.06.03.i)).

Therefore, the staff finds the proposed removal of VFS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is covered by other ITAAC.

3.1.32 Containment Recirculation Cooling System (VCS)

SNC proposes to remove the VCS functional arrangement ITAAC provided in COL Appendix C, and plant-specific Tier 1, Table 2.7.7-2, ITAAC Index No. 731 (ITAAC 2.7.07.01). SNCs justification is that VCS functional arrangement design commitment is verified by other ITAAC.

The staff reviewed the information in LAR 19-002 and finds that the DC of the VCS functional arrangement ITAAC is verified by ITAAC Index No. 732 (ITAAC 2.7.07.02). Therefore, the staff finds the proposed removal of VCS functional arrangement ITAAC acceptable because the functional arrangement ITAAC proposed to be removed is covered by other ITAAC.

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

The Tier 1 information for which a plant-specific departure and exemption was requested is described above. The result of this exemption would be that SNC could implement modifications to Tier 1 information in the PS-DCD and associated COL Appendix C. Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design as certified in the 10 CFR Part 52, Appendix D, design certification rule is requested for the involved Tier 1 information described and justified in LAR 19-002. This exemption is a permanent exemption limited in scope to the Tier 1 information specified.

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

Pursuant to 10 CFR 52.7, the Commission may, upon application by any interested person or upon its own initiative, grant exemptions from the requirements of 10 CFR Part 52. As 10 CFR 52.7 further states, the Commissions consideration will be governed by 10 CFR 50.12, Specific exemptions, which states that an exemption may be granted when: (1) the exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security; and (2) special circumstances are present.

Specifically, 10 CFR 50.12(a)(2) lists six special circumstances for which an exemption may be considered. It is necessary for one of these special circumstances to be present for the NRC to consider granting an exemption request. SNC stated that the requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subparagraph defines special circumstances as when [a]pplication of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. The staffs analysis of each of these findings is presented below.

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

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

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

the exemption is authorized by law.

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

3.2.3 CONSISTENT WITH COMMON DEFENSE AND SECURITY The proposed exemption would allow changes as described above in the technical evaluation, thereby departing from the AP1000 certified (Tier 1) design information. The change does not alter or impede the design, function, or operation of any plant structures, systems, or components associated with the facilitys physical or cyber security and, therefore, does not affect any plant equipment that is necessary to maintain a safe and secure plant status. In

addition, the changes have no impact on plant security or safeguards. Therefore, as required by 10 CFR 50.12(a)(1), the staff finds that the common defense and security is not impacted by this exemption.

3.2.4 SPECIAL CIRCUMSTANCES Special circumstances, in accordance with 10 CFR 50.12(a)(2), are present, in part, whenever application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule. The underlying purpose of the Tier 1 ITAAC information is to meet 10 CFR 52.97(b) by providing reasonable assurance that the facility has been constructed and will be operated in accordance with the pertinent requirements in the license, AEA, and NRC rules and regulations. The proposed changes described in the above technical evaluation do not impact the ability of any SSCs to perform their functions or negatively impact safety.

Special circumstances are present in the circumstances discussed in LAR 19-002, because the application of the specified Tier 1 ITAAC information is not necessary to achieve the underlying purpose of the rule. As discussed above, the functional arrangement ITAAC SNC proposes to remove either are wholly bounded by other ITAAC or are partially bounded by other ITAAC with the remaining portions not needing to be included in ITAAC to satisfy 10 CFR 52.97(b). This exemption request and associated revisions to the Tier 1 information and corresponding changes to Appendix C demonstrate that the applicable regulatory requirements will continue to be met. Therefore, for the above reasons, the staff finds that the special circumstances required by 10 CFR 50.12(a)(2)(ii) for the granting of an exemption from the Tier 1 information exist.

3.2.5 SPECIAL CIRCUMSTANCES OUTWEIGH REDUCED STANDARDIZATION This exemption would allow the implementation of changes to Tier 1 information in the PS-DCD and corresponding changes to COL Appendix C that are being proposed in the LAR. The justification provided in LAR 19-002, the exemption request, and the associated licensing basis mark-ups demonstrate that there is a limited change from the standard information provided in the generic AP1000 DCD. The design functions of the system associated with this request will continue to be maintained because the associated revisions to the Tier 1 information do not change or otherwise affect the design function of the nuclear island (Nl), annex building, turbine building, and radwaste building. Consequently, the safety impact that may result from any reduction in standardization is minimized, because the proposed change does not result in a reduction in the level of safety. Based on the foregoing reasons, in accordance with 10 CFR Part 52.63(b)(1), the staff finds that the special circumstances outweigh any decrease in safety that may result from the reduction of standardization of the AP1000 design.

3.2.6 NO SIGNIFICANT REDUCTION IN SAFETY This exemption would allow the implementation of changes discussed above. The exemption request proposes to depart from the certified design by allowing changes discussed above in the technical evaluation. The changes will not impact the functional capabilities of this system.

The proposed changes will not adversely affect the ability of the Nl, annex building, turbine building, and radwaste building to perform its design functions, and the level of safety provided by the current systems and equipment therein is unchanged. Therefore, based on the foregoing

reasons and as required by 10 CFR Part 52, Appendix D, Section VIII.A.4, the staff finds that granting the exemption would not result in a significant decrease in the level of safety otherwise provided by the design.

3.3

SUMMARY

In LAR 19-002, SNC proposed to make changes that would affect the COL Appendix C and corresponding PS-DCD Tier 1 information. None of the above proposed changes represent any technical changes to the design, construction, or operation of the plant. No SSC, design function, or analysis, as described in the UFSAR, is affected. The staff finds that with the proposed changes, the ITAAC continue to be sufficient to verify that the facility has been constructed and will be operated in accordance with the license, the AEA, and NRC rules and regulations. Additionally, the staff finds that the retention of the ITAAC Number and ITAAC Index Number, as well as a reference to the applicable amendment number for each removed functional arrangement ITAAC, will ensure that the tracking and close-out of those ITAAC that are referenced in previous SNC and NRC documentation will be accomplished. Therefore, within the scope of this license amendment, the NRC finds that 10 CFR 52.97(b) is satisfied.

The NRC documented its review of the above changes in Section 3.1 of this safety evaluation and finds the changes acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations in 10 CFR 50.91(b)(2), on December 4, 2019, the Georgia State official was notified of the proposed issuance of the amendment. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, Standards for Protection Against Radiation. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding as published in the Federal Register on August 29, 2019 (84 FR 45537). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

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

6.0 CONCLUSION

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

The staff has concluded, based on the considerations discussed in Section 3.1 that there is reasonable assurance that: (1) the health and safety of the public will not be endangered by the proposed changes, (2) the changes are in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Therefore, the staff finds the changes proposed in this license amendment acceptable.

7.0 REFERENCES

1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment and Exemption: Functional Arrangement ITAAC Optimization (LAR 19-002), July 8, 2019 (ADAMS Accession No. ML19189A181, ML19189A182, ML19189A183, ML19189A184).

2. Vogtle Electric Generating Plant Units 3 and 4, Updated Final Safety Analysis Report, Revision 6 and Tier 1, Revision 5, June 15, 2017 (ADAMS Accession No. ML17172A218).

3. AP1000 Design Control Document, Revision 19, June 13, 2011 (ADAMS Accession No. ML11171A500).

4. Combined License NPF-91 for Vogtle Electric Generating Plant Unit 3, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A106).

5. Combined License NPF-92 for Vogtle Electric Generating Plant Unit 4, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A135).