ML20069A004

COL Docs - FW: Request for Psm on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue

ML20069A004
Person / Time
Site:	Vogtle
Issue date:	03/09/2020
From:	NRC
To:	NRC/NRR/DNRL
References
Download: ML20069A004 (21)

Text

From:

Rankin, Jennivine Sent:

Monday, March 9, 2020 6:52 AM To:

Vogtle PEmails

Subject:

FW: RE: Request for PSM on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue Attachments:

ITAAC 195 NMI LAR draft for discussion 2020319.pdf For discussion at 3/19 Vogtle 3 and 4 pre-submittal meeting.

From: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Sent: Wednesday, March 04, 2020 5:08 PM To: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>; Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Chamberlain, Amy Christine <ACCHAMBE@southernco.com>; Grant, Eddie

<X2EDGRAN@SOUTHERNCO.COM>; Petrak, Tom G. <TGPETRAK@southernco.com>; Roberts, Kelli Anne

<KROBERTS@southernco.com>; Agee, Stephanie Y. <SYAGEE@southernco.com>; Arafeh, Yasmeen N.

<YNARAFEH@southernco.com>; Kellenberger, Nicholas <X2NRKELL@SOUTHERNCO.COM>

Subject:

[External_Sender] RE: Request for PSM on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue Hi Jennie and Tanny - attached is the draft Non-Material Issue Regarding ITAAC 195 (Transportable Debris) LAR. This draft will be the focus of discussion with the Staff during the planned March 19, 2020 pre-submittal meeting. Thank you for the opportunity to engage the Staff in this discussion.

Respectfully, Mark P. Humphrey Licensing Supervisor Nuclear Development Southern Nuclear 3535 Colonnade Parkway Birmingham, AL 35243 O: 205.992.6452 C: 205.215.5152 mphumphr@southernco.com From: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

Sent: Wednesday, March 4, 2020 5:52 AM To: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>; Santos, Cayetano

<Cayetano.Santos@nrc.gov>

Subject:

RE: Request for PSM on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue EXTERNAL MAIL: Caution Opening Links or Files

Good morning Mark -

The staff is able to support a 3/19 PSM for this LAR. We are looking forward to receiving the draft tomorrow and the discussion.

Thanks, Jennie From: Humphrey, Mark Phillips <MPHUMPHR@southernco.com>

Sent: Monday, March 02, 2020 1:28 PM To: Santos, Cayetano <Cayetano.Santos@nrc.gov>

Cc: Rankin, Jennivine <Jennivine.Rankin@nrc.gov>

Subject:

[External_Sender] Request for PSM on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue Hi Tanny - I left a phone message on this topic and am following up by email in case you are travelling this week.

SNC is requesting a pre-submittal meeting on Thursday, March 19, 2020 to discuss a planned LAR to address a non-material change needed to ITAAC 195 (Transportable Debris). The proposed LAR would be the first using the streamlined format for LARs addressing non-material ITAAC issues, as discussed with the staff on February 13, 2020.

In support of the proposed PSM, SNC can provide a draft of the LAR enclosures on or before Thursday, March 5, 2020. We believe this PSM can effectively take place via teleconference but could support a face to face meeting if the staff prefers.

We look forward to your response.

Respectfully, Mark P. Humphrey Licensing Supervisor Nuclear Development Southern Nuclear 3535 Colonnade Parkway Birmingham, AL 35243 O: 205.992.6452 C: 205.215.5152 mphumphr@southernco.com

Hearing Identifier:

Vogtle_COL_Docs_Public Email Number:

543 Mail Envelope Properties (MN2PR09MB489174982151CCC8E2B73F1998FE0)

Subject:

FW: RE: Request for PSM on Thurs. March 19, 2020 - LAR to Address ITAAC 195 Non-Material Issue Sent Date:

3/9/2020 6:51:49 AM Received Date:

3/9/2020 6:51:53 AM From:

Rankin, Jennivine Created By:

Jennivine.Rankin@nrc.gov Recipients:

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

Tracking Status: None Post Office:

MN2PR09MB4891.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3437 3/9/2020 6:51:53 AM image001.gif 2058 ITAAC 195 NMI LAR draft for discussion 2020319.pdf 764625 Options Priority:

Normal Return Notification:

No Reply Requested:

No Sensitivity:

Normal Expiration Date:

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

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 March 27, 2020 Docket No.:

52-025 ND-20-####

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

Non-Material Issue Regarding ITAAC 195 - Transportable Debris (LAR-20-###)

Ladies and Gentlemen:

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

The requested amendment proposes to depart from plant-specific DCD Tier 1 Inspection, Test, Analysis, and Acceptance Criteria (ITAAC) information, and the corresponding COL Appendix C information, in a way that does not materially impact the completion of the ITAAC. provides the regulatory evaluation, technical evaluation, exemption evaluation, and environmental considerations for the proposed changes. provides the significant hazards consideration. provides a description of the requested changes and includes markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents.

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

As discussed during the pre-submittal meeting on March 19, 2020, SNC requests expedited NRC staff approval of the license amendment to support completion of the ITAAC and final construction of VEGP Unit 3. The basis for an expedited review is also provided in Enclosure 1.

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

DRAFT U.S. Nuclear Regulatory Commission ND-20-####

Page 2 of 4 Should you have any questions, please contact Mr. Mark Humphrey at (205) 992-6452.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 27th of March 2020.

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

1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Significant Hazards Consideration (LAR-20-###)

3) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to Licensing Basis Documents (LAR-20-###)

DRAFT Southern Nuclear Operating Company ND-20-####

Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment and Exemption:

Non-Material Issue Regarding ITAAC 195 - Transportable Debris (LAR-20-###)

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

DRAFT ND-20-####

Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

Page 3 of 9 AMENDMENT AND EXEMPTION REQUEST VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026 1.

INTRODUCTION Southern Nuclear Operating Company (SNC) requests that the U.S. Nuclear Regulatory Commission (NRC or the Commission) amend Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Combined License (COL) Numbers NPF-91 and NPF-92, respectively. In this License Amendment Request, SNC proposes to depart from plant-specific Tier 1 information, with corresponding changes to the associated COL Appendix C information.

The requested amendment proposes changes that would revise the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) for confirming the ventilation filters, fiber-producing fire barriers, tags, signs, caulking and coating density and material transport potential in Table 2.2.3-4 to allow completion of the ITAAC by review of the implementation process, or of the plant records, for these materials.

Pursuant to Section 52.63(b)(1) and 52.98(f) of Title 10 of the Code of Federal Regulations (10 CFR), SNC also requests an exemption in accordance with 10 CFR Part 52, Appendix D, Design Certification Rule for the AP1000 Design,Section VIII.A.4. This exemption request will allow a departure from the corresponding portions of the certified information in Tier 1 of the generic DCD.

This enclosure requests approval of the license amendment necessary to implement the changes identified and shown in Enclosure 3. The discussions of changes to the plant-specific Tier 1 information also impact the corresponding COL Appendix C information.

2.

REGULATORY EVALUATION As defined in Section II of Appendix D to 10 CFR Part 52, Tier 1 information includes inspections, tests and acceptance criteria (ITAAC) and design descriptions, among other things.

10 CFR Part 52, Appendix D,Section III.B requires a licensee referencing 10 CFR Part 52, Appendix D to incorporate by reference and comply with the requirements of Appendix D, including all Tier 1 information contained in the generic AP1000 DCD.

Therefore, a licensee referencing Appendix D incorporates by reference all Tier 1 information contained in the generic DCD. The Tier 1 ITAAC and the design descriptions, along with the plant-specific ITAAC, were included in Appendix C of the COL at its issuance.

10 CFR Part 52, Appendix D, Section Vlll.A.4 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 such a request if it finds that the design change will result in a significant decrease in the level of plant safety otherwise provided by the design.

10 CFR Part 52, Appendix D, Section Vlll.B.5.a allows an applicant or licensee who references 10 CFR Part 52, Appendix D to depart from Tier 2 information without prior NRC approval, unless the proposed departure involves a change to or departure from Tier 1 information, Tier 2*

information, the Technical Specifications, or requires a license amendment under 10 CFR Part 52,

DRAFT ND-20-####

Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

Page 4 of 9 Appendix D,Section VIII, paragraphs B.5.b or B.5.c. The proposed amendment involves a departure from the plant-specific Tier 1 ITAAC information, but no changes are needed to UFSAR Subsection 6.3.2.2.7.1 where this topic is addressed. Thus, NRC approval is not required under this regulation.

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, the Commission must consider whether special circumstances, as required by 10 CFR 52. 7 and 50.12, 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 a proposed amendment to the COL for any modification to, addition to, or deletion from the terms and conditions of a COL. The proposed amendment involves changes to plant-specific Tier 1 ITAAC information and its corresponding COL Appendix C information, so NRC approval is required.

The specific NRC technical requirements applicable to the proposed amendment are the general design criteria (GDC) in Appendix A, "General Design Criteria for Nuclear Power Plants," to 10 CFR Part 50, "Domestic Licensing of Production and Utilization Facilities." In particular, these technical requirements include the following GDC:

GDC 35, "Emergency core cooling," requires that a system to provide abundant emergency core cooling be provided. The system safety function shall be to transfer heat from the reactor core following any loss of reactor coolant at a rate such that ( 1) fuel and clad damage that could interfere with continued effective core cooling is prevented, and (2) clad metal-water reaction is limited to negligible amounts.

GDC 37, "Testing of emergency core cooling system," requires that the emergency core cooling system be designed to permit appropriate periodic pressure and functional testing to assure (1) the structural and leaktight integrity of its components, (2) the operability and performance of the active components of the system, and (3) the operability of the system as a whole and, under conditions as close to design as practical, the performance of the full operational sequence that brings the system into operation, including operation of applicable portions of the protection system, the transfer between normal and emergency power sources, and the operation of the associated cooling water system.

3.

TECHNICAL JUSTIFICATION

3.1 TECHNICAL EVALUATION

OF DEPARTURE The Design Commitment for ITAAC 2.2.3.8.c (also referred to as ITAAC No. 195) states The PXS [Passive Core Cooling System] provides RCS [Reactor Coolant System] makeup, boration, and safety injection during design basis events. The inspection identified to support confirmation of the PXS capability includes three parts identified as:

x Inspections will be conducted of the as-built safety-related coatings or of plant records of the nonsafety-related coatings used inside containment on walls, floors, ceilings, and structural steel except in the CVS [Chemical and Volume Control System] room.

DRAFT ND-20-####

Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

Page 5 of 9 Inspections will be conducted of the as-built non-safety-related coatings or of plant records of the non-safety-related coatings used on components below the maximum flood level of a design basis LOCA [Loss of Coolant Accident] or located above the maximum flood level and not inside cabinets or enclosures.

x Inspections will be conducted on caulking, tags, and signs used inside containment below the maximum flood level of a design basis LOCA or located above the maximum flood level and not inside cabinets or enclosures.

x Inspections will be conducted of ventilation filters and fiber-producing fire barriers used inside containment within the ZOI [Zone of Influence] or below the maximum flood level of a design basis LOCA.

These visual inspections are required to confirm that the materials used will not be transported during an event to the in-containment refueling water storage tank (IRWST) screens and the containment recirculation screens and thus, become debris that might restrict flow through the screens.

However, material density is but one of numerous criteria that must be met as identified in UFSAR Subsection 6.3.2.2.7.1 for potential sources of materials that may become transported debris with potential to block these screens. The appropriate material density and transport potential is incorporated into the design and construction specifications and then are verified to be installed in accordance with a verified process by review of the plant records.

It is thus proposed that it is reasonable to expect that the materials would be installed and confirmed via the inspection program by review of the processes or plant records, as documented in the associated construction work packages. Such inspections of the processes and plant records are a fundamental concept of quality assurance routinely applied in commercial nuclear power plant construction and operation, and thus, are also appropriate for confirmation of this inspection and associated acceptance criteria.

In order to accomplish these proposed changes, references to the coatings, caulking, tags, signs, ventilation filters, and fiber-producing fire barriers are modified to require inspection of the implementation process, or the plant records of the coatings, caulking, tags, signs, ventilation filters, and fiber-producing fire barriers. Additionally, references to the as-built materials and the materials used are revised to avoid any confusion with installed materials in order to allow for the materials to be installed following completion of the ITAAC.

Therefore, the intent of the Acceptance Criteria continues to be met and there is no impact to the design or operation of the plant.

3.2 EVALUATION OF EXEMPTION 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 Commission's 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 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 in order for the NRC to consider granting an exemption request. SNC has determined that the requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subsection defines special circumstances as when "[a]pplication of the regulation in the

DRAFT ND-20-####

Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

Page 6 of 9 particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule." The staff's analysis of each of these findings is presented below.

3.2.1 AUTHORIZED BY LAW This exemption would allow SNC to implement approved revisions to Tier 1 information and corresponding information in COL Appendix C in the plant-specific DCD. This exemption is a permanent exemption limited in scope to particular Tier 1 information. Subsequent changes to this particular Tier 1, or any other Tier 1 information, would be subject to the exemption process specified in Section Vlll.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 Vlll.A.4 allows the NRC to grant exemptions from one or more elements of the Tier 1 information. Based on 10 CFR Part 52, Appendix D, Section Vlll.A.4, SNC has determined that granting of the proposed exemption will not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's 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 HEATH AND SAFETY The underlying purpose of Appendix D to 10 CFR Part 52 is to ensure that SNC will construct and operate the plant based on the approved information found in the DCD incorporated by reference into the licensee's licensing basis. The proposed changes would revise Tier 1 information as presented in the ITAAC table. These changes will enable the licensee to safely construct and operate the facility consistent with the performance of the as-built components for the AP1000 design certified by the NRC by revising the information mentioned above found in Tier 1 of the DCD. These changes will not impact the ability of the systems or equipment to perform their design function. These changes do not add any new equipment or system interfaces to the current plant design. The proposed changes do not introduce any new industrial, chemical, or radiological hazards that would represent a public health or safety risk, nor do they modify or remove any design or operational controls or safeguards intended to mitigate any existing on-site hazards. Furthermore, the proposed 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, as required by 10 CFR 50.12(a)(1), SNC had determined that there is no undue risk to public health and safety.

3.2.3 CONSISTENT WITH COMMON DEFENSE AND SECURITY The proposed exemption would allow changes to elements of the plant-specific Tier 1 DCD.

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

Subsequent changes to Tier 1 information would be subject to full compliance by the licensee as specified in Section Vlll.A.4 of Appendix D to 10 CFR Part 52. The proposed changes would revise Tier 1 information as presented in the ITAAC table. These changes will enable the licensee to safely construct and operate the facility consistent with the performance of the as-built components for the AP1000 design certified by the NRC by revising the information mentioned above found in Tier 1 of the DCD. The changes do not alter or impede the design, function, or operation of any plant structures, systems, and components (SSCs) associated with the facility's physical or cyber security and, therefore, do not affect any plant equipment that is necessary to maintain a safe and secure plant status. In addition, the change has no

DRAFT ND-20-####

Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

Page 7 of 9 impact on plant security or safeguards. Therefore, as required by 10 CFR 50.12(a)(1), SNC has determined 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)(ii), are present 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 purposes of Section III.B of Appendix D to 10 CFR Part 52 is to ensure that the licensee will construct and operate the plant based on the approved information found in the AP1000 DCD, which was incorporated by reference into the licensee's licensing basis. The proposed changes to Tier 1 will enable the licensee to safely construct and operate the AP1000 facility consistent with established acceptance criteria used in the design certified by the NRC.

Special circumstances are present in the particular circumstances discussed in this license amendment request because the application of Section III.B of Appendix D to 10 CFR Part 52 in this circumstance does not serve the underlying purpose of the rule. The proposed change implements changes to Tier 1 information. This exemption request and associated revisions to Tier 1 information demonstrate that the applicable regulatory requirements will continue to be met. Consequently, the safety impact that may result from any reduction in standardization is minimized because the proposed design change does not result in a reduction in the level of safety. Therefore, SNC has determined that the special circumstances required by 10 CFR 50.12(a)(2)(ii) for the granting of an exemption from Section III.B of Appendix D to 10 CFR Part 52 exist.

3.2.5 SPECIAL CIRCUMSTANCES OUTWEIGH REDUCED STANDARDIZATION This exemption would allow the implementation of changes to Tier 1 information as proposed in the license amendment request. The proposed changes would revise Tier 1 ITAAC information. These changes will enable the licensee to safely construct and operate the facility consistent with the performance of the as-built components for the AP1000 design certified by the NRC by updating the information mentioned above found in Tier 1 of the DCD. The design functions of the systems associated with this request are consistent with the current design of the plant in supporting the actual system functions. The design functions of these systems will continue to be maintained because the associated revisions to the Tier 1 information demonstrate that the applicable regulatory requirement will continue to be met.

Consequently, the safety impact that may result from any reduction in standardization is minimized, because the proposed design change does not result in a reduction in the level of safety. Based on the foregoing reasons, as required by 10 CFR Part 52.63(b)(1), SNC has determined that the special circumstances outweigh the effects the departure has on the standardization of the AP1000 design.

3.2.6 NO SIGNIFICANT REDUCTION IN SAFETY This exemption would allow the implementation of changes to Tier 1 information as proposed in the license amendment request. The changes will not significantly impact the functional capabilities of the SSCs. The proposed changes will not adversely affect the ability of the SSCs to perform their 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 Vlll.A.4, SNC has determined that granting

DRAFT ND-20-####

Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

Page 8 of 9 the exemption would not result in a significant decrease in the level of safety otherwise provided by the design.

4.

STATE CONSULTATION In accordance with the Commissions regulations in 10 CFR 50.91(b)(2), the Georgia State official was notified of the proposed amendment.

5.

ENVIRONMENTAL CONSIDERATIONS 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. 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. Enclosure 2 provides a finding that the amendment involves no significant hazards consideration. 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 does not authorize any activities other than those proposed in the license amendment, the exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), as discussed in the above paragraph. Therefore, pursuant to 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the exemption.

6.

CONCLUSION SNC has determined that pursuant to Section Vlll.A.4 of Appendix D to 10 CFR Part 52, the requested 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, (5) the special circumstances outweigh the potential decrease in safety due to reduced standardization, and (5) does not reduce the level of safety at the licensee's facility.

Therefore, SNC requests the staff grant the proposed exemption from Tier 1 information.

SNC has concluded, based on the considerations discussed in Section 3.1, Technical Evaluation of the Departure, that there is reasonable assurance that: (1) the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's 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, SNC requests the NRC Staff to find the changes proposed in this license amendment to be acceptable.

7.

REFERENCES 7.1 Combined License NPF-91 for Vogtle Electric Generating Plant Unit 3, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A106).

DRAFT ND-20-####

Request for License Amendment and Exemption: Non-Material Issue Regarding ITAAC 195 -

Transportable Debris (LAR-20-###)

Page 9 of 9 7.2 Combined License NPF-92 for Vogtle Electric Generating Plant Unit 4, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A135).

7.3 VEGP Units 3 and 4 Updated Final Safety Analysis Report (UFSAR), Revision 8, and Plant-Specific Tier 1, Revision 7, dated June 14, 2019 (ADAMS Accession No. ML19171A093).

7.4 AP1000 Design Control Document, Revision 19, dated June 13, 2012 (ADAMS Accession No. ML11171A500).

7.5 U.S. Nuclear Regulatory Commission, "Final Safety Evaluation Report Related to the Combined Licenses for Vogtle Electric Generating Plant, Units 3 and 4," Volume 1, NUREG-2124, dated September 30, 2012 (ADAMS Accession No. ML12271A045).

7.6 Final Safety Evaluation Report Related to Certification of the AP1000 Standard Plant Design, NUREG-1793, Supplement 2, dated August 5, 2011 (ADAMS Accession No. ML112061231).

8.

BASIS FOR EXPEDITED REVIEW SNC requests an expedited review of this non-material issue by May 27, 2020, in order to allow SNC to proceed with construction and completion of the identified Inspection, Test, Analysis and Acceptance Criteria (ITAAC). Delay review of this LAR will result in delay in the completion of the VEGP units as discussed below.

These inspections have high potential to become or to affect the critical path related activities leading to fuel load for Vogtle Unit 3, and similarly in 2021, for Vogtle Unit 4. Many of the Vogtle Unit 3 as-built inspections are already complete and verified, but some are scheduled for late in the construction schedule, and a few could potentially even be safely completed after construction but prior to the need for OPERABILITY of the Passive Core Cooling System (PXS). Allowing the verification to be done based on the implementation process and plant records has potential for significant savings of available manpower during the final, ITAAC intensive days of the Vogtle construction schedule.

Such considerations and the potential savings of applied manpower have only recently been recognized. Otherwise, SNC could have requested this change earlier.

Therefore, SNC requests expedited NRC staff approval of the license amendment to support completion of the ITAAC and final construction of VEGP Unit 3. Delayed approval of this license amendment could result in a delay in completion of the associated ITAAC and subsequent construction completion activities. SNC similarly expects to expedite implementation of this proposed amendment within a few days of approval of the requested changes.

Additionally, while the schedule information is applicable only for VEGP Unit 3, the requested change is applicable to both units and is also requested for VEGP Unit 4 concurrent with the Unit 3 change.

DRAFT Southern Nuclear Operating Company ND-20-####

Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Significant Hazards Consideration (LAR-20-###)

(This Enclosure consists of 3 pages, including this cover page)

DRAFT ND-20-#### - Significant Hazards Consideration (LAR-20-###)

Page 2 of 3 SIGNIFICANT HAZARDS CONSIDERATION Southern Nuclear Operating Company (SNC) is requesting issuance of an amendment to facility Operating License Nos. NPF-91 and NPF-92, issued to SNC for operation of the VEGP Units 3 and 4, located in Burke County, Georgia.

The proposed changes would revise the VEGP Units 3 and 4 combined license (COL) Appendix C (and corresponding plant-specific DCD Tier 1) information. Specifically, the request proposes to revise the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) 2.2.03.08x specified in COL Appendix C, for confirming the ventilation filters, fiber-producing fire barriers, tags, signs, caulking and coating density and material transport potential in Table 2.2.3-4 to allow completion of the ITAAC by review of the implementation process, or of the plant records, for these materials.

Because this proposed change requires a departure from Tier 1 information in the Westinghouse AP1000 DCD, SNC also requested an exemption from the requirements of the Generic DCD Tier 1 in accordance with section 52.63(b)(1) of title 10 of the Code of Federal Regulations (10 CFR).

As required by 10 CFR 50.91(a), SNC provides the following analysis of the issue of no significant hazards consideration, which is presented below:

1.

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

Response:No.

The proposed revisions have been found to continue to provide the required functional capability of the safety systems for previously evaluated accidents and anticipated operational occurrences. The affected system is not an initiator of any accident analyzed in the Updated Final Safety Analysis Report (UFSAR), nor do the changes involve an interface with any structure, system or component (SSC) accident initiator or initiating sequence of events, and thus, the probabilities of the accidents evaluated in the UFSAR are not affected. The proposed changes do not involve a change to any mitigation sequence or the predicted radiological releases due to postulated accident conditions, thus, the consequences of the accidents evaluated in the UFSAR are not affected.

The UFSAR describes the analyses of various design basis transients and accidents to demonstrate compliance of the design with the acceptance criteria for these events. The acceptance criteria for the various events are based on meeting the relevant regulations, general design criteria, and the Standard Review Plan, and are a function of the anticipated frequency of occurrence of the event and potential radiological consequences to the public.

The revised ITAAC maintains the plant conditions, and thus maintains the frequency designation and consequence level as previously evaluated.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2.

Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response:No.

The proposed revisions have been found to continue to confirm the required functional capability of the safety systems for previously evaluated accidents and anticipated operational occurrences. The proposed revisions do not change the function of the related systems, and

DRAFT ND-20-#### - Significant Hazards Consideration (LAR-20-###)

Page 3 of 3 thus, the changes do not introduce a new failure mode, malfunction or sequence of events that could adversely affect safety or safety-related equipment.

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

3.

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

Response:No.

The proposed revisions have been found to continue to provide the required functional capability of the safety systems for previously evaluated accidents and anticipated operational occurrences. The proposed revisions do not change the function of the related systems nor significantly affect the margins provided by the systems. No safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the requested changes.

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

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

DRAFT Southern Nuclear Operating Company ND-20-####

Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Changes to Licensing Basis Documents (LAR-20-###)

Additions identified by blue underlined text.

Deletions Identified by red strikethrough of text.

• *

• indicates omitted existing text that is not shown.

(This Enclosure consists of 4 pages, including this cover page)

DRAFT ND-20-####

Proposed Changes to Licensing Basis Documents - (LAR-20-###)

Page 2 of 4 LICENSING BASIS CHANGE DESCRIPTIONS COL Appendix C Table 2.2.3-4:

x Revise ITAAC No. 195 to revise inspections to allow completion of the ITAAC by review of the implementation process, or of the plant records, for ventilation filters, fiber-producing fire barriers, tags, signs, caulking and coatings. Terminology is revised to preclude intimations of installed or as-built inspections are required.

Plant-specific Tier 1 Table 2.2.3-4:

x Revise ITAAC No. 8.c)x) to revise inspections to allow completion of the ITAAC by review of the implementation process, or of the plant records, for ventilation filters, fiber-producing fire barriers, tags, signs, caulking and coatings. Terminology is revised to preclude intimations of installed or as-built inspections are required.

Markups of the licensing basis documents are provided on the following pages.

DRAFT ND-20-####

Proposed Changes to Licensing Basis Documents - (LAR-20-###)

Page 3 of 4 COL Appendix C Table 2.2.3-4 is revised as follows:

Table 2.2.3-4 Inspections, Tests, Analyses, and Acceptance Criteria No.

ITAAC No.

Design Commitment Inspections, Tests, Analyses Acceptance Criteria 195 2.2.03.08c.x 8.c) The PXS provides RCS makeup, boration, and safety injection during design basis events.

x) Inspections will be conducted of the implementation process, the as-built nonsafety-related coatings or of plant records, of the nonsafety-related coatings used for use inside containment on walls, floors, ceilings, and structural steel except in the CVS room. Inspections will be conducted of the implementation process, the as-built non-safety-related coatings or of plant records, of the non-safety-related coatings used for use on components below the maximum flood level of a design basis LOCA or located above the maximum flood level and not inside cabinets or enclosures.

Inspections will be conducted on the implementation process, or of plant records, of the caulking, tags, and signs used for use inside containment below the maximum flood level of a design basis LOCA or located above the maximum flood level and not inside cabinets or enclosures.

Inspections will be conducted of the implementation process, or of plant records, of the ventilation filters and fiber-producing fire barriers used for use inside containment within the ZOI or below the maximum flood level of a design basis LOCA.

x) A report exists and concludes that the coatings used on for these surfaces have a dry film density of 100 lb/ft3. If a coating is used that has a lower dry film density, a report must exist and conclude that the coating will not transport. A report exists and concludes that inorganic zinc coatings used on for these surfaces are Safety Service Level I or have been quantified and justified in a program for management of unqualified coatings to demonstrate the unqualified coatings are acceptable for use.

A report exists and concludes that tags and signs used on for these locations are made of steel or another metal with a density 100 lb/ft3. In addition, a report exists and concludes that caulking used on for these locations or coatings used on for these signs or tags have a dry film density of 100 lb/ft3. If the caulking, tags or signs are made of a material is used that has a lower density, a report must exist and conclude that there is insufficient water flow to transport lightweight caulking, signs, or tags.

A report exists and concludes that the ventilation filters and fire barriers in for these locations have a density of 100 lb/ft3.

DRAFT ND-20-####

Proposed Changes to Licensing Basis Documents - (LAR-20-###)

Page 4 of 4 Plant-Specific Tier 1 Table 2.2.3-4 is revised as follows:

Table 2.2.3-4 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria 8.c) The PXS provides RCS makeup, boration, and safety injection during design basis events.

x) Inspections will be conducted of the implementation process, the as-built nonsafety-related coatings or of plant records, of the nonsafety-related coatings used for use inside containment on walls, floors, ceilings, and structural steel except in the CVS room. Inspections will be conducted of the implementation process, the as-built non-safety-related coatings or of plant records, of the non-safety-related coatings used for use on components below the maximum flood level of a design basis LOCA or located above the maximum flood level and not inside cabinets or enclosures.

Inspections will be conducted on the implementation process, or of plant records, of the caulking, tags, and signs used for use inside containment below the maximum flood level of a design basis LOCA or located above the maximum flood level and not inside cabinets or enclosures.

Inspections will be conducted of the implementation process, or of plant records, of the ventilation filters and fiber-producing fire barriers used for use inside containment within the ZOI or below the maximum flood level of a design basis LOCA.

x) A report exists and concludes that the coatings used on for these surfaces have a dry film density of 100 lb/ft3. If a coating is used that has a lower dry film density, a report must exist and conclude that the coating will not transport. A report exists and concludes that inorganic zinc coatings used on for these surfaces are Safety Service Level I or have been quantified and justified in a program for management of unqualified coatings to demonstrate the unqualified coatings are acceptable for use.

A report exists and concludes that tags and signs used on for these locations are made of steel or another metal with a density 100 lb/ft3. In addition, a report exists and concludes that caulking used on for these locations or coatings used on for these signs or tags have a dry film density of 100 lb/ft3. If the caulking, tags or signs are made of a material is used that has a lower density, a report must exist and conclude that there is insufficient water flow to transport lightweight caulking, signs, or tags.

A report exists and concludes that the ventilation filters and fire barriers in for these locations have a density of 100 lb/ft3.