ND-20-0900, Supplement to Request for License Amendment: Core Makeup Tank Boron Concentration Requirements (LAR-20-004S1)

Supplement to Request for License Amendment: Core Makeup Tank Boron Concentration Requirements (LAR-20-004S1)

ML20205L560
Person / Time
Site:	Vogtle
Issue date:	07/23/2020
From:	Chamberlain A Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
ND-20-0900
Download: ML20205L560 (8)

Text

.6. Southern .Nuclear Southern Nuclear Operating Company, Inc.

3535 Colonnade Parkway Birmingham, AL 35243 July 23, 2020 Docket Nos.: 52-025 ND-20-0900 52-026 10 CFR 50.90 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 Supplement to Request for License Amendment:

Core Makeup Tank Boron Concentration Requirements (LAR-20-004S1)

Ladies and Gentlemen:

On April 30, 2020, pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requested 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) [ADAMS Accession Number ML20121A288]. The requested amendment proposes to depart from Tier 2 information in the Updated Final Safety Analysis Report (UFSAR)

(which includes the plant-specific DCD Tier 2 information) and involves changes to the plant-specific Technical Specifications (COL Appendix A).

The requested license amendment (LAR-20-004) proposes changes to the upper limit of the Core Makeup Tank (CMT) boron concentration Technical Specification (TS) Surveillance Requirement (SR), the mass of trisodium phosphate (TSP) required by TS Limiting Condition for Operation (LCO) and associated SR, and the frequency of performance of the CMT boron concentration TS SR.

That submittal built upon discussions held with the NRC staff on December 19, 2019 (ADAMS Accession Number ML19347A394) and April 23, 2020 (ADAMS Accession Number ML20115E345).

During the NRCs audit (ML20133K106) of the technical information supporting LAR-20-004, the need for clarifications was identified for the submittal based on the procedural information which supports the request. The monitoring and trending of the CMT temperature and response to unexpected temperature changes is described and clarified in the technical evaluation and licensing basis markups provided in this supplement.

This supplement does not impact the scope or conclusions of the Technical Evaluation, Significant Hazards Consideration Determination, or Environmental Considerations of the original submittal.

Enclosures 1 through 3 were provided with the original submittal.

U.S. Nuclear Regulatory Commission ND-20-0900 Page 2 of 4 provides a revision to the relevant section of the technical evaluation in Enclosure 1.

Portions of Enclosure 1 not addressed in Enclosure 4 are unaffected by this supplement. provides additional licensing basis markups supplementing those previously provided in Enclosure 2.

This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information. This letter does not impact the requested approval date or implementation period identified in the original submittal.

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

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

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 23rd of July 2020.

Respectfully submitted,

~.~

Manager, Nuclear Development Regulatory Affairs Southern Nuclear Operating Company

Enclosures:

1) through 3) provided in original submittal of LAR-20-004 dated April 30, 2020 [ML20121A288]

4) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Request for License Amendment: Core Makeup Tank Boron Concentration Requirements (LAR-20-004S 1)

5) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Proposed Changes to Licensing Basis Documents (LAR-20-004S 1)

U.S. Nuclear Regulatory Commission ND-20-0900 Page 3 of 4 cc:

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

Mr. P. P. Sena III (w/o enclosures)

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

Mr. G. Chick Mr. S. Stimac Mr. P. Martino Mr. D. L. McKinney (w/o enclosures)

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

Mr. B. H. Whitley Ms. C. A. Gayheart Ms. M. Ronnlund Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Ms. S. Agee Mr. M. Humphrey Ms. A. C. Chamberlain Mr. S. Leighty Mr. N. Kellenberger Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. D. T. Blythe Mr. K. Warren Mr. A. S. Parton Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

Mr. M. King (w/o enclosures)

Ms. M. Bailey w/o enclosures)

Mr. C. Patel Mr. C. Santos Mr. B. Kemker Mr. J. Eargle Mr. G. Khouri Ms. S. Temple Mr. C. J. Even Mr. A. Lerch Mr. S. Walker Mr. N.D. Karlovich Ms. N. C. Coovert Mr. C. Welch Mr. J. Gaslevic

U.S. Nuclear Regulatory Commission ND-20-0900 Page 4 of 4 Nuclear Regulatory Commission (Continued)

Mr. V. Hall Ms. K. P. Carrington Mr. M. Webb Mr. P.J. Heher State of Georgia Mr. R. Dunn Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. T. Rubenstein (w/o enclosures)

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

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

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham

Southern Nuclear Operating Company ND-20-0900 Enclosure 4 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Request for License Amendment:

Core Makeup Tank Boron Concentration Requirements (LAR-20-004S1)

(This Enclosure consists of 2 pages, including this cover page)

ND-20-0900 Supplement to Request for License Amendment: Core Makeup Tank Boron Concentration Requirements (LAR-20-004S1)

During the NRCs audit (ML20133K106) of the technical information supporting LAR-20-004, the need for clarifications was identified for the submittal based on the procedural information which supports the request. The monitoring and trending of the CMT temperature and response to unexpected temperature changes is described and clarified in the technical evaluation and licensing basis markups provided in this supplement. This supplement does not impact the scope or conclusions of the Technical Evaluation, Significant Hazards Consideration Determination, or Environmental Considerations of the original submittal.

Page 9 of 17 of ND-20-0507 Enclosure 1 states, Therefore, the CMT top high temperature alarm can indicate to the operators that there may be in-leakage and to initiate by procedure steps to identify if the CMT boron concentration remains within the required limits. In addition to responses to a high temperature alarm, it is also consistent with site procedures to monitor and trend the CMT top temperature and respond to an abnormal temperature rise before reaching the alarm setpoint. Data is recorded at least daily for SR 3.5.2.1 to confirm that safety analysis initial assumptions are met regarding CMT temperature. This data can also be used to determine whether Reactor Coolant System (RCS) water is entering a CMT. The capability is also provided to monitor and trend this data in real time using the plant computer.

Consistent with the results of the analysis of a temperature rise in the CMT, increases in CMT temperature of 5 to 10°F within 24 to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> are consistent with a potential leak and are investigated to determine the cause of the temperature rise. Potential causes (e.g., a rise in containment temperature) are considered and other indicators in the CMT (e.g., the temperature trend of other sensors in the CMT) are reviewed.

UFSAR (plant-specific DCD) Subsection 6.3.2.2.1 is revised to include language which reflects this practice as part of this supplement (see Enclosure 5 which supplements Enclosure 2 from the April 30, 2020 submittal [ND-20-0507]).

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Southern Nuclear Operating Company ND-20-0900 Enclosure 5 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Proposed Changes to Licensing Basis Documents (LAR-20-004S1)

Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * )

(This Enclosure consists of 2 pages, including this cover page)

ND-20-0900 Supplement to Proposed Changes to Licensing Basis Documents (LAR-20-004S1)

Revise UFSAR (plant-specific DCD) Subsection 6.3.2.2.1, Core Makeup Tanks, as shown below:

[* * *]

Core makeup tank level and inlet and outlet line temperatures are monitored by indicators and alarms. The operator can take action as required to meet the technical specification requirements for core makeup tank operability. Core makeup tank temperature is monitored and trended to investigate potential leaks prior to alarm setpoints.

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