NL-23-0467, Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S1)
| ML23160A194 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 06/09/2023 |
| From: | Brown K Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-23-0467, LAR-23-005S1 | |
| Download: ML23160A194 (1) | |
Text
A Southern Nuclear June 9, 2023 ATTN: Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Unit 4 Docket No.52-026 R. Keith Brown Director, Regulatory Affairs Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway Birmingham, AL 35243 NL-23-0467 10 CFR 50.90
Subject:
Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S 1)
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 license (COL) for Vogtle Electric Generating Plant (VEGP) Unit 4 (License Number NPF-92). The license amendment request (LAR) proposes to modify the current Unit 4 COL Condition 2.0(9), Technical Specifications (TS),
to limit the scope of COL Appendix A TS that become effective upon a Commission finding in accordance with 10 CFR 52.103(g). The proposed revision to the COL Condition would provide temporary exceptions prior to initial criticality of the reactor core for certain TS while operating in Modes 4, 5, and 6. The COL Appendix A TS are proposed to be permanently effective at Unit 4 initial criticality of the reactor core. The proposed change also includes revision to COL Appendix A TS Limiting Condition for Operation (LCO) 3.0.7 to coordinate with the TS compliance provisions proposed in the COL Condition.
On June 5, 2023, the Nuclear Regulatory Commission (NRC) Staff issued a final Request for Additional Information (RAI) (ADAMS Accession No. ML23156A667) seeking clarifications related to the requested LAR.
This supplement provides the SNC responses and revisions to the requested LAR.
This supplement does not impact the scope or conclusions of the Significant Hazards Consideration Determination or Environmental Considerations of the original submittal.
An Enclosure was previously submitted to the NRC via NL-23-0135 (LAR-22-005). provides the responses to the RAI. Enclosure 3 provides the revised Technical Evaluation, which is shown as a markup to Section 3 of the Enclosure to NL-23-0135. The remainder of the NL-23-0135 Enclosure continues to be applicable to the requested LAR. The original Attachments 1, 2 and 3 are replaced in their entirety with Attachments 4, 5, and 6, respectively.
This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.
U. S. Nuclear Regulatory Commission NL-23-0467 Page 2 This letter also revises the requested approval date for the proposed amendment. Approval of the Amendment by July 19, 2023 is requested to support precritical, post initial fuel load, activities on Unit 4, which will minimize the potential impact on the on-going startup activities. If approved, this license amendment will be effective as of the date of its issuance and shall be implemented within 10 days of issuance If you have any questions, please contact Amy Chamberlain at 205.992.6361.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 9th day of June 2023.
Respectfully submitted,
~_d /) ___
Keith Brown Director, Regulatory Affairs Southern Nuclear Operating Company
Enclosure:
[Provided with LAR-22-005] : Response to Request for Additional Information (LAR-23-005S 1) : Revised Technical Evaluation (LAR-23-005S1)
Attachments:
- 1. [Provided with LAR-22-005]
- 2. [Provided with LAR-22-005]
- 3. [Provided with LAR-22-005]
- 4. Combined License and Technical Specifications Marked-up Pages - Revised
- 5. Combined License and Technical Specifications Revised Pages - Revised
- 6. Technical Specifications Bases Marked-up Pages - Revised (For Information Only) cc:
Regional Administrator, Region II VPO Project Manager Senior Resident Inspector - Vogtle 4 Director, Environmental Protection Division - State of Georgia Document Services RTYPE: VND.LI.L00 File AR.01.02.06 to NL-23-0467 Response to Request for Additional Information (LAR-23-005S 1)
On April 17, 2023, Southern Nuclear Operating Company (SNC) submitted License Amendment Request (LAR)22-005 per ND-23-0135 (Agencywide Documents Access and Management System Accession No. ML23107A278) requesting an amendment to the combined license (COLs) for Vogtle Electric Generating Plant (VEGP) Unit 4 (License Number NPF 92). On June 5, 2023, the Nuclear Regulatory Commission (NRC) Staff issued a Request for Additional Information (RAI) (ADAMS Accession No. ML23156A667) seeking clarifications related to the requested LAR.
The NRC RAI and SNC responses follow.
NRC RAI #1:
In the LAR, the licensee requests to temporarily exclude the requirement to comply with TS 5.6.2, "Radioactive Effluent Release Report" and TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)"
until after initial criticality.
- a.
TS 5.6.2 implements the 50.36a regulatory requirement for the Radioactive Effluent Release Report. Excluding compliance with TS 5.6.2 does not change the requirement to meet 50.36a. It appears to the staff that to exclude this reporting requirement, an exemption would be required.
Please revise the application accordingly (e.g., provide the exemption request or withdraw the request to exclude TS 5.6.2) or provide an explanation as for not needing an exemption.
- b.
The LAR also requests to exclude TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)."
However, per TS 5.5.1, the "ODCM shall contain the methodology and parameters used in the calculation of offsite doses resulting from radioactive gaseous and liquid effluents, in the calculation of gaseous and liquid effluent monitoring alarm and trip setpoints, and in the conduct of the radiological environmental monitoring program;" and it "shall also contain the radioactive effluent controls and radiological environmental monitoring activities, and descriptions of the information that should be included in the Annual Radiological Environmental Operating, and Radioactive Effluent Release Reports required by Specification 5.6.1 and Specification 5.6.2 [emphasis added]."
In addition, the licensee's COL Condition 2.D.(10)(g) requires that the ODCM be implemented before initial fuel load.
Without an exemption for the Annual Effluent Release Report, the requirements for the ODCM would be needed to support the development of the Annual Effluent Release Report. The staff requests clarification of this request as necessary to be consistent with the response to Question 1.a above. The licensee's response should also address whether any necessary conforming revision to COL Condition 2.D.(10)(g) is required.
SNC RAl#1 Response:
SNC has elected to withdraw the requested changes to temporarily exclude the requirement to comply with TS 5.6.2, "Radioactive Effluent Release Report" and TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)" until after initial criticality. Refer to the revisions shown in Enclosure 3, and Attachments 4 and 5, reflecting the changes from the original request.
E2-1 to NL-23-0467 Response to Request for Additional Information (LAR-23-005S 1)
NRC RAI #2:
The licensee requested to temporarily exclude meeting the requirements of TS 5.5.2, "Radioactive Effluent Control Program" until initial criticality. However, 10 CFR 50.36a states:
(a)
To keep releases of radioactive materials to unrestricted areas during normal conditions, including expected occurrences, as low as is reasonably achievable, each licensee of a nuclear power reactor and each applicant for a design certification or a manufacturing license will include technical specifications that, in addition to requiring compliance with applicable provisions of§ 20.1301 of this chapter, require that:
(1)
Operating procedures developed pursuant to § 50.34a(c) for the control of effluents be established and followed and that the radioactive waste system, pursuant to § 50.34a, be maintained and used [emphasis added]. The licensee shall retain the operating procedures in effect as a record until the Commission terminates the license and shall retain each superseded revision of the procedures for 3 years from the date it was superseded.
And TS 5.5.2, "Radioactive Effluent Control Program," states:
This program conforms to 10 CFR 50.36a for the control of radioactive effluents and for maintaining the doses to members of the public from radioactive effluents as low as reasonably achievable [emphasis added].
In addition, the Radioactive Effluent Control Program is needed to demonstrate compliance with other regulatory requirements, such as 10 CFR 20.1302, "Compliance with dose limits for individual members of the public." Also, COL Condition 2.0.(1 0)(f) requires that "Standard Radiological Effluent Controls" be implemented before initial fuel load.
Accordingly, it appears that this exclusion may also require an exemption or exemptions to implement as the requirements of the tech spec are required by regulations. COL Condition 2.0.(1 0)(f) would also need to be modified to address this exclusion. Please revise the application accordingly or provide an explanation as to the basis for not needing an exemption. The licensee's response should also address any necessary conforming revision of COL Condition 2.0.(1 0)(f).
SNC RAl#2 Response:
SNC has elected to withdraw the requested changes to temporarily exclude the requirement of TS 5.5.2, "Radioactive Effluent Control Program" until after initial criticality. Refer to the revisions shown in Enclosure 3, and Attachments 4 and 5, reflecting the changes from the original request.
E2-2 to NL-23-0467 Response to Request for Additional Information (LAR-23-005S 1)
NRC RAI #3:
The licensee requested to temporarily exclude TS 5.7, "High Radiation Area," prior to initial criticality. However, 10 CFR 20.1601, "Control of access to high radiation areas," states:
(a)
The licensee shall ensure that each entrance or access point to a high radiation area has one or more of the following features [emphasis added]
(1)
A control device that, upon entry into the area, causes the level of radiation to be reduced below that level at which an individual might receive a deep-dose equivalent of 0.1 rem (1 mSv) in 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at 30 centimeters from the radiation source or from any surface that the radiation penetrates; (2)
A control device that energizes a conspicuous visible or audible alarm signal so that the individual entering the high radiation area and the supervisor of the activity are made aware of the entry; or (3)
Entryways that are locked, except during periods when access to the areas is required, with positive control over each individual entry.
(b)
In place of the controls required by paragraph (a) of this section for a high radiation area, the licensee may substitute continuous direct or electronic surveillance that is capable of preventing unauthorized entry.
(c)
A licensee may apply to the Commission for approval of alternative methods for controlling access to high radiation areas.
In addition, COL Condition 2.D.(10)U) requires all other Radiation Protection Program features as identified in updated final safety analysis report (UFSAR) Section 12.5 (including the ALARA principle) except for those applicable to control radioactive waste shipment be implemented before initial fuel load. Section 12.5.4 of the UFSAR states, "High and very high radiation areas are segregated and identified in accordance with 10 CFR 20. The entrances to high and very high radiation areas are locked or barricaded and equipped with audible and/or visible alarms, as required."
Accordingly, it appears that this exclusion may also require an exemption to implement as the requirements of the technical specification implement the requirements of 10 CFR 20.1601.
Please revise the application accordingly or provide an explanation as to the basis for not needing an exemption. The licensee's response should also address any necessary conforming changes to COL Condition 2.0(1 0)U).
SNC RAl#3 Response:
SNC has elected to withdraw the requested changes to temporarily exclude the requirement of TS 5.7, "High Radiation Area" until after initial criticality. Refer to the revisions shown in Enclosure 3, and Attachments 4 and 5, reflecting the changes from the original request.
E2-3 to NL-23-0467 Response to Request for Additional Information (LAR-23-00SS 1)
NRC RAI #4:
The LAR requests to exclude TS 5.6.1, "Annual Radiological Environmental Operating Report."
However, this report is not due until May 15th, and it covers the previous operating year. It is unclear from the LAR description how excluding this report would work because if the licensee achieves criticality prior to May 15th, the report would still be required to be submitted. In addition, COL Condition 2.D.(1 0)(h) requires that the Radiological Environmental Monitoring Program be implemented before initial fuel load.
Please provide an explanation of the intent for excluding this TS and the supporting technical basis. Also, if appropriate, please revise the license condition 2.0.(9) to more accurately reflect how this TS will be excluded. If the intention is to not require a report in 2024 for calendar year 2023, then the license condition for excluding TS 5.6.1 will need to be revised and a justification for not providing the report will need to be included in the LAR. The staff notes that excluding the report would not exclude the requirement to implement the program and to conduct the required monitoring as required by COL Condition 2.D.(10)(h)
SNC RAl#4 Response:
SNC has elected to withdraw the requested changes to temporarily exclude the requirement of TS 5.6.1, "Annual Radiological Environmental Operating Report" until after initial criticality. Refer to the revisions shown in Enclosure 3, and Attachments 4 and 5, reflecting the changes from the original request.
E2-4 to NL-23-0467 Response to Request for Additional Information (LAR-23-005S 1)
NRC RAI #5:
Under the category of Main Control Room (MCR) Emergency Habitability System (VES)
Radiological Controls, the LAR proposes to exclude two administrative control programs and two surveillance requirements (SR) prior to initial criticality: 1) TS 5.5.12, "Main Control Room Envelope [MCRE] Habitability Program," 2) TS 5.5.13, "Ventilation Filter Testing Program (VFTP)," 3) SR 3.7.6.9, "Perform required MCRE unfiltered air inleakage testing in accordance with the Main Control Room Envelope Habitability Program," and 4) SR 3.7.6.10, "Perform required VES Passive Filtration system filter testing in accordance with the Ventilation Filter Testing Program (VFTP)." The technical basis for excluding these programs is that the "VES requirements that involve protection from the release of radioactivity (and support actuation) are proposed to be excluded while operating in Mode 4 until initial criticality since there are no fission products to be released that would challenge MCR habitability."
The MCR Emergency Habitability System (VES) provides a protected environment from which operators can control the plant following an uncontrolled release of radioactivity, hazardous chemicals, or smoke.
- a. As stated in TS 5.5.12, "A Main Control Room Envelope (MCRE) Habitability Program shall be established and implemented to ensure that MCRE habitability is maintained such that... MCRE occupants can control the reactor safely under normal conditions and maintain it in a safe condition following a radiological event, hazardous chemical release, or a smoke challenge [emphasis added]." Similarly, as stated in the VEGP 3/4 TS Bases, SR 3.7.6.9 verifies the operability of the MCRE boundary to ensure that MCRE occupants are protected from hazardous chemicals and smoke. Please explain how protection of the MCRE from fire and hazardous chemicals would be maintained or is not needed prior to initial criticality.
- b. As stated in TS 5.5.13, a program shall be established to implement the required testing of the VES. Specific testing is required by 5.5.13 when events occur that could have an adverse effect on the high efficiency particulate air (HEPA) filter, charcoal adsorber, or carbon media functional capabilities, such as penetration of water, or painting, fire or chemical release in any ventilation zone communicating with the VES [emphasis added]. Similarly, SR 3.7.6.10 verifies that required VES testing is performed in accordance with the VFTP. Please explain why testing of the ventilation filters following water penetration, or following events such as painting, fire or chemical release, would be maintained or is not needed prior to initial criticality.
SNC RAl#S Response:
SNC has elected to withdraw the requested changes to temporarily exclude the requirements of
- 1) TS 5.5.12, "Main Control Room Envelope [MCRE] Habitability Program," 2) TS 5.5.13, "Ventilation Filter Testing Program (VFTP)," 3) SR 3.7.6.9, "Perform required MCRE unfiltered air inleakage testing in accordance with the Main Control Room Envelope Habitability Program," and
- 4) SR 3.7.6.10, "Perform required VES Passive Filtration system filter testing in accordance with the Ventilation Filter Testing Program (VFTP)" until after initial criticality. Additionally, SNC has elected to withdraw the requested change to temporarily exclude the requirements of TS 3.7.6, "Main Control Room Emergency Habitability System (VES)." Refer to the revisions shown in, and Attachments 4 and 5, reflecting the changes from the original request.
E2-5 to NL-23-0467 Response to Request for Additional Information (LAR-23-005S 1)
NRC RAI #6:
LCOs 3.4.11, "Automatic Depressurization System (ADS) - Operating," 3.5.6 "In-containment Refueling Water Storage Tank (IRWST) - Operating," 3.6.3, and "Containment Isolation Valves" are proposed for exclusion in the LAR while operating in Mode 4 prior to initial criticality. It is the staff's understanding from the LAR that excluding the LCO includes excluding the requirement to perform any related surveillances (SR) for each excluded LCO. However, these three LCO's include SRs are that are specifically required by the lnservice Testing (1ST) Program, which is required by 1 0CFR50.55a.
Accordingly, excluding the LCO would not remove the requirement to perform the testing of these components in accordance with the 1ST program. In order to exclude the 1ST related SRs, an exemption would be required. Please modify the application accordingly or provide an explanation as to why an exemption is not required to support this portion of the requested changes in the LAR.
SNC RAl#G Response:
SNC understands and agrees with the NRC staff's observation that providing temporary exception to the LCO requirements, and therefore its associated SRs, does not provide an exception for meeting the lnservice Testing (1ST) Program, as required by 10 CFR 50.55a. SNC will continue to comply with the 1ST Program requirements without the need for an exemption to 10 CFR 50.55a. The requested exception to the LCO requirements will serve to provide an exception to entering the associated TS Actions in the event of inoperabilities in the associated LCO 3.4.11, LCO 3.5.6, and LCO 3.6.3 during the temporary exception period.
E2-6 to NL-23-0467 Response to Request for Additional Information (LAR-23-00SS 1)
NRC RAI #7:
The LAR proposes to add a paragraph to LCO 3.0.7 that states:
Additionally, for Unit 4 only, Combined License Condition 2.0.(9) provides temporary exclusions for specified TS requirements prior to becoming permanently effective at initial criticality of the reactor core. Compliance with TS requirements that are excluded from becoming effective while operating in MODES 4, 5, and 6 in accordance with the COL Condition is optional [emphasis added].
However, the Bases provided with the LAR state: "LCO 3.0.7 recognizing this COL provision, allows changing the TS requirements that are deferred to initial criticality [emphasis added], which would otherwise be required to be met." The staff recognizes that the TS Bases are not reviewed and approved by the NRC. However, the staff notes that this statement reflects an incorrect interpretation of the revised LCO 3.0.7 that needs to be clarified. The revised LCO 3.0.7 would only delay the requirement to comply with the LCOs listed in Combined License Condition 2.0(9) until initial criticality and then all LCOs listed in the 2.0(9) would be permanently required to be met. If approved, the license amendment would not allow the licensee to make any changes to the requirements of the listed LCOs regardless of any TS Bases statements. The staff recommends the Bases be revised to accurately reflect the technical basis for the revised LCO 3.0.7.
SNC RAl#7 Response:
SNC agrees with the NRC staff that the revised LCO 3.0.7 would only delay the requirement to comply with the LCOs listed in Combined License Condition 2.0(9) until initial criticality and then all LCOs listed in the 2.0(9) would be permanently required to be met. If approved, the license amendment would not allow the licensee to make any changes to the requirements of the listed LCOs. The TS Bases sentence "LCO 3.0. 7 recognizing this COL provision, allows changing the TS requirements that are deferred to initial criticality" is deleted as shown in Attachment 6.
E2-7 to NL-23-0467 Revised Technical Evaluation (LAR-23-005S 1)
ENCLOSURE 3 Revised Technical Evaluation (LAR-23-005S1)
- 3.
TECHNICAL EVALUATION 3.1 3.2 3.3 Other Modes 4, 5, and 6 Exclusions 3.4 ATTACHMENTS:
- 4.
Combined License and Technical Specifications Marked-up Pages - REVISED
- 5.
Combined License and Technical Specifications Revised Pages - REVISED
- 6.
Technical Specifications Bases Marked-up Pages - REVISED (For Information Only)
Insertions to from NL-23-0135 text denoted by underlined Blue text.
Deletions from NL-23-0135 text denoted by Red Strikeout text Omitted (unchanged) text from NL-23-0135 is identified by three asterisks ( * * *)
(This Enclosure consists of two pages, including this cover page)
E3-1 to NL-23-0467 Revised Technical Evaluation (LAR-23-00SS 1)
- 3. TECHNICAL EVALUATION 3.3 Other Modes 4, 5, and 6 Exclusions Main Control Room (MCR) Emergency Habitability System (VES) Radiological Controls The VES actuation required by TS 3.3.13, "ESFAS Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization," Table 3.3.13-1, Function 1, Main Control Room Air Supply Iodine or Particulate Radiation High 2 requirements that involve.§ protection from the release of radioactivity and is (and support actuation) are proposed to be excluded while operating in Mode 4 until initial criticality since there are no fission products to be released that would challenge MCR habitability. The COL proposed exclusions f-or TS 3.7.6, "Main Control Room Habitability System (VES)" for the radiological protection functions involve excluding:
TS 3.3.13, "ESFAS Main Control Room Isolation, Air Supply Initiation, and Electrical Load De energization," Table 3.3.13 1, Function 1, Main Control Room Air Supply Iodine or Particulate Radiation High 2 Surveillance Requirements (SR) 3.7.6.9, "Perf-orm required MCRE unfiltered air in leakage testing in accordance with the Main Control Room En 1.ielope Habitability Program" and SR 3.7.6.10, "Perf-orm required VES Passive Filtration system filter testing in accordance 1Nith the Ventilation Filter Testing Program (VFTP)"
TS 5.5.12, "Main Control Room Envelope Habitability Program" TS 5.5.13, "Ventilation Filter Testing Program (VFTP)"
TS Administrative Controls Not Required Prior to Criticality The f-ollmving TS Administrative Controls are proposed to be excluded while operating in Modes 4, 5, and 6 until initial criticality. These Programs and Reports address mitigation or monitoring of doses produced as a result of plant operation after criticality. Deferring these Programs and reports until initial criticality (i.e., prior to generating fission products) is consistent with the intended basis f-or these Programs and Reports not being required prior to the 10 CFR 52.103(g) finding. Requiring them prior to initial criticality pro1.iides no safety benefit.
TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)"
TS 5.5.2, "Radioactive Effluent Control Program" TS 5.6.1, "Annual Radiological Environmental Operating Report" TS 5.6.2, "Radioactive Effluent Release Report" TS 5.7, "High Radiation Area" E3-2 (LAR-23-005S1)
Combined License and Technical Specifications Marked-up Pages - REVISIONS Insertions to Current Licensing Basis denoted by underlined Blue text.
Deletions from NL-23-0135 Attachment 1 test denoted by Red Strikeout text Omitted Current Licensing Basis text is identified by three asterisks ( * * * )
(This Attachment consists of seven pages, including this cover page) to NL-23-0467 Combined License and Technical Specifications Marked-up Pages - Revised Combined License (COL) Condition 2.D D. The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:
(8)
Incorporation The Technical Specifications, Environmental Protection Plan, and ITAAC in Appendices A, B, and C, respectively of this license, as revised through Amendment No. XXX, are hereby incorporated into this license.
(9)
Technical Specifications The technical specifications in Appendix A to this license (TS) become effective upon a Commission finding that the acceptance criteria in this license (ITAAC) are met in accordance with 10 CFR 52.103(g).,. with the following exceptions:
(a)
Prior to initial criticality of the reactor core while operating in plant operational Mode 5 (Cold Shutdown) or Mode 6 (Refueling) the following TS are temporarily excluded from becoming effective:
TS 3.3.8, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," Table 3.3.8-1 o
Function 14, RCS Wide Range Pressure - Low o
Function 15, Core Makeup Tank (CMT) Level - Low 3 o
Function 16, CMT Level - Low 6 o
Function 18, IRWST Lower Narrow Range Level - Low 3 TS 3.3.9, "Engineered Safety Feature Actuation System (ESFAS) Manual Initiation," Table 3.3.9-1 o
Function 1, Safeguards Actuation - Manual Initiation o
Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation o
Function 7, ADS Stage 4 Actuation - Manual Initiation o
Function 8, Passive Containment Cooling Actuation - Manual Initiation o
Function 9, Passive Residual Heat Removal Heat Exchanger Actuation -
Manual Initiation o
Function 12, In-Containment Refueling Water Storage Tank (IRWST)
Injection Line Valve Actuation - Manual Initiation o
Function 13, IRWST Containment Recirculation Valve Actuation - Manual Initiation TS 3.3.10, "Engineered Safety Feature Actuation System (ES FAS) Reactor Coolant System (RCS) Hot Leg Level Instrumentation" A4-2 to NL-23-0467 Combined License and Technical Specifications Marked-up Pages - Revised TS 3.3.14, "Engineered Safety Feature Actuation System (ESFAS)
In-containment Refueling Water Storage Tank (IRWST) and Spent Fuel Pool Level Instrumentation," Table 3.3.14-1 o
Function 1, Spent Fuel Pool Level - Low 2 TS 3.3.19, "Diverse Actuation System (DAS) Manual Controls," Table 3.3.19-1 o
Function 2, Passive Residual Heat Removal Heat Exchanger (PRHR HX) control and In-Containment Refueling Water Storage Tank (IRWST) gutter control valves o
Function 4, Automatic Depressurization System (ADS) stage 1 valves o
Function 5, ADS stage 2 valves o
Function 6, ADS stage 3 valves o
Function 7, ADS stage 4 valves o
Function 8, IRWST injection squib valves o
Function 9, Containment recirculation valves o
Function 10, Passive containment cooling drain valves o
Function 11, Selected containment isolation valves TS 3.3.20, "Automatic Depressurization System (ADS) and In-containment Refueling Water Storage Tank (IRWST) Injection Blocking Device,"
Table 3.3.20-1 o
Function 2, ADS and IRWST Injection Block Switches for Manual Unblocking TS 3.4.12, "Automatic Depressurization System (ADS) -
Shutdown, RCS Intact" TS 3.4.13, "Automatic Depressurization System (ADS) -
Shutdown, RCS Open" TS 3.5.5, "Passive Residual Heat Removal Heat Exchanger (PRHR HX) -
Shutdown, Reactor Coolant System (RCS) Intact"
Shutdown, MODE 5"
Shutdown, MODE 6" TS 3.6.7, "Containment Penetrations" TS 3.7.13, "Spent Fuel Pool Cooling System (SFS) Containment Isolation Valves" TS 5.5, "Programs and Manuals" o
TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)"
o TS 5.5.2, "Radioactive Effluent Control Program" o
TS 5.5.12, "Main Control Room En1,elope Habitability Program" A4-3 to NL-23-0467 Combined License and Technical Specifications Marked-up Pages - Revised o
TS 5.5.13, "Ventilation Filter Testing Program (VFTP)"
TS 5.6, "Reporting Requirements" o
TS 5.6.1, "Annual Radiological Environmental Operating Report" o
TS 5.6.2, "Radioactive Effluent Release Report" TS 5.7, "High Radiation Area" (b)
Prior to initial criticality of the reactor core while operating in plant operational Mode 4 (Safe Shutdown) when any cold leg temperature is < 275°F the following TS are temporarily excluded from becoming effective:
TS 3.3.8, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," Table 3.3.8-1 o
Function 14, RCS Wide Range Pressure - Low o
Function 15, Core Makeup Tank (CMT) Level - Low 3 o
Function 16, CMT Level - Low 6 o
Function 18, IRWST Lower Narrow Range Level - Low 3 o
Function 19, Reactor Coolant Pump Bearing Water Temperature - High 2 TS 3.3.9, "Engineered Safety Feature Actuation System (ESFAS) Manual Initiation," Table 3.3.9-1 o
Function 3, Containment Isolation - Manual Initiation o
Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation o
Function 7, ADS Stage 4 Actuation - Manual Initiation o
Function 8, Passive Containment Cooling Actuation - Manual Initiation o
Function 12, In-Containment Refueling Water Storage Tank (IRWST)
Injection Line Valve Actuation - Manual Initiation o
Function 13, IRWST Containment Recirculation Valve Actuation - Manual Initiation TS 3.3.13, "Engineered Safety Feature Actuation System (ESFAS) Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization," Table 3.3.13-1 o
Function 1, Main Control Room Air Supply Iodine or Particulate Radiation
- High 2 TS 3.3.19, "Diverse Actuation System (DAS) Manual Controls," Table 3.3.19-1 o
Function 4, Automatic Depressurization System (ADS) stage 1 valves o
Function 5, ADS stage 2 valves o
Function 6, ADS stage 3 valves o
Function 7, ADS stage 4 valves o
Function 8, IRWST injection squib valves A4-4 to NL-23-0467 Combined License and Technical Specifications Marked-up Pages - Revised o
Function 9, Containment recirculation valves o
Function 10, Passive containment cooling drain valves o
Function 11, Selected containment isolation valves TS 3.3.20, "Automatic Depressurization System (ADS) and In-containment Refueling Water Storage Tank (IRWST) Injection Blocking Device,"
Table 3.3.20-1 o
Function 2, ADS and IRWST Injection Block Switches for Manual Unblocking TS 3.4.11, "Automatic Depressurization System (ADS) - Operating" TS 3.5.1, "Accumulators" TS 3.5.6, "In-containment Refueling Water Storage Tank (IRWST) -
Operating" TS 3.6.1, "Containment" TS 3.6.2, "Containment Air Locks" TS 3.6.3, "Containment Isolation Valves" TS 3.6.6, "Passive Containment Cooling System (PCS)"
TS 3.6.8, "pH Adjustment" TS 3.7.4, "Secondary Specific Activity" TS 3.7.6, "Main Control Room Habitability System (VES)" for the radiological protection functions TS 3. 7.10, "Steam Generator (SG) Isolation Valves" only for PORV and PORV block valves (SG blowdown isolation valve not excluded)
TS 5.5, "Programs and Manuals" o
TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)"
o TS 5.5.2, "Radioactii,e Effluent Control Program" o
TS 5.5.12, "Main Control Room Envelope Habitability Program" o
TS 5.5.13, "Ventilation Filter Testing Program (VFTP)"
TS 5.6, "Reporting Requirements" o
TS 5.6.1, "Annual Radiological En1,ironmental Operating Report" o
TS 5.6.2, "Radioactive Effluent Release Report" TS 5.7, "High Radiation Area" (c)
Prior to initial criticality of the reactor core while operating in plant operational Mode 4 (Safe Shutdown) with all four cold leg temperatures > 275°F the following TS are temporarily excluded from becoming effective:
TS 3.3.8, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," Table 3.3.8-1 A4-5 to NL-23-0467 Combined License and Technical Specifications Marked-up Pages - Revised o
Function 3, Containment Radioactivity - High o
Function 18, IRWST Lower Narrow Range Level - Low 3 o
Function 19, Reactor Coolant Pump Bearing Water Temperature - High 2 TS 3.3.9, "Engineered Safety Feature Actuation System (ESFAS) Manual Initiation," Table 3.3.9-1 o
Function 3, Containment Isolation - Manual Initiation o
Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation o
Function 7, ADS Stage 4 Actuation - Manual Initiation o
Function 8, Passive Containment Cooling Actuation - Manual Initiation o
Function 13, IRWST Containment Recirculation Valve Actuation - Manual Initiation o
Function 14, SG Power Operated Relief Valve and Block Valve Isolation -
Manual Initiation TS 3.3.13, "Engineered Safety Feature Actuation System (ESFAS) Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization," Table 3.3.13-1 o
Function 1, Main Control Room Air Supply Iodine or Particulate Radiation
- High 2 TS 3.3.19, "Diverse Actuation System (DAS) Manual Controls," Table 3.3.19-1 o
Function 4, Automatic Depressurization System (ADS) stage 1 valves o
Function 5, ADS stage 2 valves o
Function 6, ADS stage 3 valves o
Function 7, ADS stage 4 valves o
Function 9, Containment recirculation valves o
Function 10, Passive containment cooling drain valves o
Function 11, Selected containment isolation valves TS 3.4.11, "Automatic Depressurization System (ADS) - Operating" TS 3.5.1, "Accumulators" TS 3.5.6, "In-containment Refueling Water Storage Tank (IRWST) -
Operating" only for containment recirculation flow paths (injection flow paths not excluded)
TS 3.6.1, "Containment" TS 3.6.2, "Containment Air Locks" TS 3.6.3, "Containment Isolation Valves" TS 3.6.6, "Passive Containment Cooling System (PCS)"
TS 3.6.8, "pH Adjustment" A4-6 to NL-23-0467 Combined License and Technical Specifications Marked-up Pages - Revised TS LCO 3.0 LCO 3.0.7 TS 3.7.4, "Secondary Specific Activity" TS 3.7.6, "Main Control Room Habitability System (VES)" for the radiological protection functions TS 3. 7.10, "Steam Generator (SG) Isolation Valves" only for PORV and PORV block valves (SG blowdown isolation valve not excluded)
TS 5.5, "Programs and Manuals" o
TS 5.5.1, "Offsite Dose Calculation Manual (ODCM)"
o TS 5.5.2, "Radioactive Effluent Control Program" o
TS 5.5.12, "Main Control Room En1,elope Habitability Program" o
TS 5.5.13, "Ventilation Filter Testing Program (VFTP)"
TS 5.6, "Reporting Requirements" o
TS 5.6.1, "Annual Radiological Environmental Operating Report" o
TS 5.6.2, "Radioacti>,e Effluent Release Report" TS 5.7, "High Radiation Area" Test Exception LCOs 3.1.8 and 3.1.10 allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.
Additionally, for Unit 4 only, Combined License Condition 2.0(9) provides temporary exclusions for specified TS requirements prior to becoming permanently effective at initial criticality of the reactor core. Compliance with TS requirements that are excluded from becoming effective while operating in MODES 4, 5, and 6 in accordance with the COL Condition is optional.
A4-7 (LAR-23-005S1)
Combined License and Technical Specifications Revised Pages - REVISIONS (This Attachment consists of eight pages, including this cover page)
(7)
(8)
Reporting Requirements (a)
Within 30 days of a change to the initial test program described in UFSAR Section 14, Initial Test Program, made in accordance with 10 CFR 50.59 or in accordance with 10 CFR Part 52, Appendix D, Section VIII, "Processes for Changes and Departures," SNC shall report the change to the Director of NRO, or the Director's designee, in accordance with 10 CFR 50.59(d).
(b)
SNC shall report any violation of a requirement in Section 2.0.(3),
Section 2.0.(4), Section 2.0.(5), and Section 2.0.(6) of this license within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. Initial notification shall be made to the NRC Operations Center in accordance with 10 CFR 50.72, with written follow up in accordance with 10 CFR 50. 73.
Incorporation The Technical Specifications, Environmental Protection Plan, and ITAAC in Appendices A, B, and C, respectively of this license, as revised through Amendment No. XXX, are hereby incorporated into this license.
(9)
Technical Specifications The technical specifications in Appendix A to this license become effective upon a Commission finding that the acceptance criteria in this license (IT AAC) are met in accordance with 10 CFR 52.103(g) with the following exceptions:
(a) Prior to initial criticality of the reactor core while operating in plant operational Mode 5 (Cold Shutdown) or Mode 6 (Refueling) the following TS are temporarily excluded from becoming effective:
TS 3.3.8, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," Table 3.3.8-1 o
Function 14, RCS Wide Range Pressure - Low o
Function 15, Core Makeup Tank (CMT) Level - Low 3 o
Function 16, CMT Level - Low 6 o
Function 18, IRWST Lower Narrow Range Level - Low 3 TS 3.3.9, "Engineered Safety Feature Actuation System (ESFAS)
Manual Initiation," Table 3.3.9-1 o
Function 1, Safeguards Actuation - Manual Initiation o
Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation o
Function 7, ADS Stage 4 Actuation - Manual Initiation o
Function 8, Passive Containment Cooling Actuation - Manual Initiation o
Function 9, Passive Residual Heat Removal Heat Exchanger Actuation - Manual Initiation 7
Amendment No. XXX
o Function 12, In-Containment Refueling Water Storage Tank (IRWST) Injection Line Valve Actuation - Manual Initiation o
Function 13, IRWST Containment Recirculation Valve Actuation
- Manual Initiation TS 3.3.10, "Engineered Safety Feature Actuation System (ES FAS)
Reactor Coolant System (RCS) Hot Leg Level Instrumentation" TS 3.3.14, "Engineered Safety Feature Actuation System (ESFAS)
In-containment Refueling Water Storage Tank (IRWST) and Spent Fuel Pool Level Instrumentation," Table 3.3.14-1 o
Function 1, Spent Fuel Pool Level - Low 2 TS 3.3.19, "Diverse Actuation System (DAS) Manual Controls,"
Table 3.3.19-1 o
Function 2, Passive Residual Heat Removal Heat Exchanger (PRHR HX) control and In-Containment Refueling Water Storage Tank (IRWST) gutter control valves o
Function 4, Automatic Depressurization System (ADS) stage 1 valves o
Function 5, ADS stage 2 valves o
Function 6, ADS stage 3 valves o
Function 7, ADS stage 4 valves o
Function 8, IRWST injection squib valves o
Function 9, Containment recirculation valves o
Function 10, Passive containment cooling drain valves o
Function 11, Selected containment isolation valves TS 3.3.20, "Automatic Depressurization System (ADS) and In-containment Refueling Water Storage Tank (IRWST) Injection Blocking Device," Table 3.3.20-1 o
Function 2, ADS and IRWST Injection Block Switches for Manual Unblocking TS 3.4.12, "Automatic Depressurization System (ADS) - Shutdown, RCS Intact" TS 3.4.13, "Automatic Depressurization System (ADS) - Shutdown, RCS Open" TS 3.5.5, "Passive Residual Heat Removal Heat Exchanger (PRHR HX) - Shutdown, Reactor Coolant System (RCS) Intact" TS 3.5.7, "In-containment Refueling Water Storage Tank (IRWST) -
Shutdown, MODE 5" TS 3.5.8, "In-containment Refueling Water Storage Tank (IRWST) -
Shutdown, MODE 6" TS 3.6.7, "Containment Penetrations" TS 3.7.13, "Spent Fuel Pool Cooling System (SFS) Containment Isolation Valves" 7a Amendment No. XXX
(b) Prior to initial criticality of the reactor core while operating in plant operational Mode 4 (Safe Shutdown) when any cold leg temperature is
- 275°F the following TS are temporarily excluded from becoming effective
TS 3.3.8, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," Table 3.3.8-1 o
Function 14, RCS Wide Range Pressure - Low o
Function 15, Core Makeup Tank (CMT) Level - Low 3 o
Function 16, CMT Level - Low 6 o
Function 18, IRWST Lower Narrow Range Level - Low 3 o
Function 19, Reactor Coolant Pump Bearing Water Temperature
- High 2 TS 3.3.9, "Engineered Safety Feature Actuation System (ESFAS)
Manual Initiation," Table 3.3.9-1 o
Function 3, Containment Isolation - Manual Initiation o
Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation o
Function 7, ADS Stage 4 Actuation - Manual Initiation o
Function 8, Passive Containment Cooling Actuation - Manual Initiation o
Function 12, In-Containment Refueling Water Storage Tank (IRWST) Injection Line Valve Actuation - Manual Initiation o
Function 13, IRWST Containment Recirculation Valve Actuation
- Manual Initiation TS 3.3.13, "Engineered Safety Feature Actuation System (ESFAS)
Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization," Table 3.3.13-1 o
Function 1, Main Control Room Air Supply Iodine or Particulate Radiation - High 2 TS 3.3.19, "Diverse Actuation System (DAS) Manual Controls,"
Table 3.3.19-1 o
Function 4, Automatic Depressurization System (ADS) stage 1 valves o
Function 5, ADS stage 2 valves o
Function 6, ADS stage 3 valves o
Function 7, ADS stage 4 valves o
Function 8, IRWST injection squib valves o
Function 9, Containment recirculation valves o
Function 10, Passive containment cooling drain valves o
Function 11, Selected containment isolation valves 7b Amendment No. XXX
TS 3.3.20, "Automatic Depressurization System (ADS) and In-containment Refueling Water Storage Tank (IRWST) Injection Blocking Device," Table 3.3.20-1 o
Function 2, ADS and IRWST Injection Block Switches for Manual Unblocking TS 3.4.11, "Automatic Depressurization System (ADS) - Operating" TS 3.5.1, "Accumulators" TS 3.5.6, "In-containment Refueling Water Storage Tank (IRWST) -
Operating" TS 3.6.1, "Containment" TS 3.6.2, "Containment Air Locks" TS 3.6.3, "Containment Isolation Valves" TS 3.6.6, "Passive Containment Cooling System (PCS)"
TS 3.6.8, "pH Adjustment" TS 3.7.4, "Secondary Specific Activity" TS 3.7.10, "Steam Generator (SG) Isolation Valves" only for PORV and PORV block valves (SG blowdown isolation valve not excluded)
(c) Prior to initial criticality of the reactor core while operating in plant operational Mode 4 (Safe Shutdown) with all four cold leg temperatures
> 275°F the following TS are temporarily excluded from becoming effective:
TS 3.3.8, "Engineered Safety Feature Actuation System (ESFAS)
Instrumentation," Table 3.3.8-1 o
Function 3, Containment Radioactivity - High o
Function 18, IRWST Lower Narrow Range Level - Low 3 o
Function 19, Reactor Coolant Pump Bearing Water Temperature
- High 2 TS 3.3.9, "Engineered Safety Feature Actuation System (ESFAS)
Manual Initiation," Table 3.3.9-1 o
Function 3, Containment Isolation - Manual Initiation o
Function 6, ADS Stages 1, 2 & 3 Actuation - Manual Initiation o
Function 7, ADS Stage 4 Actuation - Manual Initiation o
Function 8, Passive Containment Cooling Actuation - Manual Initiation o
Function 13, IRWST Containment Recirculation Valve Actuation
- Manual Initiation o
Function 14, SG Power Operated Relief Valve and Block Valve Isolation - Manual Initiation 7c Amendment No. XXX
TS 3.3.13, "Engineered Safety Feature Actuation System (ESFAS)
Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization," Table 3.3.13-1 o
Function 1, Main Control Room Air Supply Iodine or Particulate Radiation - High 2 TS 3.3.19, "Diverse Actuation System (DAS) Manual Controls,"
Table 3.3.19-1 o
Function 4, Automatic Depressurization System (ADS) stage 1 valves o
Function 5, ADS stage 2 valves o
Function 6, ADS stage 3 valves o
Function 7, ADS stage 4 valves o
Function 9, Containment recirculation valves o
Function 10, Passive containment cooling drain valves o
Function 11, Selected containment isolation valves TS 3.4.11, "Automatic Depressurization System (ADS) - Operating" TS 3.5.1, "Accumulators" TS 3.5.6, "In-containment Refueling Water Storage Tank (IRWST) -
Operating" only for containment recirculation flow paths (injection flow paths not excluded)
TS 3.6.1, "Containment" TS 3.6.2, "Containment Air Locks" TS 3.6.3, "Containment Isolation Valves" TS 3.6.6, "Passive Containment Cooling System (PCS)"
TS 3.6.8, "pH Adjustment" TS 3.7.4, "Secondary Specific Activity" TS 3. 7.10, "Steam Generator (SG) Isolation Valves" only for PORV and PORV block valves (SG blowdown isolation valve not excluded) 7d Amendment No. XXX
(10)
Operational Program Implementation SNC shall implement the programs or portions of programs identified below, on or before the date SNC achieves the following milestones:
(a)
Environmental Qualification Program implemented before initial fuel load; (b)
Reactor Vessel Material Surveillance Program implemented before initial criticality; (c)
Preservice Testing Program implemented before initial fuel load; (d)
Containment Leakage Rate Testing Program implemented before initial fuel load; (e)
- 1.
The fire protection measures in accordance with Regulatory Guide (RG) 1.189 for designated storage building areas (including adjacent fire areas that could affect the storage area) implemented before initial receipt
?e Amendment No. XXX
3.0 LCO Applicability LCO 3.0.5 LCO 3.0.6 LCO 3.0.7 VEGP Units 3 and 4 Technical Specifications LCO Applicability 3.0 Equipment removed from service or declared inoperable to comply with ACTIONS may be returned to service under administrative control solely to perform testing required to demonstrate its OPERABILITY or the OPERABILITY of other equipment. This is an exception to LCO 3.0.2 for the system returned to service under administrative control to perform the test required to demonstrate OPERABILITY.
When a supported system LCO is not met solely due to a support system LCO not being met, the Conditions and Required Actions associated with this supported system are not required to be entered. Only the support system LCO ACTIONS are required to be entered. This is an exception to LCO 3.0.2 for the supported system. In this event, additional evaluations and limitations may be required in accordance with Specification 5.5.7, "Safety Function Determination Program (SFDP)." If a loss of safety function is determined to exist by this program, the appropriate Conditions and Required Actions of the LCO in which the loss of safety function exists are required to be entered.
When a support system's Required Action directs a supported system to be declared inoperable or directs entry into Conditions and Required Actions for a supported system, the applicable Conditions and Required Actions shall be entered in accordance with LCO 3.0.2.
Test Exception LCOs 3.1.8 and 3.1.10 allow specified Technical Specification (TS) requirements to be changed to permit performance of special tests and operations. Unless otherwise specified, all other TS requirements remain unchanged. Compliance with Test Exception LCOs is optional. When a Test Exception LCO is desired to be met but is not met, the ACTIONS of the Test Exception LCO shall be met. When a Test Exception LCO is not desired to be met, entry into a MODE or other specified condition in the Applicability shall be made in accordance with the other applicable Specifications.
Additionally, for Unit 4 only, Combined License Condition 2.0(9) provides temporary exclusions for specified TS requirements prior to becoming permanently effective at initial criticality of the reactor core. Compliance with TS requirements that are excluded from becoming effective while operating in MODES 4, 5, and 6 in accordance with the COL Condition is optional.
3.0 - 2 Amendment No. 117 (Unit 3)
Amendment No. _
(Unit 4)
(LAR-23-005S1)
Technical Specifications Bases Marked-up Pages - REVISIONS (For Information Only)
Insertions to Current Licensing Basis denoted by underlined Blue text.
Deletions from NL-23-0135 Attachment 3 denoted by Red Strikeout text Omitted Current Licensing Basis text is identified by three asterisks ( * * * )
(This Attachment consists of two pages, including this cover page) to NL-23-0467 Technical Specifications Bases Marked-up Pages - Revised (For Information Only)
TS LCO 3.0 Bases LCO 3.0.7 There are certain special tests and operations required to be performed at various times over the life of the unit. These special tests and operations are necessary to demonstrate select unit performance characteristics, to perform special maintenance activities, and to perform special evolutions.
Test Exception LCOs 3.1.8 and 3.1.10 allow specified Technical Specification (TS) requirements to be changed to permit performance of these special tests and operations, which otherwise could not be performed if required to comply with the requirements of these TS. Unless otherwise specified, all the other TS requirements remain unchanged. This will ensure all appropriate requirements of the MODE or other specified condition not directly associated with or required to be changed to perform the special test or operation will remain in effect.
Additionally, for Unit 4 only, Combined License (COL) Condition 2.0(9) provides temporary exclusions for specified TS requirements commencing with the 10 CFR 52.103(g) finding prior to initial criticality. The TS exclusions listed in the COL Condition are only portions of the TS requirements Applicable in MODES 4, 5, and 6. All TS requirements become permanently effective at initial criticality of the reactor core.
LCO 3.0.7 recognizing this COL pro1o1ision, allows changing the TS requirements that are deferred to initial criticality, 1Nhich 1Nould otherwise be required to be met A6-2