ML23263A985

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Issuance of Amendments Nos. 221 and 204, Regarding Technical Specification 5.5.11.C, Acceptance Criteria for Charcoal Filter Testing
ML23263A985
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 10/12/2023
From: John Lamb
Plant Licensing Branch II
To: Coleman J
Southern Nuclear Operating Co
References
EPID L-2023-LLA-0018
Download: ML23263A985 (15)


Text

October 12, 2023 Ms. Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2, ISSUANCE OF AMENDMENTS NOS. 221 AND 204, REGARDING TECHNICAL SPECIFICATION 5.5.11.c, ACCEPTANCE CRITERIA FOR CHARCOAL FILTER TESTING (EPID L-2023-LLA-0018)

Dear Ms. Coleman:

The Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 221 to Renewed Facility Operating License NPF-68 and Amendment No. 204 to Renewed Facility Operating License NPF-81 for the Vogtle Electric Generating Plant (Vogtle), Units 1 and 2, respectively. The amendments consist of changes to the License and technical specifications (TSs) in response to your application dated February 9, 2023.

The amendments revise TS 5.5.11, Ventilation Filter Testing Program (VFTP). Specifically, the amendments revise the acceptance criteria for the charcoal adsorber penetration for the Control Room Emergency Filtration System (CREFS) item number 5.5.11.c from 0.2-percent to 0.5-percent.

A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.

Sincerely,

/RA/

John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosures:

1. Amendment No. 221 to NPF-68
2. Amendment No. 204 to NPF-81
3. Safety Evaluation cc: Listserv

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-424 VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 221 Renewed License No. NPF-68

1.

The Nuclear Regulatory Commission (NRC, the Commission) has found that:

A.

The application for amendment to the Vogtle Electric Generating Plant, Unit 1 (the facility) Renewed Facility Operating License No. NPF-68 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated February 9, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-68 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 221, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-68 and the Technical Specifications Date of Issuance: October 12, 2023 Glenn E.

Miller Digitally signed by Glenn E. Miller Date: 2023.10.12 13:13:11 -04'00'

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-425 VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 204 Renewed License No. NPF-81

1.

The Nuclear Regulatory Commission (NRC, the Commission) has found that:

A.

The application for amendment to the Vogtle Electric Generating Plant, Unit 2 (the facility) Renewed Facility Operating License No. NPF-81 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated February 9, 2023, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I; D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-81 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 204, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 180 days of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-81 and the Technical Specifications Date of Issuance: October 12, 2023 Glenn E.

Miller Digitally signed by Glenn E. Miller Date: 2023.10.12 13:13:34 -04'00'

ATTACHMENT VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 TO LICENSE AMENDMENT NO. 221 RENEWED FACILITY OPERATING LICENSE NO. NPF-68 DOCKET NO. 50-424 AND TO LICENSE AMENDMENT NO. 204 RENEWED FACILITY OPERATING LICENSE NO. NPF-81 DOCKET NO. 50-425 Replace the following pages of the Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License License No. NPF-68, page 4 License No. NPF-68, page 4 License No. NPF-81, page 3 License No. NPF-81, page 3 TSs TSs 5.5-12 5.5-12 Renewed Operating License NPF-68 Amendment No. 221 (1)

Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2)

Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 221, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4)

Deleted (5)

Deleted (6)

Deleted (7)

Deleted (8)

Deleted (9)

Deleted (10)

Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a)

Fire fighting response strategy with the following elements:

1.

Pre-defined coordinated fire response strategy and guidance

2.

Assessment of mutual aid fire fighting assets

3.

Designated staging areas for equipment and materials

4.

Command and control

5.

Training and response personnel (b)

Operations to mitigate fuel damage considering the following:

1.

Protection and use of personnel assets

2.

Communications

3.

Minimizing fire spread

4.

Procedures for Implementing integrated fire response strategy

5.

Identification of readily-available pre-staged equipment

6.

Training on integrated fire response strategy Renewed Operating License NPF-81 Amendment No. 204 (2)

Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia, pursuant to the Act and 10 CFR Part 50, to possess but not operate the facility at the designated location in Burke County, Georgia, in accordance with the procedures and limitations set forth in this license; (3)

Southern Nuclear, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as my be produced by the operation of the facility authorized herein.

C.

This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter 1 and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below.

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 204 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance requirements (SRs) contained in the Appendix A Technical Specifications and listed below are not required to be performed immediately upon implementation of Amendment No. 74. The SRs listed below shall be

Programs and Manuals 5.5 (continued)

Vogtle Units 1 and 2 5.5-12 Amendment No. 221 (Unit 1)

Amendment No. 204 (Unit 2) 5.5 Programs and Manuals 5.5.11 Ventilation Filter Testing Program (VFTP) (continued)

ESF Ventilation System Flow Rate CREFS 19,000 CFM PPAFES 15,500 CFM c.

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than or equal to the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30°C and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH CREFS

.5%

70%

PPAFES 10%

95%

d.

Demonstrate for each of the ESF systems that the pressure drop across the combined HEPA filters, the charcoal adsorbers, and CREFS cooling coils is less than the value specified below when tested in accordance with Regulatory Guide 1.52, Revision 2, and ASME N510-1989 at the system flow rate specified below +/- 10%.

ESF Ventilation System Delta P Flow Rate CREFS 7.1 in.

19,000 CFM water gauge PPAFES 6 in.

15,500 CFM water gauge e.

Demonstrate that the heaters for the CREFS dissipate 95 kW when corrected to 460 V when tested in accordance with ASME N510-1989.

The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the VFTP test frequencies.

5.5.12 Explosive Gas and Storage Tank Radioactivity Monitoring Program This program provides controls for potentially explosive gas mixtures contained in the Gaseous Waste Processing System, the quantity of radioactivity contained in each Gas Decay Tank, and the quantity of radioactivity contained in

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 221 TO RENEWED FACILITY OPERATING LICENSE NPF-68 AND AMENDMENT NO. 204 TO RENEWED FACILITY OPERATING LICENSE NPF-81 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425

1.0 INTRODUCTION

By letter dated February 9, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23040A432), Southern Nuclear Operating Company, Inc. (SNC, the licensee), requested changes to the technical specifications (TSs) for the Vogtle Electric Generating Plant (Vogtle), Units 1 and 2.

The proposed amendments revise TS 5.5.11, Ventilation Filter Testing Program (VFTP).

Specifically, the amendments revise the acceptance criteria for the charcoal adsorber penetration for the Control Room Emergency Filtration System (CREFS) item number 5.5.11.c from 0.2-percent to 0.5-percent.

2.0 REGULATORY EVALUATION

2.1 Proposed TS Changes

2.1.1 Current TS 5.5.11.c The current TS 5.5.11.c states:

Demonstrate for each of the ESF [engineered safety features] systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2 [Design, Testing and Maintenance Criteria for Post-Accident Engineered-Safety-Feature Atmosphere Cleanup System Air Filtration and Adsorption Units of Light-Water-Cooled Nuclear Power Plants, March 1978], shows the methyl iodide penetration less than or equal to the value specified below when tested in accordance with ASTM [American Society of

Testing and Materials] D3803-1989 1989 [Standard Test Method for Nuclear-Grade Activated Carbon] at a temperature of 30 oC [degrees Celsius] and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH CREFS

.2%

70%

PPAFES 10%

95%

[Piping Penetration Area Filtration and Exhaust]

2.1.2 Proposed TS 5.5.11.c The proposed TS 5.5.11.c would state:

Demonstrate for each of the ESF systems that a laboratory test of a sample of the charcoal adsorber, when obtained as described in Regulatory Guide 1.52, Revision 2, shows the methyl iodide penetration less than or equal to the value specified below when tested in accordance with ASTM D3803-1989 at a temperature of 30 oC and greater than or equal to the relative humidity specified below.

ESF Ventilation System Penetration RH CREFS

.5%

70%

PPAFES 10%

95%

2.2 Regulatory Evaluation The U.S. Nuclear Regulatory Commission (NRC) staffs evaluation is based upon the following regulations, Regulatory Guides (RGs), and standards:

Title 10 of the Code of Federal Regulations (10 CFR) Section 50.36, Technical specifications.

NRC RG 1.196, Control Room Habitability at Light-Water Nuclear Power Reactors, Revision 1, January 2007 (ML063560144).

NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [light-water reactor] Edition:

o Section 6.4, Control Room Habitability System, Revision 3, March 2007 (ML070550069),

o Section 6.5.2, Containment Spray as a Fission Product Cleanup System, Revision 4, March 2007 (ML070190178),

o Section 15.0.1, Radiological Consequence Analyses Using Alternative Source Terms, Revision 0, July 2000 (ML003734190), and o Section 16.0, Technical Specifications, Revision 3, March 2010 (ML100351425).

Generic Letter 99-02, Laboratory Testing of Nuclear-Grade Activated Charcoal, June 3, 1999 (ML082350935).

3.0 TECHNICAL EVALUATION

).

3.1 Credited Charcoal Filter Efficiencies SNC proposes to revise TS 5.5.11 to change the charcoal adsorber penetration acceptance criteria for CREFS, item number 5.5.11.c from 0.2-percent to 0.5-percent.

In Section 3.1, Basis for the change, of Enclosure to the SNC letter dated February 9, 2023, SNC states the following:

The analyses of design-basis accidents assume a particular engineered safety features (ESF) charcoal filter adsorption efficiency when calculating offsite and control room operator doses. The particular parameter defined in the UFSAR

[Updated Final Safety Analysis Report] safety analysis is the iodine removal efficiency for all forms of iodine. The assumed efficiency is 99%. A conservative factor of safety was used to determine the current CREFS TS limit of 0.2%

based on the RG 1.52 Rev. 2 criteria. Laboratory tests are conducted on charcoal adsorbers samples to verify that the adsorber efficiency is greater than the minimum limit. The laboratory test acceptance criteria contain a safety factor to ensure that the efficiency assumed in the accident analysis is still met at the end of the operating cycle. TS 5.5.11.c defines the testing method and the acceptance criteria for CREFS charcoal adsorber testing which confirms they perform as designed in the case of accident.

The NRC staff confirmed that Vogtle Final Safety Analysis Report (FSAR) Table 6.4.2-1, Performance Characteristics of Major System Components, lists the charcoal absorber efficiency of control building control room filter units as 99-percent at 70-percent relative humidity (RH) (for elemental and organic iodine). SNC is proposing to change only the charcoal adsorber penetration acceptance criteria, while keeping the charcoal adsorber efficiency and the method of testing the same. The proposed increase in the charcoal adsorber penetration acceptance criteria from 0.2-percent to 0.5-percent, resulted from lowering the safety factor assumed in the analysis. Therefore, the NRC staff evaluated the acceptability of the safety factor assumed for the proposed acceptance criteria.

GL 99-02 allows licensees that use ASTM D3803-1989 for laboratory testing to use a safety factor as low as 2 for determining the acceptance criteria for charcoal filter efficiency. The GL 99-02 states that [t]his safety factor can be used for systems with or without humidity control because the lack of humidity control is already accounted for in the test conditions (systems without humidity control test at 95 percent RH and systems with humidity control can test at 70 percent RH).

By letter dated September 20, 1999 (ML20212E875), SNC stated the following:

Vogtle Electric Generating Plant (VEGP) TSs incorporate a requirement to perform charcoal sample testing in accordance with ASTM D3803-1989.

By letter dated May 24, 2000 (ML003717945), the NRC staff reviewed SNCs response to GL 99-02 dated September 20, 1999, and the NRC staff concluded that all requested information was provided; therefore, the NRC staff considered GL 99-02 to be closed for Vogtle, Units 1 and 2.

As stated in the Enclosure to the SNC letter dated February 9, 2023, SNC used the following equation for determining the allowable (charcoal) penetration (percent), which is based on the required retention (absorption) efficiency in the licensees safety analysis (i.e., FSAR), and an applied safety factor.

Allowable Penetration = (100% - Organic Iodide Efficiency for Activated Carbon Credited in Licensees Accident Analysis) / (Safety Factor)

Substituting the required 99-percent absorber efficiency from the Vogtle analysis and a safety factor of 2, the allowed penetration becomes (100-percent percent) / 2 = 0.5-percent.

Since the 99-percent absorber efficiency is in the Vogtle licensing basis and a safety factor of 2 is allowed in GL 99-02 for the licensees using ASTM D3803-1989 for laboratory testing, the NRC staff finds that the proposed change of the charcoal adsorber penetration efficiency for CREFS to 0.5-percent acceptable.

3.2 Review of Proposed TS Changes 3.2.1 Changes to TS 5.5.11.c The current and proposed TS 5.5.11.c are described in detail in Section 2.1 above. The proposed amendments revise the acceptance criteria for the charcoal adsorber penetration for CREFS item number 5.5.11.c from 0.2-percent to 0.5-percent.

The NRC staff reviewed the proposed change and determined, based on the preceding discussion, that the TS 5.5.11.c, as revised by the proposed change, meets the standards for TSs in 10 CFR 50.36(b) and 10 CFR 50.36(c). Additionally, the change to the TSs were reviewed for technical clarity and consistency with customary terminology and format in accordance with SRP Chapter 16.0 and were found to be acceptable. The NRC staff concludes that the TSs, as amended by the proposed change, meets the requirements stated in 10 CFR 50.36 and is acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on September 17, 2023. On September 19, 2023, the State official confirmed that the State of Georgia had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change the requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 [and change surveillance requirements]. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration published in the Federal Register on March 21, 2023 (88 FR 17037), and there has been no public comment on such finding.

Accordingly, the amendments meet 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 amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Hanry Wagage and John Lamb.

Date: October 12, 2023

ML23263A985 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DORL/LA NAME AJohnson KGoldstein ABaxter DATE 09/21/2023 09/21/2023 09/21/2023 OFFICE NRR/DSS/SCPB/BC NRR/DSS/STSB/BC NRR/DEX/EMIB/BC NAME BWittick MJardaneh (A)

SBailey DATE 09/19/2023 09/21/2023 09/29/2023 OFFICE OGC - NLO NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MCarpentier MMarkley (EMiller for)

JLamb DATE 10/05/2023 10/12/2023 10/12/2023