ML24101A211
| ML24101A211 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/11/2024 |
| From: | Markley M NRC/NRR/DORL/LPL2-1 |
| To: | Coleman J Southern Nuclear Operating Co |
| Lamb J, NRR/DORL/LPL2-1 | |
| References | |
| EPID L-2024-LLA-0043 TS 5.5.13 | |
| Download: ML24101A211 (1) | |
Text
May 11, 2024
Jamie M. Coleman, Director Fleet Regulatory Affairs Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway, Bin N-226-EC Birmingham, AL 35243
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNIT 3 ISSUANCE OF AMENDMENT NO. 198 RE: CHANGE TO TECHNICAL SPECIFICATION 5.5.13, VENTILATION FILTER TESTING PROGRAM (VFTP) (EPID L-2024-LLA-0043)
Dear Jamie Coleman:
In response to your letter dated April 4, 2024, the U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 198 to Combined License (COL) No. NPF-91 for the Vogtle Electric Generating Plant (Vogtle) Unit 3. The amendment changes technical specification (TS) 5.5.13, Ventilation Filter Testing Program (VFTP), to provide an exception to the 24-month testing frequency. The exception proposes to defer the next required performance until prior to startup from the first refueling outage. This exception would apply to in-place penetration and system bypass testing of the high efficiency particulate air (HEPA) filter, in-place penetration and system bypass testing of the charcoal adsorber, and pressure drop testing across the HEPA filter, the charcoal adsorber, and the post filter, as specified in TS 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4, respectively.
A copy of the related Safety Evaluation, which includes the NRC staffs evaluation of the amendment, is enclosed. The notice of issuance of the amendment documents included in this letter will be published in the Federal Register.
Sincerely,
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Regulation Office of Nuclear Reactor Regulation
Docket No.: 52-025
Enclosures:
- 1. Amendment No. 198 to Vogtle, Unit 3, COL
- 2. Safety Evaluation
cc: ListServ SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY
OGLETHORPE POWER CORPORATION
MEAG POWER SPVM, LLC
MEAG POWER SPVJ, LLC
MEAG POWER SPVP, LLC
CITY OF DALTON, GEORGIA
VOGTLE ELECTRIC GENERATING PLANT, UNIT 3
DOCKET NO.52-025
AMENDMENT TO FACILITY COMBINED LICENSE
Amendment No. 198 License No. NPF-91
- 1. The Nuclear Regulatory Commission (the Commission) has found that:
A. The application for amendment by Southern Nuclear Operating Company (SNC),
dated April 4, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I;
B. The facility will be constructed and 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 Commissions regulations;
D. The issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public; and
E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations, and all applicable requirements have been satisfied.
Enclosure 1
- 2. The license is also amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment.
Paragraph 2.D(8) of facility Combined License No. NPF-91 is hereby amended to read as follows:
(8) Incorporation
The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 198, are hereby incorporated into this license.
- 3. This license amendment is effective as of the date of its issuance and shall be implemented upon issuance.
FOR THE NUCLEAR REGULATORY COMMISSION:
Michael Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Date of Issuance: May 11, 2024
Attachment:
Page 7 of the facility Combined License and affected pages of Appendix A, Technical Specifications
ATTACHMENT TO LICENSE AMENDMENT NO. 198
TO FACILITY COMBINED LICENSE NO. NPF-91
VOGTLE ELECTRIC GENERATING PLANT, UNIT 3
DOCKET NO.52-025
Replace the following pages of the Facility Combined License No. NPF-91 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
REMOVE INSERT
License License NPF-91, page 7 NPF-91, Page 7
TS TS
5.5-11 5.5-11
Attachment (7) 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 Directors designee, in accordance with 10 CFR 50.59(d).
(b) SNC shall report any violation of a requirement in Section 2.D.(3),
Section 2.D.(4), Section 2.D.(5), and Section 2.D.(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.
(8) Incorporation
The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 198, 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 (ITAAC) are met in accordance with 10 CFR 52.103(g).
(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;
- 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
7 Amendment No. 198 Technical Specifications Programs and Manuals 5.5
5.5 Programs and Manuals
5.5.13 Ventilation Filter Testing Program (VFTP)
- a. A program shall be established to implement the following required testing of the VES.
Tests described in Specification 5.5.13.a.1 and 5.5.13.a.2 shall be performed: i) initially, ii) once each 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage, iii) after partial or complete replacement of a HEPA filter or charcoal adsorber, iv) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the filters, and v) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the system.
Tests described in Specification 5.5.13.a.3 shall be performed: i) after each 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation or at least once each 24 months, whichever comes first, ii) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the carbon media, and iii) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the carbon media.
Tests described in 5.5.13.a.4 shall be performed once per 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage.
- 1. Demonstrate for the VES that an inplace test of the high efficiency particulate air (HEPA) filter shows a penetration and system bypass 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 3, and ASME N510-1989 at a flow rate at least 600 cfm greater than the VES makeup flow rate.
Ventilation System Flow Rate
VES 600 + VES makeup flow rate (cfm)
- 2. Demonstrate for the VES that an inplace test of the charcoal adsorber shows a penetration and system bypass 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 3, and ASME N510-1989 at a flow rate at least 600 cfm greater than the VES makeup flow rate.
Ventilation System Flow Rate
VES 600 + VES makeup flow rate (cfm)
VEGP Units 3 and 4 5.5 - 11 Amendment No. 198 (Unit 3)
Amendment No. 181 (Unit 4)
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION
RELATED TO AMENDMENT NO. 198
TO COMBINED LICENSE NO. NPF-91
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY
OGLETHORPE POWER CORPORATION
MEAG POWER SPVM, LLC
MEAG POWER SPVJ, LLC
MEAG POWER SPVP, LLC
CITY OF DALTON, GEORGIA
VOGTLE ELECTRIC GENERATING PLANT, UNIT 3
DOCKET NO.52-025
1.0 INTRODUCTION
By letter dated April 4, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24095A354), Southern Nuclear Operating Company (SNC, the licensee) requested that the U.S. Nuclear Regul atory Commission (NRC) amend Vogtle Electric Generating Plant (Vogtle), Unit 3, Combined Licens e (COL) Number NPF-91. Specifically, SNC submitted a license amendment request (LAR) to change technical specification (TS) 5.5.13, Ventilation Filter Testing Program (VFTP), to provide an exception to the 24-month testing frequency. The proposed exception would defer the next required performance until prior to startup from the first refueling outage (RFO). This exception would apply to in-place penetration and system bypass testing of the high efficiency particulate air (HEPA) filter, in-place penetration and system bypass testing of the charcoal adsorber, and pressure drop testing across the HEPA filter, the charcoal adsorber, and the post filter, as specified in TS 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4, respectively.
Enclosure 2
2.0 REGULATORY EVALUATION
2.1 Regulations and Guidance
Regulations
The NRC regulatory requirements related to the content of the TSs are contained in 10 CFR 50.36, Technical specifications. As required by 10 CFR 50.36(c)(3), TSs will include surveillance requirements, which are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The regulations in 10 CFR 50.36(c)(5), Administrative controls, state, in part, that:
Administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.
Pursuant to 10 CFR 50.90, Application for amendment of license, construction permit, or early site permit, states, in part, that, Whenever a holder of a license, including a construction permit and operating license under this part, and an early site permit, combined license, and manufacturing permit under part 52 of this chapter, desires to amend the license or permit, application for an amendment must be filed with the Commission.
Appendix A to Part 50, General Design Criteria for Nuclear Power Plants, Criterion 19 - Control room, states:
A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.
Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident. Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.
Applicants for and holders of construction permits and operating licenses under this part who apply on or after January 10, 1997, applicants for design approvals or certifications under part 52 of this chapter who apply on or after January 10, 1997, applicants for and holders of combined licenses or manufacturing licenses under part 52 of this chapter who do not reference a standard design approval or certification, or holders of operating licenses using an alternative source term under § 50.67, shall meet the requirements of this criterion, except that with regard to control room access and occupancy, adequate radiation protection shall be provided to ensure that radiation
exposures shall not exceed 0.05 Sv (5 rem) total effective dose equivalent (TEDE) as defined in § 50.2 for the duration of the accident.
The regulation 10 CFR 50.34(f)(2)(xxviii) states:
Evaluate potential pathways for radioactivity and radiation that may lead to control room habitability problems under accident conditions resulting in an accident source term11 release, and make necessary design provisions to preclude such problems. (III.D.3.4) 11.
11 The fission product release assumed for these calculations should be based upon a major accident, hypothesized for purposes of site analysis or postulated from considerations of possible accidental events, that would result in potential hazards not exceeded by those from any accident considered credible. Such accidents have generally been assumed to result in substantial meltdown of the core with subsequent release of appreciable quantities of fission products.
Guidance
NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition, Section 16.0, Revision 3, Technical Specifications, March 2010 (ML100351425), contains review guidance for NRC staff review of TSs.
The updated final safety analysis report (UFSAR) (ML23165A215) for Vogtle, Units 3 and 4, incorporate the Design Control Document for a simplified passive advanced LWR plant provided by Westinghouse Electric Company, the entity originally sponsoring and obtaining the AP1000 design certification documented in 10 CFR Part 52, Appendix D, Design Certification Rule for the AP1000 Design.
3.0 TECHNICAL EVALUATION
3.1 System Description and Operation
The letter dated April 4, 2024, states:
As described in VEGP [Vogtle Electric Generating Plant] Updated Final Safety Analysis Report (UFSAR) Subsection 9.4.1.1, Safety Design Basis, the nuclear island nonradioactive ventilation system (VBS) normally serves the main control room (MCR). VBS is designed to control the radiological habitability in the MCR within the guidelines presented in Standard Review Plan (SRP) 6.4, Control Room Habitability System, when AC power is available. This includes providing a reliable source of heating, ventilation, and cooling to the MCR (and other areas served) when AC power is available. The system equipment and component functional capabilities minimize the potential for actuation of the main control room emergency habitability system (VES) or the potential reliance on passive equipment cooling. This is achieved through the use of redundant equipment and components that are connected to standby onsite AC power sources.
The VES operation in maintaining the MCR habitable is discussed in UFSAR Section 6.4, Habitability Systems. The Engineered Safeguards Feature (ESF)
VES provides a protected environment from which operators can control the plant following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The system is designed to operate following a Design Basis Accident (DBA) that requires protection from the release of radioactivity. In these events, VBS would continue to function if AC [alternating current] power is available. VES is actuated and the MCR pressure boundary isolated on either a High-2 particulate or iodine signal in the VBS s upply ducting, a sustained loss of control room differential pressure, a sustained loss of all AC power, or manually by the operators.
3.2 Proposed Changes
SNC proposes to change TS 5.5.13 to provide an exception to the 24-month testing frequency.
The proposed exception would defer the next required performance until prior to startup from the first RFO. This exception would apply to in-place penetration and system bypass testing of the HEPA filter, in-place penetration and system bypass testing of the charcoal adsorber, and pressure drop testing across the HEPA filter, the charcoal adsorber, and the post filter, as specified in TS 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4, respectively.
The changes proposed by SNC to the TS 5.5.13 are described below:
Current TS 5.5.13.a states, in part, that:
Tests described in Specification 5.5.13.a.1 and 5.5.13.a.2 shall be performed:
i) initially, ii) once each 24 months, iii) after partial or complete replacement of a HEPA filter or charcoal adsorber, iv) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the filters, and v) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the system.
Revised TS 5.5.13.a, would state, in part, that:
Tests described in Specification 5.5.13.a.1 and 5.5.13.a.2 shall be performed:
i) initially, ii) once each 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage, iii) after partial or complete replacement of a HEPA filter or charcoal adsorber, iv) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the filters, and v) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the system.
Current TS 5.5.13.a states, in part, that:
Tests described in 5.5.13.a.4 shall be performed once per 24 months.
Revised TS 5.5.13.a would state, in part, that:
Tests described in 5.5.13.a.4 shall be performed once per 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage.
3.3 Reason for Proposed Changes
Section 2.3 of the LAR states the following:
TS 3.7.6, Main Control Room Emergency Habitability System (VES), and its Surveillance Requirement (SR) 3.7.6.10 (Perform required VES Passive Filtration system filter testing in accordance with the Ventilation Filter Testing Program (VFTP)) require operability of the filtration train to protect the control room operator, and when the filtration train is inoperable at power, entry into Condition F (second portion), VES inoperable for reasons other than Condition A, B, C, D, or E in MODE 1, 2, 3, or 4, is required, which imposes the Required Actions to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
The testing required by TS 5.5.13.a for 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4 for VEGP Unit 3 was last performed on November 11, 2021. As provided in TS 5.5.13.b, the provisions of Surveillance Requirement (SR) 3.0.2 apply and result on May 11, 2024 being the latest time for performance of the next required test. At this time, Unit 3 is at 100% power, and is anticipated to remain at power until the refueling outage currently planned for the fourth quarter 2024. This results in the necessity to perform these tests while at power. Performance of these tests requires access to the filtration train such that it results in the inoperability of the filtration train when in Modes 1, 2, 3, and 4, and the resultant requirement (in accordance with TS 3.7.6 Action F) to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> solely due to the performance of the test.
As described and approved in NRC Final Safety Evaluation Report (FSER),
Supplement 2 (ADAMS Accession No. ML112061231), subsection 6.4.2.2.6, Evaluation of the Single Failure of the Passive Filtration Line, VES filtration is a single-train passive feature. It is assumed to function during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an accident. Any inoperability of this filtration train in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a loss of that assumed safety function. As such, SNC proposes to defer the required periodic VFTP testing to the next scheduled outage, where in Mode 5 or 6, or defueled, and not moving irradiated fuel, VES operability is not required. This reflects a more appropriate time to perform periodic testing on the single train ESF filtration train.
Section 2.3 also states that:
Testing of single-train ESF systems that would require introducing a loss of an assumed safety function at power should only be required during periods when that safety function is not assumed; Mode 5 or 6, or defueled, and not moving irradiated fuel. For VES and the VFTP test proposed for deferral, the 24-month testing frequency provides the flexibility to schedule the testing during a refueling outage shutdown. However, since VEGP Unit 3 experienced an extended startup and testing program, the period between the initial performance and the
subsequent 24-month required performance does not allow reaching the first refueling outage without exceeding the Surveillance grace period defined in TS SR 3.0.2. Prior to these delays, the first refueling outage was projected such that the VFTP testing would have been performed during the refueling outage.
The licensee states that TS SR 3.0.3 provides provisions for unplanned discoveries of missed Surveillances and states that while the current situation is not an unplanned discovery, and therefore, SR 3.0.3 is not being used, provisions in SR 3.0.3 provide guidance applicable to evaluating the acceptability of deferring a surveillance. SR 3.0.3 states, in part, that:
If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO [limiting conditions for operation] not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, whichever is greater.
This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
The licensee also stated that Bases for SR 3.0.3 also provides:
The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements....
... While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.
The licensee also states that the portion of SR 3.0.3 that allows the greater delay of up to the limit of the specified Frequency and the portion A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed were included in the Vogtle, Unit 3, original issued COL and originated from TSTF-358, Missed Surveillance Requirements.
The licensee states that Vogtle, Unit 3, passed the initial VFTP performance with significant margin and has operated satisfactorily for TS SR 3.7.6.3 monthly required testing. SNC states that the prior testing margin, satisfactory monthly runs, and the lack of activities that could have affected the filtration train status provides the reasonable expectation that the tests will be met when performed.
3.4 NRC Staff Evaluation
The VES provides emergency ventilation and pressurization for the MCR. The MCR emergency habitability system also provides emergency passive heat sinks for the MCR, instrumentation and control rooms, and direct current (dc) equipment rooms. The licensee stated that, VES consists of 32 compressed air storage tanks arranged in four banks of eight tanks each, two air delivery flow paths, an eductor, a filtration flow path, and associated valves or dampers, piping, and instrumentation. The main control room passive filtration flow path contains a high-efficiency particulate (HEPA) filter in series with a charcoal adsorber and a postfilter.
During normal operation, the VES is a standby emergency system. The system is designed to operate following accidents that requires protection of the control room inhabitants from the release of radioactivity. Non-safety VBS supports normal heating, ventilation, and air-conditioning service to the MCR, control support area, instrumentation and control rooms, dc equipment rooms, battery rooms, and the nucle ar island nonradioactive ventilation system equipment room when AC power is available. Although non-safety, the VBS is expected to be available during the requested deferred period. Section 2.1 of the LAR indicates, As described in UFSAR subsection 6.4.4, System Safety Evaluation, in the event of an accident involving the release of radioactivity to the environm ent, VBS is expected to switch from the normal operating mode to the supplemental air filtration mode to protect the main control room personnel. Although the VBS is not a safety-related system, it is expected to be available to provide the necessary protection for realistic events.
Vogtle, Unit 3, TS 3.7.6, requires operability of the overall MCR VES and SR 3.7.6.10 requires performance of periodic MCR filtration system testing in accordance with the VFTP defined in TS 5.5.13. In accordance with SR 3.7.6.10 for VES filtration function, Vogtle, Unit 3, must successfully perform VFTP and meet requirements specified in TS 5.5.13 to ensure operability of the overall VES to protect the control room operator. The VFTP requirements are defined in TS 5.5.13 of Program and Manuals section of TS. As stated previously, the VES contains a single filtration train which challenges the abi lity to perform VFTP during normal operating conditions. When the filtration train is inoperable at power, entry into Condition F, VES inoperable for reasons other than Condition A, B, C, D, or E in MODE 1, 2, 3, or 4, is required, which imposes the Required Actions to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
In Section 4.3 of its submittal, the licensee stated that the exception would apply to inplace penetration and system bypass testing of the HEPA filter, inplace penetration and system bypass testing of the charcoal adsorber, and pre ssure drop testing across the HEPA filter, the charcoal adsorber, and the post filter, as specified in TS 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4, respectively. SNC proposes to accomplish the desired change by modifying the introductory portion of 5.5.1.3.a. In its submittal, SNC expressed the belief that the VFTP test could be performed satisfactorily within the time allowed by TS 3.7.6 Action F but have concerns with recently identified scenarios where there is an unanticipated delay(s) once the system has been removed from service for testing. SNC stated that, With only 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to complete the test and return the filtration train system to operable status, any unanticipated testing setup difficulties, or unanticipated results caused by an improper test setup configuration, could challenge completing the testing and restoration activities within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and would increase the likelihood of an unnecessary shutdown of the plant.
To meet GDC 19 requirements, the Vogtle VFTP program was established to require periodic verification testing of the MCR VES filtration component capabilities. The VFTP program includes testing the performance of the HEPA filter, charcoal adsorbers, minimum flow rate, and physical
properties of the activated charcoal. Specific test frequencies and additional information are discussed in detail in the VFTP. TS 5.5.13 requires the VFTP testing performed once each 24 months. As indicated in TS 5.5.13.b, the provisions of SR 3.0.2 are applicable to the VFTP test frequencies. SR 3.0.2 allows the specified frequency for SR is met if performed within 1.25 times the interval specified, as measured from the previous performance, or as measured from the time a specified condition of the frequency is met. As described in its submittal, SNC is unable to perform the VFTP testing for Vogtle, Unit 3, by the required maximum 30-month SR interval that would represent 1.25 times the 24-month interval in the relevant TS and is, therefore, requesting an exception to allow testing during the first refueling outage. The exception is requested for Cycle 1 and requests to defer the next required performance until prior to startup from the first refueling outage currently planned for the fourth quarter 2024. This could result in addition 20-25 percent plant operation prior to performing VFTP required testing.
SNC provided results of the initial VFTP tests for Vogtle, Unit 3. The tests performed for VFTP penetration and leakage testing included HEPA filter (TS 5.5.13.a.1) and the charcoal adsorber (TS 5.5.13.a.2) and were dated November 21, 2021. The test performed for measuring the pressure drop across the combined HEPA filter, charcoal adsorber, and post filter (TS 5.5.13.a.4) was also dated November 11, 2021. SNC also provided results of a test sample of the charcoal adsorber for methyl iodide penetration (TS 5.5.13.a.3) dated July 20, 2022, and stated that it is not the subject of the LAR request for deferral, indicating that the current charcoal adsorber sample test periodicity of 24 months will be maintained. The NRC staff reviewed of all the test results and determined that there is sufficient margin between the required values and the test results.
SNC did not provide exact dates for the first refueling outage but did state that the refueling outage is currently planned for the 4th quarter of 2024. After taking into consideration the provisions of SR 3.0.2, this could result in a one-time extension from the initial tests to the proposed first refueling outage testing of approx imately 6 months beyond the 30-month SR requirement discussed above.
The NRC staff reviewed the impact on the performanc e of the filters during the extended period of operation in between the tests, one of which is accumulation of foreign matter in the VES filter train. During normal operation, the VBS is operating to provide cooling to the MCR, when the VES is idle except for short periods of monthly testing required by SR 3.7.6.3. There are no direct connections between the VBS and VES systems by ventilation ducts or other means. The VBS is equipped with its own filters. The VES system is tested monthly for 15 minutes or more.
During the monthly testing, air supply to VES is from compressed air tanks, which is considered a clean supply and unlikely to cause any degradation of the filters. With this setup, any impact by intrusion of foreign matter on the VES filt er train during the extended period of normal operation, if any, is minor.
During the exception period of the proposed amendment, all requirements of TS 3.7.6, SR 3.7.6.3, and TS 5.5.13 program will remain applicable regarding the filtration system. If there are adverse conditions such as water intrusion, painting, fire or chemical release communicating with VES, VFTP tests in accordance with TS 5.5.13.a.3 would be conducted. Inability to conduct those tests as required by TS 5.5.13 would result in the end state of that SR failure.
Based on Vogtle, Unit 3, being a new plant with limited usage or demand on the VES system, the NRC finds that the filtration systems are not expected to result in a significant degraded condition impacting the VES safety function. The VES passed the initial VFTP tests with significant margin and the system has operated satisfactorily for TS SR 3.7.6.3 monthly required
testing. Based on the above, the NRC staff finds reasonable assurance that the surveillance will be met when performed, the health and safety of the public will be maintained, and the MCR staff will not be endangered by operation in the proposed manner. Therefore, the NRC staff finds there is reasonable assurance that the one-time exception to postpone testing to be performed prior to startup from first refueling outage is acceptable.
In the very unlikely event of an accident where the operators are forced to abandon the MCR, FSAR Section 3.1.2 describes the availability of a workstation providing remote shutdown capability. The remote shutdown workstation is described in Section 7.4 of FSAR.
SNC indicates that performance of these tests requires specially trained and qualified personnel it does not employ and that SNC schedules qualified contract services to perform these tests, which require advanced planning for availability. This exception is only approved for Vogtle, Unit 3, Cycle 1, prior to startup from first refueling outage. Future surveillances are expected to be conducted with proper planning, personnel, preparation, and appropriate plant conditions to perform these tests once each 24 months, as required by TS 5.5.13 VFTP program.
Based on the above, the NRC staff concludes that the proposed changes to TS 5.5.13 provide reasonable assurance that the one-time exception to the 24-month testing frequency and the grace period provided in SR 3.0.2, would continue to ensure operation of the facility in a safe manner. Therefore, the NRC staff concludes that the TS 5.5.13 proposed changes will continue to meet 10 CFR 50.36(c)(3) and (c)(5) and Part 50, Appendix A, Criterion 19.
4.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION
The NRCs regulation in 10 CFR 50.92(c) states that the NRC may make a final determination, under the procedures in 10 CFR 50.91, that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:
(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.
An evaluation of the issue of no significant hazards consideration is presented below:
- 1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?
Response: No
The proposed change relaxes the time allowed to perform a Surveillance.
The time between Surveillances is not an initiator to any accident previously evaluated. Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be operable and capable of performing the accident mitigation function assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly affected.
Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.
- 2. Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?
Response: No
The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.
Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.
- 3. Does the proposed change involve a significant reduction in a margin of safety?
Response: No
The relaxed time allowed to perform a Surveillance does not result in a significant reduction in the margin of safety. As supported by the historical data, the likely outcome of any Surveillance is verification that the requirement is met. Failure to perform a Surveillance within the currently prescribed Frequency does not cause equipment to become inoperable. The only effect of the additional time allowed to perform the Surveillance on the margin of safety is the extension of the time until inoperable equipment is discovered to be inoperable by the missed Surveillance. Balancing the rare occurrence of an undiscovered inoperability against the actual risk of manipulating the plant equipment to perform the Surveillance, leads to a conclusion of enhanced plant safety margins. In addition, the diesel-backed normal ventilation system can perform the safety function of the filtration train should there be an undiscovered inoperability. Thus, there is confidence that plant safety margins are maintained.
Therefore, the proposed change does not involve a significant reduction in a margin of safety.
Based on the above evaluation, the NRC staff concludes that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91.
5.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendment on April 8, 2024. On April 30, 2024, the State official replied that the State had no comments.
6.0 PUBLIC COMMENT
On April 10, 2024, the NRC staff published a "Notice of Consideration of Issuance of Amendments to Facility Operating Licenses, Pr oposed No Significant Hazards Consideration Determination, and Opportunity for a Hearing," in the Federal Register associated with the
proposed LAR (89 FR 25283). In accordance with the requirements in 10 CFR 50.91, the notice provided a 30-day period for public comment on the proposed no significant hazards consideration (NSHC) determination. A public comment was received regarding the proposed amendment (ML24102A187).
The NRC reviewed the subject comment and determined that it did not impact the NSHC, and no changes were made to the safety evaluation (SE).
7.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and changes surveillance requirements. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration on April 10, 2024 (89 FR 25283),
and there has been no public comment on such finding. 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.
8.0 CONCLUSION
The NRC staff has concluded, based on the considerations discussed in Section 3 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) there is reasonable assurance that 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, the NRC staff finds the changes propos ed in this license amendment acceptable.
Contributors: Andrea Russell, Gordon Curran, and Nagewara Karipineni.
Date: May 11, 2024
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