ML24289A200

NRR E-mail Capture - for Your Action - RAI - Proposed License Amendment Request (LAR) for Vogtle Electric Generating Plant, Units 3 and 4 TS 3.7.6 Action E and SR 3.7.6.5 (L-2024-LLA-0083)

ML24289A200
Person / Time
Site:	Vogtle
Issue date:	10/15/2024
From:	John Lamb Plant Licensing Branch II
To:	Lowery K Southern Nuclear Operating Co
References
L-2024-LLA-0083
Download: ML24289A200 (3)

Text

From: John Lamb Sent: Tuesday, October 15, 2024 2:50 PM To: Lowery, Ken G.

Cc: Joyce, Ryan M.

Subject:

For Your Action - RAI - Vogtle 3 and 4 - Proposed LAR TS 3.7.6 Action E and SR 3.7.6.5 (L-2024-LLA-0083)

Ken,

By letter dated June 21, 2024 (ADAMS Accession No. ML24173A220), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for Vogtle Electric Generating Plant, Units 3 and 4. The proposed amendment revises Combined License (COL)

Appendix A, Technical Specifications (TS) 3.7.6, Main Control Room Emergency Habitability System (VES), Surveillance Requirement (SR) 3.7.6.5 to refer to the Compressed Gas Association (CGA) G-7.1, Commodity Specification for Air, Grade E, for the requirements for acceptable compressed air quality in the VES air storage tanks. The LAR also proposes a change to TS 3.7.6, Action E to provide a more specific description of the VES inoperable condition due to compressed air storage tank volume below the limit.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required for the staff to complete its review. The NRC staff sent the draft requestion for additional information (RAI) on September 27, 2024, to determine if SNC needed a clarifying call. A clarifying was held on October 15, 2024. SNC said that it would responds to the RAI within 30 days of the date of this email.

If you have any questions, contact me.

John G. Lamb Senior Project Manager NRC/NRR/DORL/LPLII-1 (301) 415-3100

REQUEST FOR ADDITIONAL INFORMATION (RAI)

By letter dated June 21, 2024 (ADAMS Accession No. ML24173A220), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for Vogtle Electric Generating Plant, Units 3 and 4. The proposed amendment revises Combined License (COL)

Appendix A, Technical Specifications (TS) 3.7.6, Main Control Room Emergency Habitability System (VES), Surveillance Requirement (SR) 3.7.6.5 to refer to the Compressed Gas Association (CGA) G-7.1, Commodity Specification for Air, Grade E, for the requirements for acceptable compressed air quality in the VES air storage tanks. The LAR also proposes a change to TS 3.7.6, Action E to provide a more specific description of the VES inoperable condition due to compressed air storage tank volume below the limit.

The U.S. Nuclear Regulatory Commission (NRC) staff has determined that additional information is required for the staff to complete its review.

Regulatory Evaluation

General Design Criterion 19, "Control room," states, in part, that 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. Equipment at appr opriate 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.

Currently, Vogtle, Units 3 and 4, Updated Final Safety Analysis Report (UFSAR)

(ML23165A215) subsection 6.4.5.3 and TS Surveillance Requirement (SR) 3.7.6.5 describe the acceptance criterion of the air quality requirements for the VES Air Storage tanks to be based upon the current air quality limits specified in American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) 62-1989 standard in Table 1 and Appendix C, Table C-1.

SNC is proposing to replace this acceptance criterion in both areas with the CGA G-7.1-1997, Commodity Specification for Air, Grade E, for the purposes of establishing a sampling and testing periodicity for the VES tanks. However, in review of Table 1 of the CGA G-7.1-1997 standard, the following limiting characteristics for air pollutants are listed for Grade E without a maximum limiting characteristic as compared to what is provided for the ASHRAE 62 -1989 standard: nitrogen dioxide and sulfur dioxide. The NRC staff also observed that there are additional air pollutants with maximum limited characteristics for air quality in ASHRAE 62-1989 standard that are not listed under Grade E for the CGA G-7.1-1997 standard.

RAI #1

The NRC staff requests additional information on how SNC will account for the sampling and testing of air pollutants without maximum limiting characteristics in switching to the CGA G-7.1-1997 standard and how the provisions of the air quality as listed in the CGA G-7.1-1997 standard will be acceptable for operators in the Main Control Room if the VES tanks are activated.

RAI #2

In the Vogtle, Units 3 and 4, UFSAR, the licensee references NUREG-0700, Human-System Interface Design Review Guidelines, Revision 2. In requesting the change from the ASHRAE 62-1989 standard to the CGA G-7.1-1997 standard, the NRC staff requests that SNC provides the analysis of how the two areas cited in Section 12.1.2.2, Ventilation, which are air quantity and air velocity, will be impacted.

Hearing Identifier: NRR_DRMA Email Number: 2620

Mail Envelope Properties (MN2PR09MB508497C0C4DD463378FAFE62FA452)

Subject:

For Your Action - RAI - Vogtle 3 and 4 - Proposed LAR TS 3.7.6 Action E and SR 3.7.6.5 (L-2024-LLA-0083)

Sent Date: 10/15/2024 2:50:27 PM Received Date: 10/15/2024 2:50:00 PM From: John Lamb

Created By: John.Lamb@nrc.gov

Recipients:

"Joyce, Ryan M." <RMJOYCE@southernco.com>

Tracking Status: None "Lowery, Ken G." <KGLOWERY@southernco.com>

Tracking Status: None

Post Office: MN2PR09MB5084.namprd09.prod.outlook.com

Files Size Date & Time MESSAGE 4991 10/15/2024 2:50:00 PM

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