ML25034A221
| ML25034A221 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/24/2025 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| EPID L-2024-LLA-0083 | |
| Download: ML25034A221 (23) | |
Text
March 24, 2025 Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway, Bin N-274-EC Birmingham, AL 35243
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - ISSUANCE OF AMENDMENT TO REVISE TECHNICAL SPECIFICATION 3.7.6, MAIN CONTROL ROOM EMERGENCY HABITABILITY SYSTEM (VES), ACTIONS, CONDITION E AND SURVEILLANCE REQUIREMENT 3.7.6.5 (EPID NO. L-2024-LLA-0083)
Dear Jamie Coleman:
In response to your application dated June 21, 2024, as supplemented by letter dated October 28, 2024, the U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 200 and 196 to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, respectively. The amendment revises Technical Specifications (TS) 3.7.6, Main Control Room Emergency Habitability System (VES), Actions, Condition E, Required Actions E.1 and E.3, and Surveillance Requirement (SR) 3.7.6.5.
The amendments revise the COL Appendix A, TS 3.7.6, Actions, Condition E, Required Actions E.1 and E.3, concerning VES compressed air storage tanks compressed air not within limits and SR 3.7.6.5 to change the compressed air quality requirement specification from ASHRAE Standard 62, to Compressed Gas Association (CGA) CGA G-7.1-1997, Commodity Specification for Air, Grade E. The amendments also revise the Updated Final Safety Analysis Report (UFSAR) Subsection 6.4.5.3, Air Quality Testing.
A copy of the related safety evaluation is enclosed. The notice of issuance of the amendment documents included in this letter will be published in the Federal Register.
In accordance with Title 10 of the Code of Federal Regulations (10 CFR) Part 2, Agency Rules of Practice and Procedure, a copy of this letter will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records component of the NRCs Agencywide Documents Access and Management System (ADAMS).
ADAMS is accessible from the NRC website at http://www.nrc.gov/reading-rm/adams.html.
If you have questions, please contact me at 301-415-3100 or John.Lamb@nrc.gov.
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.: 52-025 and 52-026
Enclosures:
- 1. Amendment No. 200 to Vogtle, Unit 3, COL
- 2. Amendment No. 196 to Vogtle, Unit 4, COL
- 3. 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. 200 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 June 21, 2024, as supplemented by letter dated October 28, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's 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 Commission's 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 Commission's regulations, and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is amended to authorize changes to the Updated Final Safety Analysis Report (UFSAR) as described in the licensees application dated June 21, 2024, as supplemented by letter dated October 28, 2024. 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. Accordingly, the license is 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, Environmental Protection Plan, in Appendices A and B, respectively, of this license, as revised through Amendment No. 200, are hereby incorporated into this license.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance. The UFSAR changes shall be implemented in the next periodic update to the UFSAR in accordance with 10 CFR 50.71(e).
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:
Page 7 of the facility Combined License and affected pages of Appendix A of the facility Combined License Date of Issuance: March 24, 2025 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.03.24 14:50:48 -04'00'
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 4 DOCKET NO.52-026 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 196 License No. NPF-92
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment by Southern Nuclear Operating Company (SNC),
dated June 21, 2024, as supplemented by letter dated October 28, 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.
- 2.
Accordingly, the license is amended to authorize changes to the Updated Final Safety Analysis Report (UFSAR) as described in the licensees application dated June 21, 2024, as supplemented by letter dated October 28, 2024. 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-92 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. 196, are hereby incorporated into this license.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 60 days of the date of issuance. The UFSAR changes shall be implemented in the next periodic update to the UFSAR in accordance with 10 CFR 50.71(e).
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:
Page 7 of the facility Combined License and affected pages of Appendix C of the facility Combined License Date of Issuance: March 24, 2025 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.03.24 14:51:42 -04'00'
ATTACHMENT TO LICENSE AMENDMENT NOS. 200 AND 196 TO FACILITY COMBINED LICENSE NOS. NPF-91 AND NPF-92 DOCKET NOS.52-025 AND 52-026 Replace the following pages of the facility Combined License Nos. NPF-91 and NPF-92 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Facility Combined License No. NPF-91 REMOVE INSERT 7
7 Facility Combined License No. NPF-92 REMOVE INSERT 7
7 Appendix A to facility Combined License Nos. NPF-91 and NPF-92 REMOVE INSERT 3.7.6-2 3.7.6-2 3.7.6-4 3.7.6-4
(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. 200, 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; (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 7
Amendment No. 200
7 Amendment No. 196 (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. 196, 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) 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
Technical Specifications VES 3.7.6 VEGP Units 3 and 4 3.7.6 - 2 Amendment No. 200 (Unit 3)
Amendment No. 196 (Unit 4)
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.
Thermal mass of one or more required heat sink(s) not within limit(s).
C.1 Restore required heat sink air temperatures to within limit(s).
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND C.2 Restore thermal mass of required heat sink(s) to within limit(s).
5 days D.
VES inoperable due to inoperable MCRE boundary in MODE 1, 2, 3, or 4.
D.1 AND Initiate action to implement mitigating actions.
Immediately D.2 Verify mitigating actions ensure MCRE occupant exposures to radiological, chemical, and smoke hazards will not exceed limits.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND D.3 Restore MCRE boundary to OPERABLE status.
90 days E.
VES compressed air storage tanks compressed air volume not within limit.
E.1 Verify compressed air storage tanks contain
> 245,680 scf of compressed air.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter AND E.2 Verify VBS MCRE ancillary fans and supporting equipment are available.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> AND E.3 Restore VES compressed air storage tanks compressed air volume to within limit.
7 days
Technical Specifications VES 3.7.6 VEGP Units 3 and 4 3.7.6 - 4 Amendment No. 200 (Unit 3)
Amendment No. 196 (Unit 4)
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.6.1 Verify the compressed air storage tanks contain
> 327,574 scf of compressed air.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.7.6.2 Verify thermal mass for the following heat sink locations is within limit:
- a.
MCRE;
- b.
Each required individual room adjacent to and below MCRE;
- c.
Each required room-pair adjacent to and below MCRE; and
- d.
Room above MCRE.
24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> SR 3.7.6.3 Operate VES for 15 minutes.
31 days on a STAGGERED TEST BASIS SR 3.7.6.4 Verify each VES air header manual isolation valve is in an open position.
31 days SR 3.7.6.5 Verify the air quality of the compressed air storage tanks meets the requirements of CGA G-7.1, Commodity Specification for Air, Grade E, with a pressure dew point of 40°F at 3400 psig.
92 days SR 3.7.6.6 Verify each MCRE isolation valve is OPERABLE and will close upon receipt of an actual or simulated actuation signal, except for valves that are locked, sealed, or otherwise secured in the closed position.
24 months SR 3.7.6.7 Verify each VES pressure relief isolation valve within the MCRE pressure boundary is OPERABLE.
In accordance with the Inservice Testing Program SR 3.7.6.8 Verify each VES pressure relief damper is OPERABLE.
24 months
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 200 AND 196 TO THE COMBINED LICENSE NOS. NPF-91 AND NPF-92 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, UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026
1.0 INTRODUCTION
By letter dated June 21, 2024 (Agencywide Documents Access and Management System Accession No. ML24173A220), as supplemented by letter dated October 28, 2024 (ML24302A308), Southern Nuclear Operating Company (SNC, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, Combined License (COL) Numbers NPF-91 and NPF-92, respectively. The license amendment request (LAR) proposed to revise Technical Specifications (TS) 3.7.6, Main Control Room Emergency Habitability System (VES).
The amendments revise the COL Appendix A, TS 3.7.6, Actions, Condition E, Required Actions E.1 and E.3, concerning VES compressed air storage tanks compressed air not within limits and SR 3.7.6.5 to change the compressed air quality requirement specification from ASHRAE Standard 62, to Compressed Gas Association (CGA) CGA G-7.1-1997, Commodity Specification for Air, Grade E.
The licensee also requested approval to revise the Updated Final Safety Analysis Report (UFSAR)
Subsection 6.4.5.3, Air Quality Testing.
The supplement dated October 28, 2024, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published the Federal Register on September 3, 2024 (89 FR 71436).
2.0 REGULATORY EVALUATION
2.1 System Design and Operation As described in its submittal dated June 21, 2024, the licensee states, in part, that:
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 [Nuclear Island Nonradioactive Ventilation System] would continue to function if alternating current (AC) power is available. VES is actuated and the MCR pressure boundary isolated on either a High-2 particulate or iodine signal in the VBS supply ducting, a sustained loss of control room differential pressure, a sustained loss of all AC power, or manually by the operators. Concurrent with this action, the main control room envelope (MCRE) pressure relief isolation valves are opened after a short time delay to preclude over-pressurization of the MCRE pressure boundary.The major functions of the VES are to: (1) provide forced ventilation to deliver an adequate supply of breathable air for the MCR (main control room) occupants; (2) provide forced ventilation to maintain the MCR at a positive pressure [1/8-inch water gauge] with respect to the surrounding areas; (3) provide passive filtration to filter potential contaminated air in the MCR; and (4) maintain MCR temperature within acceptable limits to assure the MCR equipment and facilities that remain functional during design basis events.
The VES consists of 32 compressed air storage tanks arranged in four banks of eight tanks each, two air delivery flow paths, an eductor, a high efficiency particulate air (HEPA) filter, an activated charcoal adsorber section for removal of gaseous activity (principally iodines),
associated valves or dampers, piping, and instrumentation. The VES compressed air storage tanks are initially filled to contain greater than 327,574 standard cubic feet (scf) of compressed air to provide enough breathable air to supply the required air flow to the MCR for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> to maintain carbon dioxide (CO2) concentration less than 0.5% for up to 11 MCR occupants. Each bank provides at least a quarter (81,893.5 scf) of the total compressed air volume (327,574 scf) needed for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of operation. The volume of compressed air in the compressed air storage tanks is verified per TS SR 3.7.6.1 to confirm that the volume of breathable air required for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is stored in the tanks.
During operation of the VES, a self-contained pressure regulating valve maintains a constant downstream pressure regardless of the upstream pressure. Either the eductor, which contains a fixed single plate orifice, or the orifice in the secondary VES bypass line, is used to control the air flow rate into the MCR. The VES is designed to maintain the MCR at 1/8-inch water gauge positive pressure relative to surrounding areas to minimize the infiltration of airborne contaminants from the surrounding areas. The VES operation in maintaining the MCR habitable is discussed in UFSAR Section 6.4.
For current TS 3.7.6, Condition E, if one bank of VES air tanks (8 tanks out of 32 total) is inoperable, then the VES can supply air to the MCRE for 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> (75 percent of the required 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />). If the VES is actuated, the operator must take actions to maintain habitability of the MCRE once the air in the tanks has been exhausted. The VBS supplemental filtration mode or MCRE ancillary fans are both capable of maintaining the habitability of the MCRE after 54 hours6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br />.
From the TS Bases, Rev. 73 (ML23165A219) states:
With the equivalent of one bank of VES air tanks inoperable, action must be taken to restore OPERABLE status within 7 days. In this Condition, Required Action E.1 directs that the stored amount of compressed air in the remaining OPERABLE VES air tanks must be verified within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter to be > 245,680 scf. The 245,680 scf value is 75% of the minimum amount of stored compressed air that must be available in the compressed air storage tanks. The standard volume is determined using the compressed air storage tank room temperature (VAS-TE-080A/B) and compressed air storage tanks pressure (VES-PT-001A/B) via the plant control system and chart in the system procedures. Verification that the minimum volume of compressed air is contained in the OPERABLE compressed air storage tanks ensures a 54 hour6.25e-4 days <br />0.015 hours <br />8.928571e-5 weeks <br />2.0547e-5 months <br /> air supply will be available if needed. Additionally, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, the VBS ancillary fans are verified to be OPERABLE so that, if needed, can be put into use once the OPERABLE compressed air storage tanks have been exhausted.
The LAR provided the current requirements for VES air quality testing as described in Vogtle, Units 3 and 4, UFSAR, Subsection 6.4.5.3, Air Quality Testing. UFSAR 6.4.5.3 describes the connections that are provided for sampling the air supplied from the compressed and instrument air system (CAS) and for periodic sampling of the air stored in the storage tanks. Air samples of the compressed air storage tanks are taken quarterly and analyzed to confirm the air quality acceptability. This testing is required by TS SR 3.7.6.5, which currently requires that SNC Verify the air quality of the air storage tanks meets the requirements of Appendix C, Table C-1 of American Society of Heating, Refrigerating and Air-Conditioning Engineers, Inc. (ASHRAE) Standard 62-1989 with a pressure dewpoint of 40°F at 3400 psig every 92 days.
In Section 2.3 of its submittal dated June 21, 2024, the licensee stated, in part, that:
Vogtle Units 3 and 4 compressed breathing air systems are tested to ensure that air quality for respiratory protection meets or exceeds requirements as defined by 10 CFR 20.1703 Use of individual respiratory protection equipment, which specifies Grade D air quality or better as defined by the Compressed Gas Association in publication CGA G-7.1, "Commodity Specification for Air." In contrast, while ASHRAE Standard 62 provides guidelines for acceptable indoor air quality for enclosed spaces that people may occupy, ASHRAE Standard 62 does not specify air quality for compressed breathing air systems, nor does it specify periodic sampling and testing of air quality. As such, SNC proposes that testing to the federally recognized standard for respiratory protection of compressed breathing air provides the appropriate testing criteria for VES compressed air storage tanks as required by TS SR 3.7.6.5. Routine testing of MCR air quality to meet ASHRAE Standard 62 is not found in regulatory guidance.
SNC proposes replacing ASHRAE Standard 62-1989 with CGA G-7.1-1997, Grade E, which is the federally recognized standard for testing respiratory protection of compressed breathing air.
2.2 Regulations and Guidance In accordance with paragraph C.6. of Section VIII Processes for Changes and Departures of Appendix D to Part 52 Design Certification Rule for the AP1000 Design, changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90. Pursuant to 10 CFR 50.90, whenever a COL holder desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. Per 10 CFR 52.79(a), an application for a COL must contain a final safety analysis report that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components of the facility as a whole.
Per 10 CFR 52.79(a)(11), the application for a COL shall include proposed TSs prepared in accordance with the requirements of 10 CFR 50.36. 10 CFR 50.36(c)(2)(i) requires that TS include limiting conditions for operation (LCO) that are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Further, per 10 CFR 50.36(c)(2)(i), when an LCO is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the LCO can be met. Per 10 CFR 50.36(c)(3), TS will include SRs that 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 LCOs will be met. Per 10 CFR 52.97(c), a COL shall contain the terms and conditions, including TSs, as the Commission deems necessary and appropriate.
Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Both the common standards for licenses in 10 CFR 50.40(a) (regarding, among other things, consideration of the operating procedures, the facility and equipment, the use of the facility, and other TSs, or the proposals) and those specifically for issuance of combined licenses in 10 CFR 52.97(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public, and that the applicant will comply with the Commission's regulations.
The regulation in 10 CFR Part 50, Appendix A, General Design Criteria (GDC) 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.
Per 10 CFR 20.1703(g), if a licensee assigns or permits the use of respiratory protection equipment to limit the intake of radioactive material, then:
Atmosphere-supplying respirators must be supplied with respirable air of grade D quality or better as defined by the Compressed Gas Association in publication G-7.1, Commodity Specification for Air, 1997 and included in the regulations of the Occupational Safety and Health Administration (29 CFR 1910.134(i)(1)(ii)(A) through (E). Grade D quality air criteria include (1) Oxygen content (v/v) of 19.5-23.5%;
(2) Hydrocarbon (condensed) content of 5 milligrams per cubic meter of air or less; (3) Carbon monoxide (CO) content of 10 ppm or less; (4) Carbon dioxide content of 1,000 ppm or less; and (5) Lack of noticeable odor.
NUREG-0700, Human-System Interface Design Review Guidelines, Revision 3, July 2020 (ML20162A214), provides the regulatory guidance for plant personnel and plants systems and components that are evaluated for conformance with the human factors engineering guidelines.
Regulatory Guide 1.52, Revision 4, Design, Inspection, and Testing Criteria for Air Filtration and Adsorption Units of Post-Accident Engineered-Safety-Feature Atmosphere Cleanup Systems in Light-Water Cooled Nuclear Power Plants.
3.0 TECHNICAL EVALUATION
3.1 Current TSs Current TS 3.7.6, Actions, Condition E, and SR 3.7.6.5 are as follows:
CONDITION REQUIRED ACTION COMPLETION TIME E.
One bank of VES air tanks inoperable.
E.1 Verify that the OPERABLE tanks contain
> 245,680 scf of compressed air.
AND E.2 Verify VBS MCRE ancillary fans and supporting equipment are available.
AND E.3 Restore VES to OPERABLE status.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 7 days SURVEILLANCE FREQUENCY SR 3.7.6.5 Verify the air quality of the air storage tanks meets the requirements of Appendix C, Table C-1 of ASHRAE Standard 62 with a pressure dewpoint of 40°F at 3400 psig.
92 days 3.2 Proposed TSs Revised TS 3.7.6, Actions, Condition E, and SR 3.7.6.5 would state:
CONDITION REQUIRED ACTION COMPLETION TIME E.
VES compressed air storage tanks compressed air volume not within limit.
E.1 Verify compressed air storage tanks contain
> 245,680 scf of compressed air.
AND E.2 Verify VBS MCRE ancillary fans and supporting equipment are available.
AND E.3 Restore VES compressed air storage tanks compressed air volume to within limit.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> AND Once per 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 7 days SURVEILLANCE FREQUENCY SR 3.7.6.5 Verify the air quality of the compressed air storage tanks meets the requirements of CGA G-7.1, Commodity Specification for Air, Grade E, with a pressure dewpoint of 40°F at 3400 psig.
92 days 3.3 Description of the Proposed Change to UFSAR 6.4.5.3 and TS SR 3.7.6.5 Section 3 of the submittal dated June 21, 2024, SNC stated, in part, that:
The VES air storage tanks and SCBAs inside the MCR are refilled by the high-pressure subsystem of CAS, which only takes place on as needed basis. The high-pressure CAS system provides air that meets the CGA G-7.1 Grade E, air quality standard. This meets or exceeds the air quality requirements of 10 CFR 20.1703 Use of Individual Respiratory Protection Equipment, which requires CGA G-7.1, Grade D, quality or better. Complying with Grade E limits exceeds the requirements of Grade D air quality limits.
In Section 3 of its submittal dated June 21, 2024, the licensee stated, in part, that:
The VES provides a safety-related passive filtration system prior distribution into the MCR, which includes a HEPA filter, a charcoal adsorber, and a downstream postfilter. The filters are configured to satisfy the guidelines of Regulatory Guide 1.52. The VES circulates and distributes the breathable air from the emergency air storage tanks throughout the MCR providing an additional means of minimizing the presence of pollutants within the MCR.
The proposed change in the LAR modifies TS SR 3.7.6.5 to adopt the air quality requirements of CGA G-7.1-1997, Grade E, in lieu of the current air quality limits specified in ASHRAE Standard 62-1989 for the VES. UFSAR Subsection 6.4.5.3, Air Quality Testing, proposed change replaces Table 1 and Appendix C, Table C-1, of Reference 1, with CGA G-7.1-1997 and adding CGA G-7.1-1997 as a Reference in TS SR 3.7.6.5. The change from ASHRAE Standard 62-1989 to the requirements of CGA G-7.1-1997, Grade E, is changing the VES air quality and testing requirements with the current air quality requirements for the CAS. SNC indicated that the proposed use of CGA G-7.1-1997, Grade E, meets the employee breathing air quality requirements of 10 CFR 20.1703 and is an appropriate replacement for ASHRAE Standard 62-1989 for VES compressed air storage tank quality confirmation without adversely impacting the safety of the MCR occupants.
3.4 Technical Evaluation of the Proposed Changes 3.4.1 HUMAN FACTORS TECHNICAL EVALUATION 3.4.1.1 NRC Staff Evaluation of Proposed Changes to UFSAR 6.4.5.3 and TS SR 3.7.6.5 The NRC staff reviewed the LAR in accordance with NUREG-0700 due to the change in air quality standards potentially impacting the plant personnel in the MCR when the VES is activated. No new operator actions or changes to the VES are being proposed. Consequently, the NRC review focused on the human-system interaction portion. The current air quality standards cited in ASHRAE Standard 62-1989 Table 1 and Appendix C, Table C-1 are the following:
ASHRAE Standard 62-1989 - Long-Term Contaminant Concentration ug/m3 Concentration ppm Averaging Sulfur Dioxide 80 0.03 1 year Total Particulate 75 N/A 1 year Carbon Monoxide N/A N/A N/A Carbon Monoxide N/A N/A N/A Oxidants (ozone)
N/A N/A N/A Nitrogen dioxide 100 0.055 1 year Lead 1.5 N/A 3 months ASHRAE Standard 62-1989 - Short-Term Contaminant Concentration ug/m3 Concentration ppm Averaging Sulfur Dioxide 365 14 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Total Particulate 260 N/A 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> Carbon Monoxide 40,000 35 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Carbon Monoxide 10,000 9
8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> Oxidants (ozone) 235 12 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> Nitrogen dioxide N/A N/A N/A Lead N/A N/A N/A The comparison between the Grade D and Grade E quality air in in CGA G-7.1-1997 has the following:
Grade D Quality Air Criterion Value Oxygen Content 19.5-23.5%
Hydrocarbon 5 milligrams per cubic meter of air or less Carbon Monoxide 10 ppm or less Carbon Dioxide 1,000 ppm or less Odor Lack of noticeable odor Grade E Quality Air Criterion Value Oxygen Content 20-22%
Hydrocarbon Maximum 25 parts per million (ppm)
Carbon Monoxide Maximum 10 ppm Carbon Dioxide Maximum 1,000 ppm Odor Lack of noticeable odor Condensed Oil Maximum 5 milligrams per cubic meter (mg/m3)
SNC proposes to use the air quality requirements of Grade E in CGA G-7.1 for the VES, which would meet the requirements of 10 CFR 20.1703. The NRC staff reviewed the air quality requirements between both references and evaluated the potential impact of the air pollutants on the operators and how they will continue to be measured with the change in the air quality standards. The NRC staff noticed in its review of Table 1 of the CGA G-7.1-1997 standard, limiting characteristics for nitrogen dioxide and sulfur dioxide were listed without a maximum limiting characteristic as is provided for the ASHRAE 62-1989 standard. The NRC staff also nored 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. The NRC staff requested 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 MCR if the VES tanks are activated.
In its supplement dated October 28, 2024, the licensee stated that the CGA G-7.1-1997, Section 2.1, Quality verification levels (grades), describes that the Table 1, Directory of limiting characteristics, with an absence of a listed quality verification level, merely indicates that the test is not required for compliance with the specification. The acceptability of air supplied from the VES tanks for operators in the MCR is established by providing bottled air quality that exceeds the standard in regulations for personnel being supplied bottled air for breathing. Specifically, 10 CFR 20.1703, Use of Individual Respiratory Protection Equipment, Paragraph (g) requires that respirators must be supplied with respirable air of Grade D quality or better as defined by CGA G-7.1-1997 and included in the regulations of the Occupational Safety and Health Administration (29 CFR 1910.134(i)(1)(ii)(A) through (E)). The Vogtle, Units 3 and 4, VES bottled air is required to meet Grade E quality, which meets or exceeds the 10 CFR 20.1703 minimum requirements for bottled breathing air.
SNC also indicated the additional air pollutants not specified in CGA G-7.1-1997 will be protected by a feature in the VES that calls for the VES bottled air supply and MCR air to be processed through the VES safety-related passive filtration unit prior to distribution within the MCR after the VES is actuated.
The filtration unit is designed to satisfy the guidelines of Regulatory Guide 1.52 and includes a HEPA filter, a charcoal adsorber, and a downstream postfilter. The filtered air is circulated and distributed throughout the MCR, providing an additional means of minimizing the presence of pollutants within the MCR as listed in the ASHRAE Standard 62-1989. The VES respiratory-grade bottled air and post-actuation VES safety-related passive filtration system, provide assurance of acceptable air quality for the operators in the MCR.
The NRC staff also inquired how the human-system analysis for Vogtle, Units 3 and 4, regarding NUREG-0700, Section 12.1.2.2, would be impacted in the areas of air quantity and air velocity because of changing the air quality standard to CGA G-7.1-1997 in UFSAR 6.4.5.3 and TS SR 3.7.6.5. SNC responded that the proposed change in the LAR will not require any physical modifications to the VES or MCR ventilation, and therefore, the areas of air velocity and air quantity would remain the same.
The NRC staff reviewed both ASHRAE Standard 62-1989 and CGA G-7.1-1997 to compare the air quality requirements and with consideration of the inherent design features of the VES in providing additional air quality protection for operators in the MCR upon activation. The NRC staff finds that the VES will continue to adhere to appropriate air quality and sampling standards with the change to the CGA G-7.1-1997, Grade E standard. The CAS system currently uses the same air quality standard, so this change for the VES will maintain compliance with 10 CFR 20.1703 and 10 CFR 50, Appendix A, GDC 19. The NRC staff also finds that SNCs response confirms that the VES system would remain intact with no physical modifications nor any new impacts to the operators in the MCR if actuated.
Therefore, the NRC staff finds the changes to UFSAR 6.4.5.3 and TS SR 3.7.6.5 to use CGA G-7.1-1997, Grade E standard acceptable.
3.4.1.2 Human Factors Evaluation Conclusion The NRC staff reviewed the human-systems interface of the actuation of VES in the MCR and the differences of the air quality standards cited for ASHRAE Standard 62-1989 and CGA G-7.1-1997.
NRC staff agrees that the Grade E requirements for CGA G-7.1-1997 will continue to meet 10 CFR 20.1703 and 10 CFR 50, Appendix A, GDC 19 based upon the inherent design features of the VES that already exists to protect operators from various air pollutants upon activation. Along with the air sampling requirements being suggested in CGA G-7.1-1997, the NRC staff finds that the VES will continue to be appropriately monitored for effectiveness as part of the changes to UFSAR 6.4.5.3 and TS SR 3.7.6.5. The NRC staff also finds that no physical modifications or new operator actions will be needed as part of this change. Based on the determination that the licensee will continue to adequately meet the applicable regulatory requirements, the NRC staff finds the proposed license amendment to be acceptable.
3.4.2 TS 3.7.6 Condition E and Required Action E.1 and E.3 Changes In its letter dated June 21, 2024, SNC requested a change to TS 3.7.6 regarding Action E.1 as a clarification to the status of the VES air storage tanks. The licensee identified a potential scenario where, due to how the total volume of the VES tanks is calculated, the four banks may have less than the required minimum volume of 327,574 scf as stated in SR 3.6.7.1:
Verify the compressed air storage tanks contain > 327,573 scf of compressed air.
The current wording of Condition E in the TS presumes the complete loss of 25 percent of the required volume of the compressed air, with the loss limited to one bank. This may lead to the licensee unnecessarily entering TS 3.7.6, Condition F, which requires the plant to be in MODE 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and MODE 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />, even if the VES banks contain more compressed air than required by Action E.1 due to one bank being declared INOPERABLE.
The current Required Action E.1 requires periodic verification that the remaining VES tanks contain more than 245,680 scf (which corresponds to 75 percent of the required volume for a 72-hour supply or an equivalent 54-hour supply), of breathable compressed air. The revised condition and required actions continue to assure the 54-hour supply is available. The proposed change aligns Condition E with SR 3.7.6.1, which is based on the total volume of the VES banks, rather than basing it from the operability of a single bank. The proposed changes are also more consistent with containers of volumes, which is more accurate for describing the VES banks type of component.
The proposed changes do not modify the design for any safety-related structures, systems, and components, nor change the limits set by the TS. The revised Condition E and Required Actions provide reasonable assurance of public health and safety because the action directs that the stored amount of compressed air in the VES compressed air storage tanks must be verified within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and every 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> thereafter to contain > 245,680 scf. Therefore, the NRC staff finds the proposed Condition E and Required Action E changes 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 February 3, 2025. On February 8, 2025, the State official indicated the State of Georgia had no comments.
5.0 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. 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on September 3, 2024 (89 FR 71436).
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.
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 Commissions 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: G. Armstrong, NRR D. Scully, NRR R. Atienza, NRR J. Wilson, NRR Y. Wong, NRR Date: March 24, 2025
ML25034A221 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DRO/IOLB/BC NRR/DSS/SCPB/BC NAME JLamb KZelenock (ABaxter for)
ADAgostino (A)
MValentin DATE 01/28/2025 02/04/2025 01/28/2025 02/04/2025 OFFICE NRR/DSS/STSB/BC NRR/DEX/EMIB/BC OGC - NLO NRR/DORL/LPL2-1/BC NAME SMehta SBailey SGellen MMarkley DATE 02/04/2025 02/04/2025 03/05/2025 03/24/2025 OFFICE NRR/DORL/LPL2-1/PM NAME JLamb DATE 03/24/2025