ML25351A043
| ML25351A043 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/31/2025 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| EPID L-2025-LLA-0107 | |
| Download: ML25351A043 (0) | |
Text
December 31, 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 MAIN CONTROL ROOM EMERGENCY HABITABILITY SYSTEM TECHNICAL SPECIFICATIONS ACTIONS (EPID L-2025-LLA-0107)
Dear Ms. Coleman:
In response to your application dated July 15, 2025, the U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment Nos. 211 and 209 to Combined License (COL)
Nos. NPF-91 and NPF-92, respectively, for Vogtle Electric Generating Plant (Vogtle), Units 3 and 4. The amendment revises Technical Specification (TS) 3.7.6, Main Control Room Emergency Habitability System (VES), and TS 3.3.13, Engineered Safety Feature Actuation System (ESFAS) Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization.
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.
J. Coleman 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. 211 to Vogtle, Unit 3, COL
- 2. Amendment No. 209 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. 211 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 July 15, 2025, 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 hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.D(8) of Facility Combined Operating 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. 211, are hereby incorporated into this license.
3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.
FOR THE NUCLEAR REGULATORY COMMISSION:
Michael Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Page 4 of the facility Combined License and affected pages of Appendix C of the facility Combined License Date of Issuance: December 31, 2025 SHAWN WILLIAMS Digitally signed by SHAWN WILLIAMS Date: 2025.12.31 08:50:23 -05'00' 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. 209 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 July 15, 2025, 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 hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.D(8) of Facility Combined Operating 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. 209, are hereby incorporated into this license.
- 3.
This license amendment is effective as of the date of its issuance and shall be implemented within 120 days.
FOR THE NUCLEAR REGULATORY COMMISSION:
Michael Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Page 4 of the facility Combined License and affected pages of Appendix C of the facility Combined License Date of Issuance: December 31, 2025 SHAWN WILLIAMS Digitally signed by SHAWN WILLIAMS Date: 2025.12.31 08:50:54 -05'00'
ATTACHMENT TO LICENSE AMENDMENT NOS. 211 AND 209 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 4
4 Facility Combined License No. NPF-92 REMOVE INSERT 4
4 Appendix A to facility Combined License Nos. NPF-91 and NPF-92 REMOVE INSERT 3.3.13-2 3.3.13-2 3.3.13-4 3.3.13-4 3.7.6-3 3.7.6-3
D.
The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:
(1)
Changes during Construction - Removed by Amendment No. 202 (2)
Pre-operational Testing - Removed by Amendment Nos. 192 and 202 (3)
Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos. 192 and 202 (4)
Initial Criticality and Low-Power Testing - Removed by Amendment No. 202 (5)
Power Ascension Testing - Removed by Amendment No. 202 (6)
Maximum Power Level (7)
(8)
SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.
Reporting Requirements - Removed by Amendment No. 202 Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 211, are hereby incorporated into this license.
(9)
Technical Specifications - Removed by Amendment No. 202 (10)
Operational Program Implementation - Removed by Amendment No. 202 (11)
Operational Program Implementation Schedule - Removed by Amendment No.202 (12)
Site-and Unit-specific Conditions - Removed by Amendment No. 202
[Blank Pages 5 through 14 removed by Amendment No. 202.]
4 Amendment No. 211
D.
The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:
(1)
Changes during Construction - Removed by Amendment No. 199 (2)
Pre-operational Testing - Removed by Amendment Nos. 194 and 199 (3)
Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos. 194 and 199 (4)
Initial Criticality and Low-Power Testing - Removed by Amendment No. 199 (5)
Power Ascension Testing - Removed by Amendment No. 199 (6)
Maximum Power Level (7)
(8)
SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.
Reporting Requirements - Removed by Amendment No. 199 Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 209, are hereby incorporated into this license.
(9)
Technical Specifications - Removed by Amendment No. 199 (10)
Operational Program Implementation - Removed by Amendment No. 199 (11)
Operational Program Implementation Schedule - Removed by Amendment No. 199 (12)
Site-and Unit-specific Conditions - Removed by Amendment No. 199
[Blank Pages 5 through 14 removed by Amendment No. 199.]
4 Amendment No. 209
Technical Specifications ESFAS Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization 3.3.13 VEGP Units 3 and 4 3.3.13 - 2 Amendment No. 211 (Unit 3)
Amendment No. 209 (Unit 4)
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME C.
As required by Required Action A.1 and referenced in Table 3.3.13-1.
C.1 AND C.2 Verify one channel OPERABLE.
Restore channel to OPERABLE status.
Immediately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> D.
Required Action and associated Completion Time of Condition B or C not met.
D.1 Declare VES inoperable.
Immediately E.
- NOTE -
Separate Condition entry is allowed for each channel.
As required by Required Action A.1 and referenced in Table 3.3.13-1.
E.1 OR E.2.1 AND E.2.2 Place inoperable channel in trip.
Verify actuation capability is maintained.
Restore channel to OPERABLE status.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 6 hours 7 days F.
Required Action and accociated Completion time of Condition E not met.
F.1 De-energize both MCR air supply radiation monitor sample pumps.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />
Technical Specifications ESFAS Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization 3.3.13 VEGP Units 3 and 4 3.3.13 - 4 Amendment No. 211 (Unit 3)
Amendment No. 209 (Unit 4)
Table 3.3.13-1 (page 1 of 1)
ESFAS Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-Energization Instrumentation FUNCTION APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS REQUIRED CHANNELS CONDITIONS SURVEILLANCE REQUIREMENTS 1.
Main Control Room Air Supply Iodine or Particulate Radiation -
High 2 1(a),2(a),3(a),4(a) 2 B
SR 3.3.13.1 SR 3.3.13.2 (b)(a) 2 C
SR 3.3.13.1 SR 3.3.13.2 2.
Main Control Room Differential Pressure - Low 1,2,3,4 2
B SR 3.3.13.1 SR 3.3.13.2 (b) 2 C
SR 3.3.13.1 SR 3.3.13.2 3.
Class 1E 24-Hour Battery Charger Undervoltage 1,2,3,4,5,6,(b) 2/24-hour battery charger E
SR 3.3.13.1 (a) Not applicable for the Main Control Room Air Supply Iodine or Particulate Radiation - High 2 function when the Main Control Room Envelope is isolated and the Main Control Room Emergency Habitability System is in operation.
(b) During movement of irradiated fuel assemblies.
Technical Specifications VES 3.7.6 VEGP Units 3 and 4 3.7.6 - 3 Amendment No. 211 (Unit 3)
Amendment No. 209 (Unit 4)
ACTIONS (continued)
CONDITION REQUIRED ACTION COMPLETION TIME F.
Required Action and associated Completion Time of Condition A, B, C, or E not met.
OR VES inoperable for reasons other than Condition A, B, C, D, or E.
F.1 AND F.2 Verify VBS available for mitigating VES inoperability.
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 /> 7 days G.
Required Action and associated Completion Time of Condition D or F not met in MODE 1, 2, 3, or 4.
G.1 AND G.2 Be in MODE 3.
Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours H.
Required Action and associated Completion Time of Condition F not met during movement of irradiated fuel.
H.1 Suspend movement of irradiated fuel assemblies.
Immediately OR VES inoperable due to inoperable MCRE boundary during movement of irradiated fuel.
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 211 AND 209 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 July 15, 2025 (Agencywide Documents Access and Management System Accession No. ML25196A469), Southern Nuclear Operating Company (SNC, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC, the Commission) amend Vogtle Electric Generating Plant (Vogtle), Units 3 and 4, Combined License (COL) Nos. NPF-91 and NPF-92.
The license amendment request (LAR) proposed to revise Technical Specification (TS) 3.7.6, Main Control Room Emergency Habitability System (VES), and TS 3.3.13, Engineered Safety Feature Actuation System (ESFAS) Main Control Room Isolation, Air Supply Initiation, and Electrical Load De-energization.
2.0 REGULATORY EVALUATION
2.1 System Design and Operation As described in its submittal dated July 15, 2025, the licensee states, in part, that:
The main control room envelope (MCRE) is also provided with emergency passive heat sinks for the main control room (MCR), instrumentation and control rooms, and dc [direct current] equipment rooms to support VES function to maintain the MCRE within habitable limits for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. As described in the TS 3.7.6 Bases, nonessential, non-safety MCR heat loads are de-energized by the VES actuation signals to maintain the heat sink. Two redundant divisions of MCR Class 1E load shed relays and timers located in two safety-related panels are required to meet the single failure criterion. Each panel contains redundant load shed relays and timers actuated by the two PMS [Protection and Safety Monitoring System] divisions such that actuation of either division deenergizes the specified loads associated with both panels.
2.2 Regulations and Guidance In accordance with paragraph C.6. of Section VIII of the Code of Federal Regulations (10 CFR)
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. As required by 10 CFR 50.36(c)(2)(i), the TSs will 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), TSs will include surveillance requirements (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 LCO 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.
The NRC staffs guidance for the review of TS is in NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [LightWater Reactor]
Edition (SRP), Chapter 16, Section 16.0, Technical Specifications, March 2010 (ML100351425). The NRC staffs review includes consideration of whether the proposed changes are consistent with the NUREG-2194, Revision1, Standard Technical Specifications, Westinghouse Advanced Passive 1000 (AP1000) Plants.
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 Commissions 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.
The Updated Final Safety Analysis Report (UFSAR), Revision 12 (ML23165A215),
Section 6.4.4, System Safety Evaluation, states, in part:
In the event of an accident involving the release of radioactivity to the environment, the nuclear island nonradioactive ventilation system (VBS) is expected to switch from the normal operating mode to the supplemental air filtration mode to protect the main control room personnel. Although VBS is not a safety-related system, it is expected to be available to provide the necessary protection for realistic events. However, the design basis accident doses reported in Chapter 15 utilize conservative assumptions, and the main control room doses are calculated based on operation of the safety-related emergency habitability system (VES) since this is the system that is relied upon to limit the amount of activity the personnel are exposed to. The analyses assume that the VBS is initially in operation, but fails to enter the supplemental air filtration mode on a High-1 radioactivity indication in the main control room atmosphere. VES operation is then assumed to be initiated once the High-2 level for control room atmosphere iodine or particulate radioactivity is reached.
TS Bases, Revision 73 (ML23165A219), states, in part:
The Main Control Room Emergency Habitability System (VES) provides a protected environment from which operators can control the plant following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The system is designed to operate following a Design Basis Accident (DBA) which requires protection from the release of radioactivity. In these events, the Nuclear Island Non-Radioactive Ventilation System (VBS) would continue to function if AC power is available. If AC power is lost for greater than 10 minutes, or Low main control room differential pressure is sensed for greater than 10 minutes, or a High-2 iodine or particulate Main Control Room Envelope (MCRE) radiation signal is received, the VES is actuated.
Heat sources inside the MCRE include operator workstations, emergency lighting and occupants. During normal operation, temperatures in the main control room, instrumentation and control rooms, dc equipment rooms, Class 1E electrical penetration rooms, and some adjacent rooms are maintained within a specified range by the VBS. As described in UFSAR Section 9.4.1.2, the VBS consists of independent subsystems, including the main control room / control support area HVAC subsystem and the Class 1E Electrical room HVAC subsystem. The Class 1E Electrical room HVAC subsystem is further divided into two independent subsystems, with one serving the Division A & C Class 1E electrical division rooms and the other serving the Division B & D Class 1E electrical division rooms. Each independent subsystem serves its associated rooms with two redundant, 100 percent capacity equipment trains, maintaining temperatures within the specified range.
To support OPERABILITY of the VES, passive heat sink air temperatures are maintained by VBS in required dc Equipment rooms and required I&C rooms.
Certain required room-pairs (i.e., 12201/12301, 12203/12302, 12205/12305, and 12207/12304) require the average temperature of the combined room-pair to be 85°F, as monitored by temperature elements located in the shared return air ducting. Other required individual rooms (i.e., 12202, 12204, 12300, 12313, 12412, and 12501) are each required to be 85°F. Additionally, a maximum air temperature limit of 75°F is also placed on the MCRE. The passive heat sinks limit the temperature rise inside each room and the MCRE during the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period following VES actuation.
2.3 Precedent There is no precedent for this specific permanent Technical Specification change. Although a one-time emergency amendment dated May 27, 2025 (ML25136A381) was previously approved to address a similar VES inoperability condition at Vogtle Unit 4, that action was temporary in nature and does not constitute a precedent for permanent Technical Specification changes. The current amendment request is intended to provide a permanent solution based on the operational experience and technical basis established during the one-time emergency amendment.
3.0 TECHNICAL EVALUATION
3.1 Current TS 3.7.6 The current TS 3.7.6 states, in part:
CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and associated Completion Time of Condition A, B, C, D, or E not met in MODE 1, 2, 3, or 4.
OR VES inoperable for reasons other than Condition A, B, C, D, or E in MODE 1, 2, 3, or 4.
NOTE----------
For one-time use on Unit 4, initiation of Required Actions F.1 and F.2 Completion Times may be delayed for 100 hours0.00116 days <br />0.0278 hours <br />1.653439e-4 weeks <br />3.805e-5 months <br /> from discovery of Condition F entry when Condition F entry is a result of VES air system leakage repair(s), provided VBS is providing ventilation to the main control room envelope. This provision expires 124 hours0.00144 days <br />0.0344 hours <br />2.050265e-4 weeks <br />4.7182e-5 months <br /> following NRC approval.
F.1 Be in MODE 3.
AND F.2 Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours G. Required Action and associated Completion Time of Condition A, B, C, or E not met during movement of irradiated fuel.
OR VES inoperable for reasons other than Condition A, B, C, or E during movement of irradiated fuel.
OR VES inoperable due to inoperable MCRE boundary during movement of irradiated fuel.
G.1 Suspend movement of irradiated fuel assemblies.
Immediately 3.2 Proposed Redline/Strikeout Mark-Up TS 3.7.6 The proposed TS 3.7.6 redline/strikeout mark-up would state:
3.3 Proposed Clean TS 3.7.6 The proposed TS 3.7.6 changes would state:
CONDITION REQUIRED ACTION COMPLETION TIME F. Required Action and associated Completion Time of Condition A, B, C, or E not met.
OR VES inoperable for reasons other than Condition A, B, C, D, or E.
F.1 Verify VBS available for mitigating VES inoperability.
AND F.2 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 /> 7 days CONDITION REQUIRED ACTION COMPLETION TIME G. Required Action and associated Completion Time of Condition D or E not met in MODE 1, 2, 3, or 4.
G.1 Be in MODE 3.
AND G.2 Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours H. Required Action and associated Completion Time of Condition F not met during movement of irradiated fuel.
OR VES inoperable due to inoperable MCRE boundary during movement of irradiated fuel.
H.1 Suspend movement of irradiated fuel assemblies.
Immediately 3.4 Current TS 3.3.13 The current TS 3.3.13 states, in part:
CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required Action A.1 and referenced in Table 3.3.13-1.
C.1 Verify one channel OPERABLE.
AND C.2 Restore channel to OPERABLE status.
Immediately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> D. Required Action and associated Completion Time of Condition B not met.
D.1 Be in MODE 3.
AND D.2 Be in MODE 5.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 36 hours E. Required Action and associated Completion Time of Condition C not met.
E.1 Suspend movement of irradiated fuel assemblies.
Immediately F. -----------------------------
- NOTE -
F.1 Place inoperable channel in trip.
OR 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> CONDITION REQUIRED ACTION COMPLETION TIME Separate Condition entry is allowed for each channel.
As required by Required Action A.1 and referenced in Table 3.3.13-1.
F.2.1 Verify actuation capability is maintained.
AND F.2.2 Restore channel to OPERABLE status.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 7 days G. Required Action and associated Completion time of Condition F not met.
G.1 De-energize both MCR air supply radiation monitor sample pumps.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 3.5 Proposed Redline/Strikeout Mark-Up TS 3.3.13 The proposed redline/strikeout mark-up TS 3.3.13 changes would state:
3.6 Proposed Clean TS 3.3.13 The proposed TS 3.3.13 changes would state:
CONDITION REQUIRED ACTION COMPLETION TIME C. As required by Required Action A.1 and referenced in Table 3.3.13-1.
C.1 Verify one channel OPERABLE.
AND C.2 Restore channel to OPERABLE status.
Immediately 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> D. Required Action and associated Completion Time of Condition B or C not met.
D.1 Declare VES inoperable.
Immediately E. -----------------------------
- NOTE -
Separate Condition entry is allowed for each channel.
E.1 Place inoperable channel in trip.
OR E.2.1 Verify actuation capability is maintained.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 6 hours CONDITION REQUIRED ACTION COMPLETION TIME As required by Required Action A.1 and referenced in Table 3.3.13-1.
AND E.2.2 Restore channel to OPERABLE status.
7 days F. Required Action and associated Completion time of Condition E not met.
F.1 De-energize both MCR air supply radiation monitor sample pumps.
6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> 3.7 Current TS Table 3.3.13-1 The current function 3, Class 1E 24-Hour Battery Charger Undervoltage, for TS Table 3.3.13-1 applies to Condition F.
3.8 Proposed TS Table 3.3.13-1 The proposed function 3, Class 1E 24-Hour Battery Charger Undervoltage, for TS Table 3.3.13-1 would apply to Condition E.
3.9 Technical Evaluation of the Proposed Changes 3.9.1 Evaluation of Editorial Changes The following are the editorial changes being made:
In TS 3.3.13, Condition F is being re-named Condition E.
In TS 3.13.13, Condition G is being re-named Condition F.
In TS 3.7.6, Condition F is being re-named Condition G.
In 3.7.6, Condition G is being re-named Condition H.
The proposed editorial changes do not alter the intent, scope, or requirements in the TS, but the editorial changes serve to improve its presentation and usability. Therefore, the NRC staff finds the proposed editorial changes acceptable.
3.9.2 Radiological Dose Assessment When VES, which is the primary, safety related, control room habitability system, is inoperable, the Vogtle, Units 3 and 4, control room ventilation system exhibits defense-in-depth with the backup, no-safety related VBS ventilation system. While this is a non-safety-related system, the Vogtle, Units 3 and 4, updated final safety analysis report (UFSAR) table 15.6.5-3 provides the radiological consequence analysis of a Loss-of-Coolant Accident (LOCA) when relying on the VBS when VES is not available. The accident analysis provides results from both the safety-related system (VES) and the non-safety related backup system (VBS). The accident dose analysis is performed using only one of the two redundant trains of VBS. This analysis demonstrates that when available the control room ventilation backup system, VBS, will be able to maintain control room dose below regulatory limits during the design basis LOCA.
SNC has demonstrated that when available the VBS would allow the site to meet control room dose criteria during the loss of coolant accident (LOCA) design basis event. These backup systems demonstrate defense-in-depth and redundancy. The VBS system is designed with redundant subsystems, and the VBS has a backup power supply in the event of a loss of offsite power.
The NRC staff reviewed assumptions, inputs, and methods used by SNC to assess the radiological impacts of loss of VES (reliance on VBS) concurrent with a LOCA, and find that the values used in the calculations to support the use of the VBS back up control room habitability system are consistent with their current licensing basis. Further, the results of this analysis meet regulatory dose limit requirements for access and occupancy of the control room under accident conditions through use of one train of VBS. Therefore, based on the above, the NRC staff finds the LAR is acceptable with respect to the radiological consequences analysis of the backup VBS.
Table 15.6.5-3 (from UFSAR)
Radiological Consequences of a Loss-of-Coolant Accident with Core Melt (Control Room Dose)
Main control room dose - VES (emergency habitability system in operation)
- Airborne activity entering the main control room
- Direct radiation from adjacent structures, including sky shine
- Filter shine
- Spent fuel pool boiling
- Total 3.70 0.30 0.32 0.01 4.33 Main control room dose - VBS (normal HVAC operating in the supplemental filtration mode)
- Airborne activity entering the main control room
- Direct radiation from adjacent structures, including sky shine
- Filter shine
- Spent fuel pool boiling
- Total 4.50 0.30 0.03 0.01 4.84 3.9.3 VBS Evaluation SNC states in section 3 of enclosure to the LAR dated July 15, 2025, that VBS is designed to control the radiological habitability in the main control room within the guidelines presented in Standard Review Plan 6.4, Control Room Habitability System, and NUREG 0696, Functional Criteria for Emergency Response Facilities, and within allowable GDC 19 limits during design basis accidents in both the main control room and control support area.
UFSAR section 6.4.4 states that in the event of an accident involving the release of radioactivity to the environment, VBS is expected to switch from the normal operating mode to the supplemental air filtration mode to protect the main control room personnel. Although VBS is not a safety-related system, it is expected to be available to provide the necessary protection for realistic events.
The licensee states the following in section 3 of enclosure to the LAR:
In the event of a loss of the normal ac power and offsite power, two standby diesel generators provide power to support the operation of VBS. Since VBS operates continuously during normal plant operation, its availability is continuously evident and maintaining its continued reliability is necessary for normal plant operations. This normal continuous VBS operation is necessary to maintain the required heat sink as verified by SR 3.7.6.2With VBS not in operation, the MCRE would not be maintained within its required 75°F limit (for example) and VES would be declared inoperable and TS 3.7.6 Action C entered.
Additionally, both the VBS and the standby diesel generators are included within the VEGP Maintenance Rule Program in accordance with 10 CFR 50.65. This program ensures that these systems remain reliable and capable of fulfilling their intended safety functions through required preventive maintenance and performance monitoring. Both VBS and the standby diesel generators currently maintain a green (a)(2) status, indicating effective performance and reliability.
SNC states in the LAR that the proposed TS Required Action F.1 ensures the availability of one train of the VBS system, including its diesel generator and supporting subsystemsto mitigate VES inoperability by maintaining positive pressure and temperature control in the MCRE. This includes isolating the MCR from outdoor air during high radioactivity events and supplying filtered air to pressurize and cool both the MCR and the control support areas. The system also filters recirculated air to reduce airborne radioactivity, ensuring personnel doses remain within GDC 19 limits during design basis accidents. A 2-hour Completion Time allows for administrative verification of VBS availability, supporting continued habitability and dose control.
Additionally, the licensee states in the LAR that TS Required Action F.2 proposes a 7-day Completion Time to restore VES operability, justified by the low probability of a significant radiation release and the mitigating capability of the VBS system.
UFSAR section 1.9.4.2.3 states that in the event of external smoke or radiation release, VBS provides for a supplemental filtration mode of operation. In the unlikely event of a toxic chemical release, VES has the capability to be manually actuated by the operators. Further, a 6-hour supply of self-contained portable breathing equipment is stored inside the main control room pressure boundary. However, UFSAR section 6.4.4.2 states that toxic chemical habitability analysis results for offsite and site-specific onsite chemicals show that there are no toxic hazards to Units 3 and 4 control room personnel. As such, the licensee states in section 3 of enclosure to the LAR that the use of VES or self-contained portable breathing equipment is not postulated to be needed for toxic chemical releases. The TS operability requirement for VES does not include the necessity for VES to be operable for toxic gas event protection.
UFSAR section 9.4.1.2.3.1 states that if a high concentration of smoke is detected in the outside air intake, an alarm is initiated in the main control room and VBS is manually realigned to the recirculation mode by closing the outside air and toilet exhaust duct isolation valves. The exhaust fans for the main control room toilets and the toilet serving the control support area are tripped upon closure of the isolation valves. As such, the licensee states in section 3 of enclosure to the LAR that the TS operability requirement for VES does not include the necessity for VES to be operable for smoke event protection.
Based on the review of information presented in the LAR, TS, UFSAR, the NRC staff determines that the licensees proposed request is acceptable with respect to the use of VBS as a backup, provided VBS is available to provide ventilation to the MCRE.
3.9.4 Evaluation of TS Change SNC has proposed the following TS changes for Vogtle, Units 3 and 4:
Adding Condition F to TS 3.7.6, Deleting and adding information to Condition G of TS 3.7.6, Deleting and adding information to Condition H of TS 3.7.6, Deleting and adding information to Condition D of TS 3.3.13, Deleting Condition E of TS 3.3.13, and Changing the Condition for Function 3 of TS Table 3.3.13-1.
The proposed TS 3.7.6, TS 3.3.13, and TS Table 3.3.13-1 changes are stated above.
The NRC staff reviewed the proposed TS changes. The net effect of the changes proposed in the LAR is to consolidate all actions associated with the inoperability of the VES under TS 3.7.6.
Currently, SNC will enter TS 3.3.13 Action D when VES cannot automatically initiate due to either the Main Control Room Air Supply Iodine or Particulate Radiation - High 2 channel, or the Main Control Room Differential Pressure - Low channel, is inoperable for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
The licensee will take the Required Actions D.1 Be in Mode 3 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> and D.2 Be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
SNC proposes to revise TS 3.3.13 Required Action D.1 from 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 /> to Declare VES inoperable immediately and deleting Required Action D.2 Be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.
As a result, the licensee would enter TS 3.7.6 for an inoperable VES and follow the remedial actions specified in new Condition F, as discussed below.
SNC proposes the addition of a new Condition F to TS 3.7.6 to address cases where the VES is inoperable for reasons not covered under Conditions A through E, including inoperability of the VES automatic actuation instrumentation specified in TS 3.3.13. This new condition specifies the following required actions:
F.1 Verify VBS available within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> F.2 Restore VES operable within 7 days Verifying the availability of the VBS within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> ensures that this backup system can temporarily mitigate the loss of VES functionality. As discussed above, the VBS is considered an acceptable backup in the event of the loss of VES functionality. This verification provides reasonable assurance that plant safety is maintained while the VES is being restored to operable status. The NRC staff finds the specified 2-hour Completion Time (CT), for the verification, reasonable due to the low likelihood of a DBA requiring VES actuation during this period. Once verified, VBS availability must be maintained continuously. If VBS availability is lost before VES is restored, the Required Actions of the proposed Condition G must be implemented.
The proposed Required Action F.2 allows a 7-day CT to restore the VES to operable status. The NRC staff finds the 7-day CT acceptable due to the availability of VBS to temporarily backup VES, as discussed in Section 3.7.3. The 7-day CT is consistent with standard practices for establishing Completion Times, as described in RG 1.177, An Approach for Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications, which identifies 7 days as a typical CT for systems with backup capability. This duration provides adequate time to complete necessary repairs without requiring an immediate plant shutdown.
SNC proposes revising TS 3.7.6 Condition G to incorporate into the new Condition F, if Condition F is not met. The Required Actions are G.1, 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 G.2, Be in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />. These actions are the same as the proposed deletion of TS 3.3.13 Conditions D.1 and D.2, which require transitioning to 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 />, The NRC staff find the deleted Required Actions D.1 and D.1 to be reasonable, as these actions are now addressed under a revised TS 3.7.6 Condition G.
Additionally, SNC proposes revising TS 3.7.6 Condition H to incorporate into the new Condition F, if Condition F is not met. The Required Action is to immediately suspend the movement of irradiated fuel. This action is the same as the proposed deletion of TS 3.3.13 Condition E, which has the Required Action to immediately suspend the movement of irradiated fuel.
The NRC staff find the deleted TS Condition E to be reasonable, as these actions are now addressed under a revised TS 3.7.6 Condition H.
The proposed 7-day CT discussed above in Condition F would postpone entry into the proposed Conditions G and H until VES is restored. The NRC staff finds the revisions of TS 3.7.6 Conditions F, G and H acceptable due to the availability of VBS to temporarily backup VES, as discussed in Section 3.7.3.
Based on the above evaluation, the NRC staff finds that the proposed TS changes are acceptable. In addition, the NRC staff has determined that the proposed changes to TS 3.7.6 and TS 3.3.13 continue to meet the regulatory requirements of 10 CFR 50.36(c)(2). The revised TS will continue to describe the lowest functional capability or performance level of equipment necessary for the safe operation of the facility. Furthermore, the proposed remedial actions provide reasonable assurance that the plant will remain in a safe condition until the LCO can be met.
The NRC staff determined that the regulatory requirements of 10 CFR 50.36(c)(2) will continue to be met, because the modified TS will continue to describe the lowest functional capability or performance level of equipment required for safe operation of the facility and the remedial actions permitted by the TSs until the LCO can be met.
The NRC staff notes that, although the original application requested a 60-day implementation period, the licensee subsequently made a verbal request to extend the implementation period to 120 days. The licensee indicated that this extension was requested to accommodate the possibility that NRC approval may be granted earlier than originally estimated.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on November 19, 2025. On December 14, 2025, the there were no comments received from the State of Georgia official.
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 amendment involves no significant hazards consideration, and there has been no public comment on such finding on September 2, 2025 (90 FR 42457). 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: H. Wagage, NRR D. Coy, NRR M. Schwieg, NRR S. Meighan, NRR J. Parillo, NRR K. Hsu, NRR Date: December 31, 2025
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