ND-17-1519, Supplement to Request for License Amendment and Exemption Regarding Main Control Room Emergency Habitability System (Ves) Changes to Satisfy Post-Actuation Performance Requirements (LAR-17-001S1)

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Supplement to Request for License Amendment and Exemption Regarding Main Control Room Emergency Habitability System (Ves) Changes to Satisfy Post-Actuation Performance Requirements (LAR-17-001S1)
ML17258B211
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 09/15/2017
From: Whitley B
Southern Nuclear Operating Co
To:
Document Control Desk, Office of New Reactors
Shared Package
ML17258B210 List:
References
LAR-17-001S1, ND-17-1519
Download: ML17258B211 (41)
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Text

B. H. Whitley Southern Nuclear Director Operating Company, Inc.

Regulatory Affairs 42 Inverness Center Parkway Birmingham, AL 35242 Tel 205.992.7079 Fax 205.992.5296 September 15, 2017 Docket Nos.: 52-025 ND-17-1519 52-026 10 CFR 50.90 10 CFR 52.63 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Supplement to Request for License Amendment and Exemption Regarding Main Control Room Emergency Habitability System (VES) Changes to Satisfy Post-Actuation Performance Requirements (LAR-17-001S1)

Ladies and Gentlemen:

Southern Nuclear Operating Company, the licensee for Vogtle Electric Generating Plant Units 3 and 4, previously requested an amendment and exemption to Combined License (COL)

Numbers NPF-91 and NPF-92 to revise the licensing basis information to reflect design changes to the main control room emergency habitability system (VES) to address the main control room envelope temperature response. The requested amendment proposes to depart from approved AP1000 Design Control Document (DCD) Tier 2 information (text, tables, and figures) as incorporated into the Updated Final Safety Analysis Report (UFSAR) as plant-specific DCD information, and also proposes to depart from involved plant-specific Tier 1 information (and associated COL Appendix C information) and from involved plant-specific Technical Specifications (PS-TS) as incorporated in Appendix A of the COL. This request was provided by Southern Nuclears letter ND-17-0003 dated May 9, 2017 [ADAMS Accession No. ML17129A608]. Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design as certified in the 10 CFR Part 52, Appendix D, design certification rule was also requested for the involved Tier 1 information.

Subsequent to the submittal of SNC LAR-17-001, questions were asked of SNC by the NRC staff regarding the graphs depicting the time/temperature profiles for several of the cases (i.e.,

scenarios) discussed in LAR-17-001 and the applicability of the GOTHIC model used for the MCR heat up analysis in SNC LAR-17-001 to the model used for the William States Lee Nuclear Plant (WLS) Units 1 and 2 departure, presented in the Duke Energy Carolinas departure letter, WLG2016.0204, dated February 9, 2016 [ADAMS Accession No. ML16043A123].

Independent of the NRC staffs questions, SNC identified that two of the proposed licensing basis changes provided in original LAR-17-001 required revision.

The supplemental information is provided in Enclosures 10 and 11 (non-proprietary) and Enclosures 12 and 13 (proprietary) of this letter, which supplements the original LAR-17-001

U.S. Nuclear Regulatory Commission ND-17-1519 Page 2 of 5 provided in SNC letter ND-17-0003. Enclosures 1 through 9 were provided in SNC letter ND-17-0003.

x Enclosure 10 provides the non-proprietary (i.e., redacted) supplemental information in response to the NRC Staffs questions and the additional supplemental information identified by SNC following submittal of the original LAR.

x Enclosure 11 provides the non-proprietary (i.e., redacted) revised licensing basis markups resulting from the supplemental information discussed in Enclosure 10.

x Enclosure 12 provides the proprietary (i.e., non-redacted) version of the supplemental information in Enclosure 10. Enclosure 12 provides information that is considered to be proprietary; therefore, Enclosure 12 is requested to be withheld from disclosure to the public under 10 CFR 2.390.

x Enclosure 13 provides the proprietary (i.e., non-redacted) version of the revised licensing basis markups in Enclosure 11. Enclosure 13 provides information that is considered to be proprietary; therefore, Enclosure 13 is requested to be withheld from disclosure to the public under 10 CFR 2.390.

x Enclosure 14 provides the SNC affidavit for withholding proprietary information contained in Enclosures 12 and 13.

x Enclosure 15 provides the Westinghouse affidavit for withholding proprietary information contained in Enclosures 12 and 13. 5 provides Westinghouses Proprietary Information Notice, Copyright Notice and CAW-17-4605, Application for Withholding Proprietary Information from Public Disclosure and Affidavit. The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

Correspondence with respect to the copyright or proprietary aspects of the items listed above or the supporting Westinghouse affidavit should reference CAW-17-4605 and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

Correspondence with respect to proprietary aspects of this letter and its enclosures should also be addressed to Brian Whitley at the contact information within this letter.

The information provided in Enclosures 10 through 13 clarifies the information provided in the original license amendment request (LAR-17-001), but does not change the scope of, nor affect the Technical Evaluation or the Significant Hazards Consideration determination in SNCs original license amendment request submitted on May 9, 2017.

SNC requests staff approval of this license amendment by January 31, 2018, to support closure of the associated VES Inspections, Tests, Analyses and Acceptance Criteria (ITAAC). SNC expects to implement this proposed amendment (through incorporation into the licensing basis documents; e.g., the UFSAR) within 30 days of approval of the requested changes.

U.S. Nuclear Regulatory Commission ND-17-1519 Page 3 of 5 This letter contains no regulatory commitments. This letter has been reviewed and confirmed to not contain security-related information.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this LAR supplement by transmitting a copy of this letter and enclosure to the designated State Official.

Should you have any questions, please contact Mr. Wesley Sparkman at (205) 992-5061.

I declare under penalty of pe~ury that the foregoing is true and correct. Executed on the 151h of September 2017.

Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company

Enclosures:

1) - 9) (previously submitted with SNC's original LAR, LAR-17-001 , in SNC letter ND-17-0003)
10) Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Supplemental Information Regarding Request for License Amendment and Exemption: Main Control Room Emergency Habitability System (VES)

Changes to Satisfy Post-Actuation Performance Requirements (Publically Available Information) (LAR-17-001S1)

11) Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Supplemental Proposed Changes to the Licensing Basis Documents (Publically Available Information) (LAR-17-001S1)
12) Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Supplemental Information Regarding Request for License Amendment and Exemption: Main Control Room Emergency Habitability System (VES)

Changes to Satisfy Post-Actuation Performance Requirements (Withheld Information) (LAR-17-001S1)

13) Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Supplemental Proposed Changes to the Licensing Basis Documents (Withheld Information) (LAR-17-00181)
14) Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-17-001S1)
15) Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Westinghouse Authorization Letter CAW-17-4605, Affidavit, Proprietary Information Notice and Copyright Notice (LAR-17-00181)

U.S. Nuclear Regulatory Commission ND-17-1519 Page 4 of 5 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)

Mr. M. D. Rauckhorst Mr. D. G. Bost (w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. D. H. Jones (w/o enclosures)

Mr. D. L. McKinney (w/o enclosures)

Mr. T. W. Yelverton (w/o enclosures)

Mr. B. H. Whitley Mr. J. J. Hutto Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. E. W. Rasmussen Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Mr. M. K. Washington Ms. A. L. Pugh Mr. J. D. Williams Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

Mr. L. Burkhart (w/o enclosures)

Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Ms. V. Ordaz Mr. T. E. Chandler Ms. P. Braxton Mr. T. Brimfield Mr. C. J. Even Mr. A. Lerch State of Georgia Mr. R. Dunn (w/o enclosure 12 & 13)

Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 12 & 13)

Mr. K. T. Haynes (w/o enclosure 12 & 13)

Ms. A. Whaley (w/o enclosure 12 & 13)

U.S. Nuclear Regulatory Commission ND-17-1519 Page 5 of 5 Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 12 & 13)

Mr. S. M. Jackson (w/o enclosure 12 & 13)

Dalton Utilities Mr. T. Bundros (w/o enclosure 12 & 13)

Westinghouse Electric Company, LLC Mr. R. Easterling (w/o enclosures)

Mr. G. Koucheravy (w/o enclosures)

Mr. P. A. Russ Mr. M. L. Clyde Ms. L. Iler Mr. D. Hawkins Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc. (w/o enclosure 12 & 13)

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure 12 & 13)

Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure 12 & 13)

Ms. S. W. Kernizan, Georgia Public Service Commission (w/o enclosure 12 & 13)

Mr. K. C. Greene, Troutman Sanders (w/o enclosure 12 & 13)

Mr. S. Blanton, Balch Bingham Mr. R. Grumbir, APOG NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-17-1519 Enclosure 10 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplemental Information Regarding Request for License Amendment and Exemption:

Main Control Room Emergency Habitability System (VES) Changes to Satisfy Post-Actuation Performance Requirements (Publically Available Information)

(LAR-17-001S1)

(This Enclosure consists of 19 pages, including this cover page.)

ND-17-1519 0 Supplemental Information Regarding Request for License Amendment and Exemption: VES Changes to Satisfy Post-Actuation Performance Requirements (Publically Available Information)

(LAR-17-001S1)

Southern Nuclear Operating Company, the licensee for Vogtle Electric Generating Plant Units 3 and 4, has requested an amendment and exemption to Combined License (COL) Numbers NPF-91 and NPF-92 to revise the licensing basis information to reflect design changes to the main control room emergency habitability system (VES) to address the main control room envelope temperature response. This license amendment request (LAR), LAR-17-001, was provided by Southern Nuclears letter ND-17-0003 dated May 9, 2017 [ADAMS Accession No. ML17129A608].

Subsequent to the submittal of SNC LAR-17-001, questions were asked of SNC by the NRC Staff regarding the graphs depicting the time/temperature profiles for several of the cases (i.e.,

scenarios) discussed in LAR-17-001 and the applicability of the GOTHIC model used for the MCR heat up analysis in SNC LAR-17-001 to the model used for the William States Lee Nuclear Plant (WLS) Units 1 and 2 departure, presented in the Duke Energy Carolinas departure letter, WLG2016.0204, dated February 9, 2016 [ADAMS Accession No. ML16043A123].

Independent of the NRC Staffs questions, SNC identified that two of the proposed licensing basis changes provided in original LAR-17-001 required revision.

This enclosure provides responses to questions that were provided to support the NRC Staffs review of SNC LAR-17-001 and the changes identified by SNC following submittal of this LAR.

NRC Question 1:

Please provide the graphs for the following cases referred to in the LAR: Cases 3, 3a, 3b, 3d, 3e, and 3f, as applicable.

SNC Response 1:

The main control room (MCR) heat up calculation for the AP1000 design was revised to include additional sensitivities and other changes during recent efforts to close out open design items.

The cases and heat loads presented in LAR-17-001, Main Control Room Emergency Habitability System (VES) Changes to Satisfy Post-Actuation Performance Requirements, remain bounded by current analysis; however, the cases have been restructured in the analysis revision. The following graphs describe both the Revision 1 and Revision 2 analysis results. The analysis of record, continues to support the conclusions and heat loads presented in LAR 001.

Revision 2 of the MCR heat up calculation evaluated a limiting set of cases. The results indicate that optimized load shedding in response to loss of VBS can maintain the main control room envelope (MCRE) air temperature within the current licensing basis 72-hour limit. The updated Case 3 in Revision 2 has the same basic assumptions as Case 3e of Revision 1 and is modeled as follows:

  • The major difference between Case 3 of Revision 2 and Case 3e of Revision 1 is the modeling of the subfloor.
  • The Nuclear Island Nonradioactive Ventilation System (VBS) is turned off at time zero.
  • VES is turned on and Stage 1 heat loads modeled as heaters are de-energized at 31 minutes.

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ND-17-1519 0 Supplemental Information Regarding Request for License Amendment and Exemption: VES Changes to Satisfy Post-Actuation Performance Requirements (Publically Available Information)

(LAR-17-001S1)

  • Stage 2 heat loads modeled as heaters are de-energized at three hours and 31 minutes.
  • Heat loads powered by Non-Class 1E dc and Uninterruptible Power Supply System (EDS) 8-hour batteries and Class 1E dc Uninterruptible Power Supply System (IDS) 24-hour batteries are modeled as heaters and are manually de-energized at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
  • The transient duration is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or whenever the main control room envelope (MCRE) average air temperature exceeds the acceptance criterion.
  • Initial room temperatures are conservatively modeled, with average air temperatures for rooms outside of the MCRE normally maintained at less than or equal to 85°F increased by 2°F to 87°F.
  • The initial average air temperature of the MCRE, room 12401, above the subfloor is modeled at 75°F. The initial air temperature for the room 12401 subfloor, which is normally maintained by a VBS supply air temperature of 52°F, is modeled at 60°F. A sensitivity analysis was also performed modeling the subfloor at an increased temperature of 75°F; this case is described in the response to NRC Question 2.
  • Peak Outside ambient air temperature is modeled at 115°F for the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and 101°F after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.
  • Heat loads are increased by 1%.

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(a,c)

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ND-17-1519 0 Supplemental Information Regarding Request for License Amendment and Exemption: VES Changes to Satisfy Post-Actuation Performance Requirements (Publically Available Information)

(LAR-17-001S1)

The maximum average air temperature reached in the MCRE within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, with load shedding, is below acceptance criterion of 95°F dry bulb and remains below the wet bulb globe temperature (WBGT) index acceptance criterion of 90°F for the entirety of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The peak MCRE average air temperature is reached approximately 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> into the transient. With equipment powered by alternating current (ac) power sources with no battery backup, MCRE average air temperature starts to decrease at the 1-hour mark. With more load shedding performed at later hours, the MCRE average air temperature is maintained below 95°F.

Revision 2 of the analysis did not include all of the variations as the Revision 1 analysis. The only additional variation of Case 3 in this revision was Revision 2 Case 3d which is the same as Revision 2 Case 3 but reflects a different termination of loads at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. This case serves as the analysis of record and bounds either:

x Operation of non-safety communication equipment in the event that the Technical Support Center is not available. For this event it is assumed that the EDS batteries are exhausted prior to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. These loads are bounded by cases where ac power is available, thus no specific modelling is performed.

x Operation of the VES with ac power available. The exhaustion of the EDS batteries is not considered and the following loads are terminated at 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

o Site-supplied laptops o 24-hour emergency lighting and associated power panels are reduced/eliminated o Emergency Lighting (Integral Sealed Battery)

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(a,c)

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(LAR-17-001S1)

Case 6 is a post-72-hour analysis, completed in Revision 2, which assumed the following post-72-hour initial conditions:

x Initial conditions of rooms and heat sinks are set up by the Case 3 72-hour runs.

x 72-hour loads, powered by the Division B 72-Hour Battery (IDSB) and Division C 72-Hour Battery (IDSC), and operators, are heaters post-72 hours. (8 and 24-hour items are shed).

x VBS fans are in operation after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with 1,700 cfm pulling air from outside the auxiliary building into the main control room (MCR). The coolers placed within other auxiliary building rooms that represent the VBS are also tripped on at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

x The VES is turned off when the VBS is actuated at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

x The MCR door to vestibule and vestibule door to corridor are in open positions.

An additional 96-hour duration is modeled as a transient to determine the room response for severe accident/dose assessment assumptions. Case 6 in Revision 2 is similar to Case 3f in Revision 1.

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(a,c)

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(LAR-17-001S1)

Revision 1 of the analysis included Cases 3, 3a, 3b, 3d, 3e, and 3f. These were not updated in Revision 2, but the assumptions in the above cases bound these variations. Descriptions and results from each of these cases are included below for completeness. The Revision 1 Case 3 is modeled as follows

x VBS is turned off at time zero.

x VES is turned on and Stage 1 heat loads, which are modeled as heaters, are de-energized at 31 minutes.

x Stage 2 heat loads are modeled as heaters and are de-energized at 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> and 31 minutes.

x Heat loads powered by EDS batteries are modeled as heaters and are de-energized at eight hours (approximate time of battery exhaustion).

x Remaining heat loads powered by IDS 24-hour batteries are modeled as heaters and are manually de-energized at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

x The transient duration is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or whenever the MCRE average air temperature exceeds the acceptance criterion.

x Initial room temperatures are conservatively modeled, with average air temperatures for rooms outside of the MCRE, normally maintained at less than or equal to 85°F, increased by 2°F to 87°F.

x The initial average air temperature of the MCRE, room 12401, above the subfloor is modeled at 75.25°F.

Peak Outside ambient air temperature is modeled at 115°F for the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, and 101°F after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

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(a,c)

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Variations of Case 3 were also run in Revision 1 and all had satisfactory results. For cases run out to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, the MCRE temperature remained below 95°F (3a, 3b, 3d, and 3e) and for Case 3f, which was run between 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br />, the MCRE temperature remained below 110°F (dry bulb). These cases evaluated the following sensitivities:

Revision 1 Case 3a evaluates prolonged operation of the EDS batteries, the 8-hour heaters are turned off at 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> (i.e., 4 additional hours of operation modeled). This is bounded by Revision 2 Case 3 because the heat loads from the 8-hour heaters are assumed to last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

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(a,c)

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Revision 1 Case 3b evaluates the tolerance of the results to heat load variations, with 1% more heat load added to every heater and increased temperatures in certain control volumes from 105°F to 130°F. This is bounded by Revision 2 Case 3 because the heat loads include 1%

increase as well as other conservative assumptions.

(a,c)

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(LAR-17-001S1)

Revision 1 Case 3d evaluates the effect of changes to air temperatures surrounding the MCRE using different control volume initial temperatures, including the upper limit Technical Specification temperatures at the beginning of the transient.

(a,c)

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(LAR-17-001S1)

Revision 1 Case 3e uses the same bounding assumptions as Revision 2 Case 3. The load shedding for the 8-hour EDS batteries and 24-hour IDS loads is done at the same time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and alternate mixing assumptions are used for the analysis.

(a,c)

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(LAR-17-001S1)

Revision 1 Case 3f is a variation of Revision 1 Case 3b as a post-72-hour analysis. The 72-hour loads and the operators are modeled as heaters post-72 hours, with the VBS fans in operation with 1,700 cfm of 115°F hot air discharged into the MCRE. An additional 96-hour duration is modeled as a transient to determine the room response for severe accident/dose assessment assumptions.

(a,c)

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NRC Question 2:

Please confirm that the GOTHIC model used for SNC LAR-17-001 is identical to that used in the Levy submittals with the exception of the heat loads and temperature boundary conditions, as applicable.

SNC Response 2:

The GOTHIC model used for the MCR heat up analysis in LAR-17-001 and the model used in the Duke Energy submittals (i.e., William States Lee Letter WLG2016.02-04, dated February 9, 2016 [ML16043A123], which incorporates by reference the corresponding Levy Nuclear Station submittals on this same subject) are the same. It should be noted that some changes were evaluated in response to customer comments and it was determined that the analysis of record remains applicable (i.e., bounding). The comments were regarding site-specific heat loads and an increased subfloor temperature from 60°F to 75°F. The additional cases that were analyzed are explained in the response to Question 1.

The site-specific MCR heat loads have increased with the finalization of the MCR design and the completion of updated calculations to meet Emergency Preparedness (EP) licensing commitments. Margin exists between the maximum analyzed heat loads and the loads for the expected standard plant equipment such that the addition of EP equipment will not violate the values in the licensing basis.

(a,c)

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(a,c)

Use of the sensitivity case as the heat load limit in Tier 1 Table 2.2.5-4 and UFSAR Tier 2 Table 6.4-3 is conservative because these loads will result in less severe heatup than the limiting case, Case 3d; thereby requiring a more limiting acceptance criteria in the associated ITAAC.

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(LAR-17-001S1)

Licensee-Identified Updates to Licensing Basis Markups in LAR-17-001 Independent of the NRC Staffs questions, SNC identified that two of the proposed licensing basis changes provided with the original LAR-17-001, in letter ND-17-001, Enclosures 3 and 9, required revision. A description of the revised markups is provided below; the revised markups of the licensing basis documents are provided in Enclosures 11 (non-proprietary) and 13 (proprietary) of this letter.

1. Letter No. ND-17-0003, Enclosure 3, page 26 of 35, provided a excerpt of the markup of UFSAR Figure 7.2-1 (Sheet 13 of 21), Functional Diagram Containment and Other Protection. The markup shows changes to add electrical load de-energization to the functional logic relating to the main control room isolation and air supply initiation. The markup also shows changes to several logic names from Control Room to MCR to better align the UFSAR terminology in figures and sections. One logic name change from HIGH-2 CONTROL ROOM AIR SUPPLY RADIOACTIVITY inadvertently omitted -2 from the logic in the figure. The revised figure shown in Enclosures 11 and 13 of this letter returns the -2 by identifying the revised logic title as: HIGH-2 MCR AIR SUPPLY RADIOACTIVITY.
2. Letter No. ND-17-0003, Enclosure 3 (Non-Proprietary), page 31 of 35, and Enclosure 9 (Proprietary), pages 2 and 3 of 3, provided markups to add revised text from WCAP-16438-P/NP, Revision 7, to UFSAR Appendix 7A. It was subsequently identified that the load and cabinet equipment tag numbers in the Division C table incorrectly mimicked those in the Division A table. The revised markup in Enclosures 11 and 13 of this letter corrects these equipment tag numbers in the Division C table, by showing how the load shed panels are added to WCAP-16438-N/NP, Revision 7.

Page 19 of 19

Southern Nuclear Operating Company ND-17-1519 Enclosure 11 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplemental Proposed Changes to the Licensing Basis Documents (Publically Available Information)

(LAR-17-001S1)

Additions are identified by blue underlined text.

Revised areas of figures are shown in red bubbles.

Revision bars are provided in the right-hand margin, adjacent to the area of change from the original LAR-17-001.

(This Enclosure consists of 3 pages, including this cover page.)

ND-17-1519 1 Supplemental Proposed Changes to the Licensing Basis Documents (Publically Available Information) (LAR-17-001S1)

NOTE: This page replaces ND-17-0003, Enclosure 3, page 26 of 35 in its entirety.

UFSAR Tier 2 Figure 7.2-1 (Sheet 13 of 21)

Functional Diagram Containment and Other Protection Revise the right hand side of UFSAR Tier 2 Figure 7.2-1 (Sheet 13 of 21), as depicted in the excerpt below:

Page 2 of 3

ND-17-1519 1 Supplemental Proposed Changes to the Licensing Basis Documents (Publically Available Information) (LAR-17-001S1)

NOTE: This page replaces ND-17-0003, Enclosure 3, page 31 of 35 in its entirety.

UFSAR Tier 2 Subsection 7A.4 WCAP-16438-P and WCAP-16438-NP, FMEA of AP1000 TM Protection and Safety Monitoring System Revise Tier 2 text in UFSAR Appendix 7A, Instrumentation and Controls Licensing Basis Document Changes, by adding a new bullet in Subsection 7A.4, WCAP-16438-P and WCAP-16438-NP, FMEA of AP1000 TM Protection and Safety Monitoring System, after the bullet for the revision to the BIBLIOGRAPHY section, as provided below.

x Revise Appendix A, Failure Impact on Plant, as per the following directions:

(a,c)

Page 3 of 3

Southern Nuclear Operating Company ND-17-1519 Enclosure 14 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-17-001S1)

(This Enclosure consists of 2 pages, plus this cover page.)

ND-17-1519 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-17-001S1)

Affidavit of Brian H. Whitley

1. My name is Brian H. Whitley. I am the Regulatory Affairs Director of Southern Nuclear Operating Company (SNC). I have been delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized to apply for its withholding on behalf of SNC.
2. I am making this affidavit on personal knowledge, in conformance with the provisions of 10 CFR Section 2.390 of the Commissions regulations, and in conjunction with SNCs filing on dockets52-025 and 52-026, Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for License Amendment and Exemption Regarding Main Control Room Emergency Habitability System (VES) Changes to Satisfy Post-Actuation Performance Requirements (LAR-17-001S1), also referred to as APP-GW-GLR-621, Supplement to APP-FSAR-GLN-545 Revision 0 (Proprietary). I have personal knowledge of the criteria and procedures used by SNC to designate information as a trade secret, privileged or as confidential commercial or financial information.
3. Based on the reason(s) at 10 CFR 2.390(a)(4), this affidavit seeks to withhold from public disclosure Enclosures 12 and 13 of SNC letter ND-17-1519 for Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for License Amendment and Exemption Regarding Main Control Room Emergency Habitability System (VES) Changes to Satisfy Post-Actuation Performance Requirements (LAR-17-001S1).
4. The following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
a. The information sought to be withheld from public disclosure has been held in confidence by SNC and Westinghouse Electric Company.

Page 1 of 2

ND-17-1519 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-17-001S1)

b. The information is of a type customarily held in confidence by SNC and Westinghouse Electric Company and not customarily disclosed to the public.
c. The release of the information might result in the loss of an existing or potential competitive advantage to SNC and/or Westinghouse Electric Company.
d. Other reasons identified in Enclosure 15 of SNC letter ND-17-1519 forVogtle Electric Generating Plant Units 3 and 4, Supplement to Request for License Amendment and Exemption Regarding Main Control Room Emergency Habitability System (VES)

Changes to Satisfy Post-Actuation Performance Requirements (LAR-17-001S1), and those reasons are incorporated here by reference.

5. Additionally, release of the information may harm SNC because SNC has a contractual relationship with the Westinghouse Electric Company regarding proprietary information.

SNC is contractually obligated to seek confidential and proprietary treatment of the information.

6. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
7. To the best of my knowledge and belief, the information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method.

I declare under penalty of perjury that the foregoing is true and correct.

---~'~.,...._*_W_..:....{J._'Jd_-......:.4J.r-----------

~~H. Whitley Executed on "{lfJ1 1 Date Page 2 of2

Southern Nuclear Operating Company ND-17-1519 Enclosure 15 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Westinghouse Authorization Letter CAW-17-4605, Affidavit, Proprietary Information Notice and Copyright Notice (LAR-17-001S1)

(This Enclosure consists of 10 pages, plus this cover page.)

Westinghouse Non-Proprietary Class 3

@Westinghouse Westinghouse Electric Company New Plants and Major Projects 1000 Westinghouse Drive, Building 1 Cranberry Township, Pennsylvania 16066 USA Document Control Desk Direct tel: (412) 374-3382 U S Nuclear Regulatory Commission Direct fax: (724) 940-8505 Washington, DC 20852-2738 e-mail: russpa@westinghouse.com Proj letter: SVP_SV0_004998 CAW-17-4605 August 17,2017 APPLICATION FOR WITHHOLDING PROPRIETARY INFORMATION FROM PUBLIC DISCLOSURE

Subject:

"Supplement to APP-FSAR-GLN-545 Revision 0 (Proprietary)"

The Application for Withholding Proprietary Information from Public Disclosure is submitted by Westinghouse Electric Company LLC ("Westinghouse"), pursuant to the provisions of paragraph (b)( 1) of Section 2.390 of the Nuclear Regulatory Commission's ("Commission's") regulations. It contains commercial strategic information proprietary to Westinghouse and customarily held in confidence.

The proprietary information for which withholding is being requested in the above-referenced report is further identified in Affidavit CAW-17-4605 signed by the owner of the proprietary information, Westinghouse. The Affidavit, which accompanies this letter, sets forth the basis on which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of 10 CPR Section 2.390 of the Commission's regulations.

Accordingly, this letter authorizes the utilization of the accompanying Affidavit by Southern Nuclear Company.

Correspondence with respect to the proprietary aspects of the Application for Withholding or the Westinghouse Affidavit should reference CAW-17-4605, and should be addressed to James A. Gresham, Manager, Regulatory Compliance, Westinghouse Electric Company, 1000 Westinghouse Drive, Building 3 Suite 310, Cranberry Township, Pennsylvania 16066.

Very truly yours,

<kdct~

Paul A. Russ, Director Licensing & Regulatory Support

© 2017 Westinghouse Electric Company LLC. All Rights Reserved.

Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company New Plants and Major Projects 1000 Westinghouse Drive, Building 1 Cranberry Township, Pennsylvania 16066 USA Enclosures to CAW-17-4605

1. AFFIDAVIT CAW-17-4605
2. PROPRIETARY INFORMATION NOTICE and COPYRIGHT NOTICE
3. APP-GW-GLR-621 Revision 0, Supplement to APP-FSAR-GLN-545 Revision 0 (Proprietary)
4. APP-GW-GLR-622 Revision 0, Supplement to APP-FSAR-GLN-545 Revision 0 (Non-Proprietary)

© 2017 Westinghouse Electric Company LLC. All Rights Reserved.

ENCLOSURE 1 to CAW-17-4605 AFFIDAVIT

Westinghouse Non-Proprietary Class 3 CAW-17-4605 August 17,2017 AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA:

ss COUNTY OF BUTLER:

I, Paul A. Russ, am authorized to execute this Mfidavit on behalf of Westinghouse Electric Company LLC ("Westinghouse"), and declare that the averments of fact set forth in this Affidavit are true and correct to the best of my knowledge, information, and belief.

Paul A. Russ, Director Licensing & Regulatory Support

Westinghouse Non-Proprietary Class 3 CAW-17-4605 2 August 17, 2017 (1) I am Director, Licensing & Regulatory Support, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

(2) I am making this Affidavit in conformance with the provisions of 10 CFR Section 2.390 of the Nuclear Regulatory Commissions (Commissions) regulations and in conjunction with the Westinghouse Application for Withholding Proprietary Information from Public Disclosure accompanying this Affidavit.

(3) I have personal knowledge of the criteria and procedures utilized by Westinghouse in designating information as a trade secret, privileged or as confidential commercial or financial information.

(4) Pursuant to the provisions of paragraph (b)(4) of Section 2.390 of the Commissions regulations, the following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.

(i) The information sought to be withheld from public disclosure is owned and has been held in confidence by Westinghouse.

(ii) The information is of a type customarily held in confidence by Westinghouse and not customarily disclosed to the public. Westinghouse has a rational basis for determining the types of information customarily held in confidence by it and, in that connection, utilizes a system to determine when and whether to hold certain types of information in confidence. The application of that system and the substance of that system constitute Westinghouse policy and provide the rational basis required.

Under that system, information is held in confidence if it falls in one or more of several types, the release of which might result in the loss of an existing or potential competitive advantage, as follows:

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of

Westinghouse Non-Proprietary Class 3 CAW-17-4605 3 August 17, 2017 Westinghouses competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

(b) It consists of supporting data, including test data, relative to a process (or component, structure, tool, method, etc.), the application of which data secures a competitive economic advantage, e.g., by optimization or improved marketability.

(c) Its use by a competitor would reduce his expenditure of resources or improve his competitive position in the design, manufacture, shipment, installation, assurance of quality, or licensing a similar product.

(d) It reveals cost or price information, production capacities, budget levels, or commercial strategies of Westinghouse, its customers or suppliers.

(e) It reveals aspects of past, present, or future Westinghouse or customer funded development plans and programs of potential commercial value to Westinghouse.

(f) It contains patentable ideas, for which patent protection may be desirable.

(iii) There are sound policy reasons behind the Westinghouse system which include the following:

(a) The use of such information by Westinghouse gives Westinghouse a competitive advantage over its competitors. It is, therefore, withheld from disclosure to protect the Westinghouse competitive position.

(b) It is information that is marketable in many ways. The extent to which such information is available to competitors diminishes the Westinghouse ability to sell products and services involving the use of the information.

(c) Use by our competitor would put Westinghouse at a competitive disadvantage by reducing his expenditure of resources at our expense.

Westinghouse Non-Proprietary Class 3 CAW-17-4605 4 August 17, 2017 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

(e) Unrestricted disclosure would jeopardize the position of prominence of Westinghouse in the world market, and thereby give a market advantage to the competition of those countries.

(f) The Westinghouse capacity to invest corporate assets in research and development depends upon the success in obtaining and maintaining a competitive advantage.

(iv) The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.

(v) The information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method to the best of our knowledge and belief.

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in APP-GW-GLR-621 Revision 0, Supplement to APP-FSAR-GLN-545 (Proprietary), for submittal to the Commission, being transmitted by Southern Nuclear Company letter. The proprietary information as submitted by Westinghouse is that associated with changes to main control room heat up and load shed, and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to:

(i) Provide the NRC and SNC with technical information related to the changes for the main control room heat up issue.

Westinghouse Non-Proprietary Class 3 CAW-17-4605 5 August 17, 2017 (b) Further this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of similar information to its customers for the purpose of providing products and services.

(ii) Westinghouse can sell support and defense of industry guidelines and acceptance criteria for plant-specific applications.

(iii) The information requested to be withheld reveals the distinguishing aspects of a methodology which was developed by Westinghouse.

Public disclosure of this proprietary information is likely to cause substantial harm to the competitive position of Westinghouse because it would enhance the ability of competitors to provide similar technical evaluation justifications and licensing defense services for commercial power reactors without commensurate expenses. Also, public disclosure of the information would enable others to use the information to meet NRC requirements for licensing documentation without purchasing the right to use the information.

The development of the technology described in part by the information is the result of applying the results of many years of experience in an intensive Westinghouse effort and the expenditure of a considerable sum of money.

In order for competitors of Westinghouse to duplicate this information, similar technical programs would have to be performed and a significant manpower effort, having the requisite talent and experience, would have to be expended.

Further the deponent sayeth not.

ENCLOSURE 2 to CAW-17-4605 PROPRIETARY INFORMATION NOTICE and COPYRIGHT NOTICE

CAW-17-4605 August 17, 2017 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and/or non-proprietary versions of documents furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

In order to conform to the requirements of 10 CFR 2.390 of the Commissions regulations concerning the protection of proprietary information so submitted to the NRC, the information which is proprietary in the proprietary versions is contained within brackets, and where the proprietary information has been deleted in the non-proprietary versions, only the brackets remain (the information that was contained within the brackets in the proprietary versions having been deleted). The justification for claiming the information so designated as proprietary is indicated in both versions by means of lower case letters (a) through (f) located as a superscript immediately following the brackets enclosing each item of information being identified as proprietary or in the margin opposite such information. These lower case letters refer to the types of information Westinghouse customarily holds in confidence identified in Sections (4)(ii)(a) through (4)(ii)(f) of the Affidavit accompanying this transmittal pursuant to 10 CFR 2.390(b)(1).

COPYRIGHT NOTICE The reports transmitted herewith each bear a Westinghouse copyright notice. The NRC is permitted to make the number of copies of the information contained in these reports which are necessary for its internal use in connection with generic and plant-specific reviews and approvals as well as the issuance, denial, amendment, transfer, renewal, modification, suspension, revocation, or violation of a license, permit, order, or regulation subject to the requirements of 10 CFR 2.390 regarding restrictions on public disclosure to the extent such information has been identified as proprietary by Westinghouse, copyright protection notwithstanding. With respect to the non-proprietary versions of these reports, the NRC is permitted to make the number of copies beyond those necessary for its internal use which are necessary in order to have one copy available for public viewing in the appropriate docket files in the public document room in Washington, DC and in local public document rooms as may be required by NRC regulations if the number of copies submitted is insufficient for this purpose. Copies made by the NRC must include the copyright notice in all instances and the proprietary notice if the original was identified as proprietary.

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