Text

Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)
	ML18031B131
Person / Time
Site:	Vogtle
Issue date:	01/31/2018
From:	Sparkman W; Southern Nuclear Operating Co
To:	; Document Control Desk, Office of New Reactors
References
	LAR-18-004, ND-18-0053
	Download: ML18031B131 (53)
	v • d • e

Southern Nuclear Operating Company, Inc.

42 Inverness Center Parkway Birmingham, AL 35242 January 31, 2018 Docket Nos.: 52-025 ND-18-0053 52-026 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment:

Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC), requests an amendment to Combined Licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 (License Nos. NPF-91 and NPF-92, respectively). The requested amendment requires changes to the VEGP Units 3 and 4 COL Appendix A, Technical Specifications (TS). Because the proposed changes impact the Technical Specifications, this activity has been determined to require prior NRC approval.

The request includes proposed changes to TS 3.4.6, Pressurizer Safety Valve, Applicability to require the pressurizer safety valves (PSVs) to be operable when the TS 3.4.14, Low Temperature Overpressure Protection, is not required to be operable. A conforming change to the TS 3.4.6 Actions is also proposed. Additional TS changes necessary to support PSV operability are proposed for consistency with the TS 3.4.6 change.

The request also proposes moving TS Limiting Condition for Operation (LCO) Notes regarding reactor coolant pump (RCP) starts from TS 3.4.4, Reactor Coolant System (RCS) Loops, 3.4.8, Minimum RCS Flow, and 3.4.14 to TS 3.4.3 RCS Pressure / Temperature (P/T) Limits. provides the description, technical evaluation, regulatory evaluation (including the significant hazards consideration determination), and environmental considerations for the proposed changes. provides the proposed changes to the licensing basis document. provides conforming Technical Specification Bases changes for information only.

U.S. Nuclear Regulatory Commission ND-18-0053 Page 2 of 4 This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security related information.

SNC requests NRC staff review and approval of the license amendment no later than July 31, 2018. Approval by this date will allow sufficient time to implement licensing basis changes necessary to support procedure development in relation to conducting the necessary operator training to support plant operations. SNC expects to implement the proposed amendment within thirty days of approval.

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

Should you have any questions, please contact Mr. Adam Quarles at (205) 992-7031.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 31st of January 2018.

Respectfully submitted, Enclosures 1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Proposed Changes to Licensing Basis Documents (LAR-18-004)

3) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Conforming Technical Specification Bases Changes (For Information Only) (LAR-18-004)

U.S. Nuclear Regulatory Commission ND-18-0053 Page 3 of 4 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. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. J. D. Williams Mr. F. J. Redwanz Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Mr. F. Brown Mr. T.E. Chandler Ms. P. Braxton Mr. T. Brimfield Mr. C. J. Even Mr. A. Lerch State of Georgia Mr. R. Dunn Oglethorpe Power Corporation Mr. M. W. Price Mr. K. T. Haynes Ms. A. Whaley

U.S. Nuclear Regulatory Commission ND-18-0053 Page 4 of 4 Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)

Mr. G. Koucheravy (w/o enclosures)

Mr. M. Corletti Mr. M. L. Clyde Ms. L. Iller Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders 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-18-0053 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

(This Enclosure consists of 17 pages, including this cover page.)

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION AND TECHNICAL EVALUATION

3. TECHNICAL EVALUATION (Included in Section 2)

4. REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria 4.2. Precedent 4.3. Significant Hazards Consideration 4.4. Conclusions

5. ENVIRONMENTAL CONSIDERATIONS

6. REFERENCES Page 2 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Combined License (COL) Nos.

NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.

1.

SUMMARY

DESCRIPTION The requested amendment proposes changes to COL Appendix A, Technical Specifications (TS). Two groups of changes are proposed.

Change 1 proposes a revision to the Technical Specification (TS) 3.4.6, Pressurizer Safety Valve, Applicability to require the pressurizer safety valves (PSVs) to be operable when the TS 3.4.14, Low Temperature Overpressure Protection, is not required to be operable. The PSV Applicability is proposed to be Modes 1, 2, and 3, and Mode 4 when all four cold leg temperatures are > 275°F. A conforming change to the TS 3.4.6 Actions is also proposed.

Additionally, the following TS changes necessary to support PSV operability are proposed for consistency with the TS 3.4.6 change:

TS 3.3.8, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, Table 3.3.8-1 Function 9, Pressurizer Water Level - High 2 and Function 10, Pressurizer Water Level, High 3, Applicability revised, as well as conforming changes to the Actions. An additional editorial change is proposed to Table 3.3.8-1 Function 10, nomenclature to remove the , (comma) and add a - (hyphen) between Level and High 3,

TS 3.3.9, ESFAS Manual Initiation, Table 3.3.9-1 Function 10, Chemical and Volume Control System (CVS) Makeup Isolation, Applicability revised,

TS 3.3.15, ESFAS Actuation Logic - Operating, the Note to the Surveillance Requirement (SR) stating Verify pressurizer heater circuit breakers trip open on an actual or simulated actuation signal revised,

TS 3.4.4, Reactor Coolant System (RCS) Loops, Limiting Condition for Operation (LCO) Note 1 deleted,

TS 3.4.5, Pressurizer, Applicability revised, as well as conforming changes to the Actions,

TS 3.4.8, Minimum RCS Flow, LCO Note 2 deleted,

TS 3.4.14, Low Temperature Overpressure Protection (LTOP), LCO Note 1 deleted, and

TS 3.4.16, Reactor Vessel Head Vent (RVHV) Applicability revised, as well as conforming changes to the Actions.

Change 2 proposes moving TS LCO Notes stating No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of RCP speed from TS 3.4.4, Reactor Coolant System (RCS) Loops, Page 3 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004) 3.4.8, Minimum RCS Flow, and 3.4.14 to TS 3.4.3 RCS Pressure / Temperature (P/T)

Limits.

This enclosure requests approval of the license amendment necessary to implement the COL Appendix A changes.

2. DETAILED DESCRIPTION AND TECHNICAL EVALUATION Change 1: Alignment of TS Related to PSV Operability As described in UFSAR section 5.2.2, overpressure protection of the RCS during power operation is provided by the PSVs, in conjunction with the action of the reactor protection system. This combination is compliant with the overpressure protection requirements of the ASME Boiler and Pressure Vessel Code,Section III. However, with any RCS cold leg 275°F, LTOP is provided by relief valves in the suction line of the normal residual heat removal (RNS) system.

As described in UFSAR section 5.4.9, PSVs connected to the pressurizer provide overpressure protection for the RCS during power operation. The relief valves on the suction line of the normal residual heat removal system (RNS) provide LTOP during shutdown operations. The PSVs and the RNS relief valves are spring-loaded, self-actuated by direct fluid pressure, and have backpressure compensation features. These valves are designed to reclose and prevent further flow of fluid after normal conditions have been restored.

During Modes 1, 2, and 3, and Mode 4 when the RNS is isolated or when RCS temperature is 275°F, the PSVs provide overpressure protection, as required by TS 3.4.6, Pressurizer Safety Valves. The supporting safety analyses (as described in UFSAR Chapter 15) and shutdown Mode assessments (as described in UFSAR Chapter 19E) that apply when the PSVs are credited for overpressure protection of the RCS also credit the following functions, since PSVs are designed to relieve steam and are not qualified for liquid water relief; therefore, pressurizer overfill must be prevented when the PSVs are credited for overpressure protection:

presence of a pressurizer steam bubble (UFSAR subsection 5.4.7.4, as well as subsection 19E.3.1.3.2, discusses the requirements for a pressurizer steam bubble during startup and shutdown, a steam bubble in the pressurizer is required to be formed prior to isolation of the RNS),

actuation of High-2 pressurizer water level engineered safety feature (ESF) (UFSAR Table 7.3-1 shows that a High-2 pressurizer water level signal initiates chemical and volume control system (CVS) makeup isolation),

actuation of High-3 pressurizer water level ESF (UFSAR Table 7.3-1 shows that a High-3 pressurizer water level signal actuates passive residual heat removal (PRHR) and trips the pressurizer heaters),

capability to manually isolate CVS makeup, and Page 4 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

capability to manually vent through the RVHV (UFSAR section 5.4.12.1 describes the function of the vent arrangement to prevent long-term pressurizer overfill and required operator action).

TS LCO 3.4.14 Low Temperature Overpressure Protection is required in Mode 4 when any cold leg temperature is 275°F, Mode 5, and Mode 6 when the reactor vessel head is on. It requires that one of two methods of overpressure protection shall be operable; either two RNS suction relief valves aligned, or the RCS depressurized and vented with a vent area of 4.15 square inches. During these Modes, the RNS relief valves (or RCS vents) provide overpressure protection of the RCS. The supporting LTOP analyses do not credit a steam bubble in the pressurizer, nor do they credit the High-2 or High-3 pressurizer level ESF actuations, manual makeup isolation, or RVHV. The RNS relief valves required by TS 3.4.14 are qualified for water relief; therefore, the pressurizer bubble requirement is not required to support LTOP operability. It should be noted that although the RNS may be aligned to the RCS above 275°F, LTOP is not required to be operable per TS 3.4.14 until at least one cold leg temperature is 275°F, and therefore the PSVs are still credited means of RCS overpressure protection above 275°F.

The current TS LCO 3.4.6 Applicability has two Mode 4 conditions, MODE 4 with Normal Residual Heat Removal System (RNS) isolated, and MODE 4 with RCS temperatures 275°F. The current Mode 4 applicability does not adequately capture the plant conditions where the PSVs are required for overpressure protection. In order to simplify the Applicability and clarify when PSVs are needed, the Mode 4 Applicability is changed to MODE 4 with all four cold leg temperatures > 275°F. This change simplifies to a cold leg temperature requirement that appropriately reflects the opposite of the TS 3.4.14 LTOP Mode 4 Applicability.

Currently, although credited in safety analysis when PSVs provide overpressure protection of the RCS (i.e., Modes 1, 2, 3 and Mode 4 > 275°F), TS 3.3.8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation requires the High-2 and High-3 pressurizer water level ESF signals (CVS makeup isolation on High-2 and PRHR actuation and pressurizer heater trip on High-3) to be operable in Modes 1, 2, 3, and Mode 4 above P-19 (i.e., 700 psig) with the RCS not being cooled by the RNS. This means that Mode 4 operability is not required if pressure is below P-19 or the RCS is being cooled by the RNS.

This creates a gap when RCS pressure is less than 700 psig but temperature is above 275°F, during which time the high pressurizer level ESF signals are currently not required to be operable while the PSVs are credited for overpressure protection. In order to address the gap in Applicability, it is proposed to change the Pressurizer Water Level - High 2 and High-3 (Table 3.3.8-1 Functions 9 and 10, respectively) Mode 4 Applicability (Note (g)) to be With all four cold leg temperatures > 275°F. This removes the P-19 reference and ensures that the ESF signals that protect against pressurizer overfill when the PSVs are credited for overpressure protection will be in place until the RNS can be credited for overpressure protection. For consistency, a change is also proposed to be made to the Note for the TS 3.3.15 SR that states Verify pressurizer heater circuit breakers trip open on an actual or simulated actuation signal. This SR is for an actuated device test corresponding to ESFAS actuation on Pressurizer Water Level - High 3. The proposed Note change is to remove the reference to Mode 4 above the P-19 (RCS Pressure) interlock with the RCS not being Page 5 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004) cooled by RNS and change to when all four cold leg temperatures are > 275°F. All four cold leg temperatures > 275°F is consistent with Modes 1, 2, 3, and 4, as cold leg temperatures will not be greater than 275°F in Modes 5 and 6 and inversely, cold leg temperatures will not be less than 275°F in Modes 1, 2, or 3.

Additionally, the TS Table 3.3.8-1 Function 10 listed Condition should be modified from Condition F (which requires action to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in Mode 4 with RCS cooling provided by RNS in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months ) to a proposed new Condition Q. Condition F does not provide the Actions consistent with the proposed changes to the TS Applicability Note (g).

Proposed new Action Q, Required Action Q.1, requires actions to be in Mode 3 in 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and Required Action Q.2 requires action to be in Mode 4 with at least one cold leg temperature 275°F in 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , thereby exiting the proposed Applicability. The additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months beyond the current 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach Mode 4 allows an appropriate time to also achieve RCS temperature reduction to 275°F. The Completion Time is consistent with the current completion time for TS 3.4.6 Required Action B.2.

An additional editorial change is proposed to Table 3.3.8-1 Function 10, nomenclature to remove the , (comma) and add a - (hyphen) between Level and High 3. This change makes the Function name consistent with the other Functions in the table.

TS 3.3.9 ESFAS Manual Initiation requires the manual CVS makeup isolation signal to be operable in Modes 1, 2, and 3, and Mode 4 with the RCS not being cooled by the RNS. The purpose of the manual makeup isolation signal (as stated in the corresponding TS Bases) is to prevent pressurizer overfill, which protects PSV operability. As such, the Applicability is proposed to be changed to be consistent with the proposed change to TS 3.4.6 Applicability.

TS 3.4.16 for the RVHV has a similar Applicability requirement: in Modes 1, 2, and 3, and Mode 4 with the RCS not being cooled by the RNS. The RVHV is credited to prevent pressurizer overfill when the PSVs provide overpressure protection, so the TS 3.4.16 Applicability is similarly proposed to be modified to align with the proposed Applicability for TS 3.4.6.

TS 3.4.5 currently requires the pressurizer level to be below 92% in Modes 1, 2, and 3. This does not ensure a steam bubble exists in the pressurizer in Mode 4 with the RCS temperature > 275°F. The Applicability change is proposed to align with the proposed Applicability for PSV operability. TS 3.4.5 Bases explain that the intent of the LCO is to ensure that a steam bubble exists in the pressurizer prior to power operation to minimize the consequences of potential overpressure transients. The presence of the steam bubble is consistent with analytical assumptions that credit PSV protection. Therefore, the TS 3.4.5 Applicability is proposed to be changed to MODES 1, 2, and 3 and MODE 4 with all four cold leg temperatures > 275°F. With any cold leg temperature 275°F, overpressure protection by the RNS suction relief valves is required per TS 3.4.14. The change to TS 3.4.5 (and previously described change to TS 3.4.6) ensures that the steam bubble in the pressurizer is maintained and that the PSVs are available for overpressure protection until RNS is aligned and credited for overpressure protection.

TS 3.4.5 Required Action A.4, TS 3.4.6 Required Action B.2, and TS 3.4.16 Required Action C.2 for being in Mode 4 are revised for consistency to require being in Mode 4 with one cold Page 6 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004) leg temperature to 275°F, at which time LTOP protection is required. TS 3.4.5 Required Action A.4 and TS 3.4.16 Required Action C.2 Completion Time is revised to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The additional 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months beyond the current 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to reach Mode 4 allows an appropriate time to also achieve RCS temperature reduction to 275°F. The Completion Time is consistent with the current completion time for TS 3.4.6 Required Action B.2.

Aligning the TS 3.4.5 Applicability with the Applicability of TS 3.4.6 for PSV operability (i.e.,

to include Mode 4 with RCS temperature > 275°F) makes the Note in TS LCOs 3.4.4, 3.4.8, and 3.4.14 regarding RCP starts at temperatures 350°F unnecessary. The Notes read:

No RCP shall be started when the RCS temperature is 350°F unless the pressurizer level is < 92%. However, with the revised TS 3.4.5 Applicability, pressurizer level will be required to be less than 92% when the RCS temperature is > 275°F. Therefore, the existing TS LCO 3.4.4 Note 1, TS LCO 3.4.8 Note 2, and TS 3.4.14 LCO Note 1, are proposed to be deleted as unnecessary duplication of the 92% requirement.

The proposed changes do not adversely impact any functions associated with containing, controlling, channeling, monitoring, or processing radioactive or non-radioactive materials, nor do they diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. The types and quantities of expected plant effluents are not changed. No effluent release path is associated with the proposed changes to TS. Therefore, neither radioactive nor non-radioactive material effluents are affected by this proposed change.

These proposed changes to the TS do not adversely impact radiologically controlled zones.

Plant radiation zones, radiation controls established to satisfy 10 CFR Part 20 requirements, and expected amounts and types of radioactive materials are not affected by the proposed changes. Therefore, individual and cumulative radiation exposures are not affected by this change.

The proposed change has no adverse impact on the emergency plan or the physical security plan implementation, because there are no changes to physical access to credited equipment inside the Nuclear Island (including containment or the auxiliary building) and no adverse impact to plant personnels ability to respond to any plant operations or security event.

Change 1 COL Appendix A Technical Specification Changes

a. 3.3.8 ACTIONS: Add Action Q:

Q. As required by Required Q.1 Be in MODE 3 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action C.1 and AND referenced in Table 3.3.8-1 Q.2 Be in MODE 4 with at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months least one cold leg temperature 275°F.

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ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

b. Table 3.3.8-1 Function 10:

1. Remove , and replace with - so it reads: Pressurizer Water Level - High 3

2. Replace listed Condition F with new Q.

c. Table 3.3.8-1 Note (g): Rewrite Note to read With all four cold leg temperatures

> 275°F.

d. Table 3.3.9-1 Function 10; replace Mode 4 Note (a) with (h).

e. Table 3.3.9-1 Add Note (h): With all four cold leg temperatures > 275°F.

f. TS 3.3.15 SR that states Verify pressurizer heater circuit breakers trip open on an actual or simulated actuation signal, revise the Note to read, Only required to be met when all four cold leg temperatures are > 275°F.

g. LCO 3.4.4: delete Note 1

h. TS 3.4.5 Applicability, add MODE 4 with all four cold leg temperatures > 275°F.

i. TS 3.4.5 Required Action A.4, add with at least one cold leg temperature 275°F after MODE 4. Revise Completion Time from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

j. TS 3.4.6 Applicability:

1. Remove MODE 4 with Normal Residual Heat Removal System (RNS) isolated,

2. Replace MODE 4 with RCS temperature 275°F with MODE 4 with all four cold leg temperatures > 275°F.

k. TS 3.4.6 Required Action B.2 revise to replace RNS aligned to the RCS and RCS temperature < 275°F with at least one cold leg temperature 275°F.

l. LCO 3.4.8 delete Note 2.

m. LCO 3.4.14 delete Note 1.

n. TS 3.4.16 Applicability, replace MODE 4 with the RCS not being cooled by the Normal Residual Heat Removal System (RNS) with MODE 4 with all four cold leg temperatures > 275°F.

o. TS 3.4.16 Actions, Required Action C.2 replace the RCS cooling provided by the RNS with at least one cold leg temperature 275°F. Revise Completion Time from 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

Page 8 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

Change 2: Reactor Coolant Pump (RCP) Start Note Consistency Change TS LCO 3.4.4 Reactor Coolant System (RCS) Loops, TS LCO 3.4.8 Minimum RCS Flow, and TS LCO 3.4.14 Low Temperature Overpressure Protection (LTOP) each contain a Note that puts a restriction on RCP starts based on RCS cold leg temperature and secondary side water temperature. The Note reads:

No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of RCP speed.

As described in TS Bases 3.4.4, the purpose of this restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started. The limitation helps to ensure that the normal residual heat removal system (RNS) pressure remains below both the piping design pressure and the acceptable RNS relief valve inlet pressure.

TS 3.4.4 Applicability requires this Note to be adhered to in Modes 1 and 2 and Modes 3, 4, and 5 with the Plant Control System capable of rod withdrawal or one or more rods not fully inserted. These Applicabilities would not capture any RCP start with cold leg temperatures 350°F if the Plant Control System was not capable of rod withdrawal and all rods were fully inserted (as would be expected at 350°F). TS 3.4.8 Applicability requires this Note to be adhered to in Modes 3, 4, and 5 with unborated water sources not isolated from the RCS.

These Applicabilities would not capture any RCP start with cold leg temperatures 350°F if unborated water sources were isolated. TS 3.4.14 Applicability requires this Note to be adhered to in Mode 4 when any cold leg temperature is 275°F, Mode 5, and Mode 6 when the reactor vessel head is on. These Applicabilities would not capture any RCP start with cold leg temperatures 350°F but > 275°F, or the reactor head removed. When the Mode requirements are compiled together, the current Notes restricting RCP starts are applicable in all Modes except Mode 3 with plant control system not capable of rod withdrawal and unborated water sources isolated, Mode 4 with all cold legs > 275°F, plant control system not capable of rod withdrawal and unborated water sources isolated, and Mode 6 without the reactor vessel head on.

In order to simplify the TS, remove redundancy, and enforce the Note restriction in the intended plant conditions, the Note regarding RCP start restrictions is proposed to be moved to TS LCO 3.4.3 RCS Pressure and Temperature (P/T) Limits. The applicability of this TS is At all times, which means that the relocated Note will maintain the intended restrictions on RCP start as stated in the Notes. This removes redundancy in the TS. Furthermore, the current TS 3.4.4, TS 3.4.8, and TS 3.4.14 Actions do not have appropriate compensatory measures should an RCP be started outside the stated limitations. The TS 3.4.3 Actions with the proposed change would require restoration of the limitation (i.e., secondary side water temperature of each SG 50°F above each of the RCS cold leg temperatures and the RCP at 25% of rated RCP speed), and an evaluation to determine that the RCS is acceptable for continued operation. Additionally, rated is inserted before RCP speed in the Note. This change provides clarification to what is intended by RCP speed; no new technical requirements are introduced by this change.

Page 9 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

The proposed change to remove the Note from TS LCOs 3.4.4, 3.4.8, and 3.4.14 and add the Note to TS LCO 3.4.3 is a more restrictive change. The same LCO restrictions continue to apply for RCP starts, however, they are proposed to apply in a more complete range of Applicabilities. Furthermore, the proposed Actions impose an evaluation not currently required. The RCPs will continue to perform their design functions and the Note regarding RCP start restrictions to prevent RCP starts when RCS and secondary conditions do not meet the requirements for pump start remains as originally intended. The restriction will continue to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

The proposed changes do not adversely impact any functions associated with containing, controlling, channeling, monitoring, or processing radioactive or non-radioactive materials, nor do they diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. The types and quantities of expected plant effluents are not changed. No effluent release path is associated with the proposed changes to the TS. Therefore, neither radioactive nor non-radioactive material effluents are affected by this proposed change.

These proposed changes to the TS do not adversely impact radiologically controlled zones.

Plant radiation zones, radiation controls established to satisfy 10 CFR Part 20 requirements, and expected amounts and types of radioactive materials are not affected by the proposed changes. Therefore, individual and cumulative radiation exposures are not affected by this change.

The proposed change has no adverse impact on the emergency plan or the physical security plan implementation, because there are no changes to physical access to credited equipment inside the Nuclear Island (including containment or the auxiliary building) and no adverse impact to plant personnels ability to respond to any plant operations or security event.

Change 2 COL Appendix A Technical Specification Changes

a. LCO 3.4.3: add new Note, No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of rated RCP speed.

b. LCO 3.4.4: delete S from NOTES and delete Note 2.

c. LCO 3.4.8: delete S from NOTES and delete Note 3.

d. LCO 3.4.14: delete S from NOTES and delete Note 2.

3. TECHNICAL EVALUATION (Included in Section 2)

Page 10 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 52.98(c) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a Combined License (COL). This activity involves changes to COL Appendix A Technical Specifications; therefore, this activity requires an amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this license amendment request.

10 CFR 52, Appendix D, Section VIII.C.6 states that after issuance of a license, Change to the plant-specific TS (Technical Specifications) will be treated as license amendments under 10 CFR 50.90. 10 CFR 50.90 addresses the application for amendments of licenses, construction permits, and early site permits. As discussed above, a change to a COL Appendix A is requested, and thus a license amendment request (LAR) (as supplied herein) is required.

10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants General Design Criterion (GDC) 14 - Reactor coolant pressure boundary, the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture. The proposed changes do not impact the quality of the reactor coolant pressure boundary (RCPB). The changes to the applicabilities for ESFAS, RCS P/T limits, RCS loops, RCS flow, pressurizer, pressurizer safety valves, LTOP, and RVHV do not impact the function of the RCPB components or their ability to perform the function of maintaining RCBP. The integrity of the RCPB is not compromised with this change. Therefore, compliance with GDC-14 is not affected.

10 CFR 50, Appendix A, GDC Quality of reactor coolant pressure boundary, components which are part of the RCPB shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting, and to the extent practical, identifying the location of the source of reactor coolant leakage. The proposed changes do not impact the quality of the RCPB. There are no physical changes proposed to the pressurizer, pressurizer safety valves, LTOP, or RVHV. The components will continue to protect the RCBP from over pressurization during all modes of operation so that the integrity of the RCPB is not compromised.

Therefore, compliance with GDC-30 is not affected. There are no changes proposed to instrumentation for detecting and identifying the location of the source of reactor coolant leakage.

4.2 Precedent No precedent is identified.

Page 11 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004) 4.3 Significant Hazards Consideration The requested amendment proposes changes to Combined License (COL) Appendix A, Technical Specifications (TS). Two groups of changes are proposed.

Change 1 proposes changing the Technical Specification (TS) 3.4.6, Pressurizer Safety Valve, Applicability to require the pressurizer safety valves (PSVs) to be operable when the TS 3.4.14, Low Temperature Overpressure Protection, is not required to be operable. The PSV Applicability is proposed to be in Modes 1, 2, and 3, and Mode 4 when all four cold leg temperatures are > 275°F. A conforming change to the TS 3.4.6 Actions is also proposed. Additionally, the following TS changes necessary to support PSV operability are proposed for consistency with the TS 3.4.6 change:

TS 3.3.8, Engineered Safety Feature Actuation System (ESFAS)

Instrumentation, Table 3.3.8-1 Function 9, Pressurizer Water Level - High 2 and Function 10, Pressurizer Water Level, High 3, Applicability revised, as well as conforming changes to the Actions. An additional editorial change is proposed to Table 3.3.8-1 Function 10, nomenclature to remove the , (comma) and add a -

(hyphen) between Level and High 3,

TS 3.3.9, ESFAS Manual Initiation, Table 3.3.9-1 Function 10, Chemical and Volume Control System (CVS) Makeup Isolation, Applicability revised,

TS 3.3.15, ESFAS Actuation Logic - Operating, the Note to the Surveillance Requirement (SR) stating Verify pressurizer heater circuit breakers trip open on an actual or simulated actuation signal revised,

TS 3.4.4, Reactor Coolant System (RCS) Loops, Limiting Condition for Operation (LCO) Note 1 deleted,

TS 3.4.5, Pressurizer, Applicability revised, as well as conforming changes to the Actions,

TS 3.4.8, Minimum RCS Flow, LCO Note 2 deleted,

TS 3.4.14, Low Temperature Overpressure Protection (LTOP), LCO Note 1 deleted, and

TS 3.4.16, Reactor Vessel Head Vent (RVHV) Applicability revised, as well as conforming changes to the Actions.

Change 2 proposes moving TS LCO Notes stating No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of RCP speed from TS 3.4.4, Reactor Coolant System (RCS) Loops, 3.4.8, Minimum RCS Flow, and 3.4.14 to TS 3.4.3 RCS Pressure / Temperature (P/T) Limits.

Page 12 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

This activity proposes changes to Combined License (COL) Appendix A (Plant-Specific Technical Specifications). This activity requests approval of the license amendment necessary to implement these changes.

An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

4.3.1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed changes do not affect the operation of any systems or equipment that initiate an analyzed accident or alter any structures, systems, and components (SSCs) accident initiator or initiating sequence of events.

The proposed changes do not affect the physical design of SSCs related to the TS on ESFAS, RCS P/T limits, RCS loops, RCS flow, pressurizer, pressurizer safety valves, LTOP, or RVHV, as described in the Updated Final Safety Analysis Report (UFSAR). Therefore, the operation of the listed functions and components is not affected. Therefore, the proposed changes do not affect the probability of an accident previously evaluated.

The proposed changes do not affect the physical design of SSCs related to the TS on ESFAS, RCS P/T limits, RCS loops, RCS flow, pressurizer, pressurizer safety valves, LTOP, or RVHV to meet their design functions. The design of the functions and components continue to meet the same regulatory acceptance criteria, codes, and standards as stated in the UFSAR. In addition, the proposed changes maintain the capabilities of the ESFAS, RCS P/T limits, RCS loops, RCS flow, pressurizer, pressurizer safety valves, LTOP, or RVHV to mitigate the consequences of an accident and to meet the applicable regulatory acceptance criteria.

The proposed changes do not affect the prevention and mitigation of other abnormal events (e.g., anticipated operational occurrences, earthquakes, floods, and turbine missiles), or their safety or design analyses. Therefore, the consequences of the accidents evaluated in the UFSAR are not affected.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Page 13 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004) 4.3.2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed changes do not affect the operation of any systems or equipment that may initiate a new or different kind of accident, or alter any SSC such that a new accident initiator or initiating sequence of events is created.

The proposed changes do not affect any other SSC design functions or methods of operation in a manner that results in a new failure mode, malfunction, or sequence of events that affect the safety-related or non-safety related equipment. Therefore, this activity does not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that result in significant fuel cladding failures.

Therefore, the requested amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed changes maintain existing safety margins. The proposed changes verify and maintain the physical design of SSCs related to ESFAS, RCS P/T limits, RCS loops, RCS flow, pressurizer, pressurizer safety valves, LTOP, and RVHV to perform their design functions. Therefore, the proposed changes satisfy the same design functions in accordance with the same codes and standards as stated in the UFSAR. These changes do not affect any design code, function, design analysis, safety analysis input or result, or design

/ safety margin.

No safety analysis or design basis acceptance limit / criterion is challenged or exceeded by the proposed changes, and no margin of safety is reduced.

Therefore, the requested amendment does not involve a significant reduction in margin of safety.

Based on the above, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of no significant hazards consideration is justified.

Page 14 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004) 4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. The above evaluations demonstrate that the proposed changes can be accommodated without an increase in the probability or consequences of an accident previously evaluated, without creating the possibility of a new or different kind of accident from any accident previously evaluated, and without a significant reduction in margin of safety.

Having arrived at negative declarations with regard to the criteria of 10 CFR 50.92, this assessment determined that the proposed change does not involve a Significant Hazards Consideration.

5. ENVIRONMENTAL CONSIDERATIONS Southern Nuclear Operating Company (SNC or Licensee) is requesting an amendment to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively. The requested amendment proposes changes to Combined License (COL) Appendix A, Technical Specifications (TS). Two groups of changes are proposed.

Change 1 proposes changing the Technical Specification (TS) 3.4.6 Pressurizer Safety Valve (PSV) Applicability to require the pressurizer safety valves to be operable when the TS 3.4.14, Low Temperature Overpressure Protection, is not required to be operable. The PSV Applicability is proposed to be in Modes 1, 2, and 3, and Mode 4 when all four cold leg temperatures are > 275°F. Additionally, the Applicabilities of the following TS will be revised for consistency with the TS 3.4.6 change. TS 3.3.8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation, instrumentation signals for High-2 and High-3 pressurizer water level, TS 3.3.9 ESFAS Manual Initiation, instrumentation signal for chemical and volume control system (CVS) makeup isolation, TS 3.4.5 Pressurizer, and TS 3.4.16 Reactor Vessel Head Vent (RVHV), are being revised to be consistent with TS 3.4.6 Pressurizer Safety Valve Applicability. In addition, changes are proposed to Notes for TS 3.3.15 ESFAS Actuation Logic - Operating, Surveillance Requirement, TS 3.4.4 Reactor Coolant System (RCS) Loops, TS 3.4.8 Minimum RCS Flow, and TS 3.4.14 Low Temperature Overpressure Protection (LTOP). The proposed changes will align TS Applicability to be consistent with when ESFAS functions, pressurizer steam bubble, and RVHV are credited in the supporting safety analysis and shutdown mode assessments.

Change 2 proposes moving the TS Notes in TS 3.4.4, TS 3.4.8, and TS 3.4.14 regarding restrictions on reactor coolant pump (RCP) start from TS where the note does not apply correctly or is repeated unnecessarily, to TS 3.4.3 RCS Pressure / Temperature (P/T) Limits, that is applicable in all modes of operation.

Page 15 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

A review has determined that the facility construction and operation following implementation of the requested amendment does not involve (i) a significant hazards consideration, (ii) as significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:

(i) There is no significant hazards consideration.

As documented in Section 4.3, Significant Hazards Consideration, of this license amendment request, an evaluation was completed to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment. The Significant Hazards Consideration determined that (1) the requested amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the requested amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the requested amendment does not involve a significant reduction in a margin of safety. Therefore, it is concluded that the requested amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of no significant hazards consideration is justified.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed changes in the requested amendment would not adversely affect the design or function of any structure, system, or component (SSC). The proposed changes are unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents), or adversely affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation.

Therefore, it is concluded that the proposed amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

Page 16 of 17

ND-18-0053 Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

(iii) There is no significant increase in individual or cumulative occupational radiation exposure.

The proposed changes in the requested amendment would not adversely affect the design or function of any SSC. Plant radiation zones (described in UFSAR Section 12.3) are not affected, and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure. Therefore, the proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure Based on the above review of the proposed amendment, it has been determined that anticipated construction and operational effects of the proposed amendment do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed amendment is not required.

6. REFERENCES None.

Page 17 of 17

Southern Nuclear Operating Company ND-18-0053 Enclosure 2 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * )

(This Enclosure consists of 12 pages, including this cover page.)

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.3.8, to add a new Condition with Required Actions, and Completion Times as shown below:

CONDITION REQUIRED ACTION COMPLETION TIME P. As required by Required P.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action C.1 and referenced in AND Table 3.3.8-1.

P.2 Be in MODE 5. 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months AND P.3 Open a containment air 44 hours5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months flow path 6 inches in diameter.

Q. As required by Required Q.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months Action C.1 and referenced in AND Table 3.3.8-1.

Q.2 Be in MODE 4 with at 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months least one cold leg temperature 275°F.

Page 2 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Table 3.3.8-1 (page 1 of 2), Function 10, to refer to Technical Specification Condition Q and to revise note (g) as follows:

Table 3.3.8-1 (page 1 of 2)

Engineered Safeguards Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED FUNCTION CONDITIONS CHANNELS CONDITIONS

10. Pressurizer Water Level, - High 3 1,2,3,4(g) 4 FQ (g) Above the P-19 (RCS Pressure) interlock with the RCS not being cooled by RNS.With all four cold leg temperatures

> 275°F.

Page 3 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Table 3.3.9-1 (page 1 of 2), to add a new note (h) for use in Function 10 of Table 3.3.9-1 as follows:

Table 3.3.9-1 (page 1 of 2)

Engineered Safeguards Actuation System Instrumentation APPLICABLE MODES OR OTHER SPECIFIED REQUIRED FUNCTION CONDITIONS CHANNELS CONDITIONS

10. Chemical and Volume Control System Makeup Isolation - Manual Initiation 1,2,3,4(a)(h) 2 switches F (a) With the RCS not being cooled by the Normal Residual Heat Removal System (RNS).

(h) With all four cold leg temperatures > 275°F.

Page 4 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.3.15, to revise the pressurizer heater circuit breakers trip Surveillance Requirement as shown below:

SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY

- NOTE -

Only required to be met when all four cold leg temperatures are > 275°F.in MODE 4 above the P-19 (RCS Pressure) interlock with the RCS not being cooled by RNS.

Verify pressurizer heater circuit breakers trip open 24 months on an actual or simulated actuation signal.

Page 5 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.4.3, to add a Note under LCO 3.4.3 as shown below:

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.3 RCS Pressure and Temperature (P/T) Limits LCO 3.4.3 RCS pressure, RCS temperature, and RCS heatup and cooldown rates shall be maintained within the limits specified in the PTLR.

- NOTE -

No RCP shall be started with any RCS cold leg temperatures 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of rated RCP speed.

APPLICABILITY: At all times.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. ------------------------------- A.1 Restore parameters to 30 minutes

- NOTE - within limits.

Required Action A.2 shall be completed AND whenever this Condition is entered.

A.2 Determine RCS is 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months acceptable for continued Requirements of LCO operation.

not met in MODE 1, 2, 3, or 4.

Page 6 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.4.4, to delete Notes 1 and 2 under LCO 3.4.4 as shown below:

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.4 RCS Loops LCO 3.4.4 Two RCS loops shall be OPERABLE with four Reactor Coolant Pumps (RCPs) in operation with variable speed control bypassed.

- NOTES -

1. No RCP shall be started when the RCS temperature is 350°F unless pressurizer level is < 92%.

2. No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of RCP speed.

3. All RCPs may be removed from operation in MODE 3, 4, or 5 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period provided:

a. No operations are permitted that would cause introduction into the RCS, coolant with boron concentration less than required to meet the SDM of LCO 3.1.1; and

b. Core outlet temperature is maintained at least 10°F below saturation temperature.

APPLICABILITY: MODES 1 and 2, MODES 3, 4, and 5 with Plant Control System capable of rod withdrawal or one or more rods not fully inserted.

Page 7 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.4.5, LCO 3.4.5 applicability and Required Action A.4 and its Completion Time as shown below:

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.5 Pressurizer LCO 3.4.5 The pressurizer water level shall be 92% of span.

APPLICABILITY: MODES 1, 2, and 3.

MODE 4 with all four cold leg temperatures > 275°F.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. Pressurizer water level A.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months not within limit.

AND A.2 Initiate action to fully insert 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months all rods.

AND A.3 Place the Plant Control 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months System in a condition incapable of rod withdrawal.

AND A.4 Be in MODE 4 with at least 1224 hours0.0142 days 0.34 hours 0.00202 weeks 4.65732e-4 months one cold leg temperature 275°F.

Page 8 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A LCO 3.4.6 Applicability and Required Action B.2 as follows:

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.6 Pressurizer Safety Valves LCO 3.4.6 Two pressurizer safety valves shall be OPERABLE with lift settings 2460 psig and 2510 psig.

APPLICABILITY: MODES 1, 2, and 3.

MODE 4 with Normal Residual Heat Removal System (RNS) isolated, MODE 4 with RCS all four cold leg temperatures > 275°F.

- NOTE -

The lift settings are not required to be within the LCO limits during MODES 3 and 4 for the purpose of setting the pressurizer safety valves under ambient (hot) conditions. One pressurizer safety valve at a time may be inoperable for hot lift setting adjustment.

This exception is allowed for 36 hours4.166667e-4 days 0.01 hours 5.952381e-5 weeks 1.3698e-5 months following entry into MODE 3, provided a preliminary cold setting was made prior to heatup.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One pressurizer safety A.1 Restore valve to 15 minutes valve inoperable. OPERABLE status.

B. Required Action and B.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time of Condition A not AND met.

OR B.2 Be in MODE 4 with RNS 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months aligned to the RCS and at least one cold leg RCS Two pressurizer safety temperature < 275°F.

valves inoperable.

Page 9 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.4.8 to delete LCO 3.4.8 Notes 2 and 3 as shown below:

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.8 Minimum RCS Flow LCO 3.4.8 At least one Reactor Coolant Pump (RCP) shall be in operation with a total flow through the core of 3,000 gpm.

- NOTES -

1. All RCPs may be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months

2. No RCP shall be started when the RCS temperature is 350°F unless pressurizer level is < 92%.

3. No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of RCP speed.

APPLICABILITY: MODES 3, 4, and 5 with Plant Control System incapable of rod withdrawal, all rods fully inserted, and unborated water sources not isolated from the RCS.

Page 10 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.4.14 to delete LCO 3.4.14 Notes 1 and 2 as shown below:

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.14 Low Temperature Overpressure Protection (LTOP)

LCO 3.4.14 At least one of the following overpressure protection methods shall be OPERABLE, with the accumulators isolated:

a. Two Normal Residual Heat Removal System (RNS) suction relief valves and Chemical and Volume Control System (CVS) makeup line containment isolation valve, CVS-PL-V091, closed; or

b. The RCS depressurized and an RCS vent of 4.15 square inches.

- NOTES -

1. No reactor coolant pump (RCP) shall be started when the RCS temperature is 350°F unless pressurizer level is < 92%.

2. No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of RCP speed.

3. Accumulator isolation is only required when accumulator pressure is greater than or equal to the maximum RCS pressure for the existing RCS cold leg temperature allowed by the P/T limit curves provided in the PTLR.

APPLICABILITY: MODE 4 when any cold leg temperature is 275°F, MODE 5, MODE 6 when the reactor vessel head is on.

Page 11 of 12

ND-18-0053 Proposed Changes to Licensing Basis Documents (LAR-18-004)

Revise COL Appendix A Technical Specification 3.4.16 Applicability and Required Action C.2 and its Completion Time as follows:

3.4 REACTOR COOLANT SYSTEM (RCS) 3.4.16 Reactor Vessel Head Vent (RVHV)

LCO 3.4.16 The Reactor Vessel Head Vent shall be OPERABLE.

APPLICABILITY: MODES 1, 2, and 3.

MODE 4 with the RCS not being cooled by the Normal Residual Heat Removal System (RNS) all four cold leg temperatures > 275°F.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One flow path A.1 Restore flow path to 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months inoperable. OPERABLE status.

B. Two flow paths B.1 Restore at least one flow 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months inoperable. path to OPERABLE status.

C. Required Action and C.1 Be in MODE 3. 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months associated Completion Time not met. AND C.2 Be in MODE 4, with the 1224 hours0.0142 days 0.34 hours 0.00202 weeks 4.65732e-4 months RCS cooling provided by the RNS at least one cold leg temperature 275°F.

Page 12 of 12

Southern Nuclear Operating Company ND-18-0053 Enclosure 3 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * )

(This Enclosure consists of 20 pages, including this cover page.)

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.1.9 Applicability as follows:

B 3.1 Reactivity Control Systems B 3.1.9 Chemical and Volume Control System (CVS) Demineralized Water Isolation Valves and Makeup Line Isolation BASES APPLICABILITY The requirement that at least two CVS demineralized water isolation valves and two CVS makeup line isolation valves be OPERABLE is applicable in MODES 1, 2, 3, 4, and 5 because a boron dilution event is considered possible in these MODES, and the automatic closure of these valves is assumed in the safety analysis. The pressurizer overfill event is also possible in MODES 1, 2, and 3, and MODE 4 with all four cold leg temperatures > 275°Fwith the Normal Residual Heat Removal System (RNS) suction to the RCS not open and the automatic closure of these valves is assumed in the safety analysis. The steam generator tube rupture (SGTR) event is also possible in MODES 1, 2, and 3, and in MODE 4 at an RCS temperature 350°F. In MODE 4 with an RCS temperature < 350°F and MODES 5 and 6, the RCS pressure and temperature are reduced and an SGTR is not credible. In the applicable MODES, the need to isolate the CVS makeup to the RCS is detected by the pressurizer level instruments (High setpoint coincident with safeguards actuation or High 2 setpoint) or the steam generator narrow range level instruments (High setpoint coincident with reactor trip (P-4) or High 3 setpoint).

Page 2 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.3.8 Applicable Safety Analyses, LCOs, and Applicability as follows:

B 3.3 INSTRUMENTATION B 3.3.8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation BASES APPLICABLE * *

SAFETY ANALYSES, LCOs, RCS Pressure, P-19 and APPLICABILITY The P-19 interlock is provided to permit water solid conditions (i.e., when the pressurizer water level is > 92%) in lower MODES without automatic isolation of the CVS makeup pumps. With RCS pressure below the P-19 setpoint, the PMS allows the operator canto manually block CVS isolation on High 2 pressurizer water level, and block Passive RHR actuation and Pressurizer Heater Trip on High 3 pressurizer water level. The operator can manually block these functions once they are no longer required to be OPERABLE when at least one RCS cold leg temperature is 275°F.

When RCS pressure is above the P-19 setpoint, these Functions are automatically unblocked.

Page 3 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.3.8 Applicable Safety Analyses, LCOs, and Applicability as follows:

B 3.3 INSTRUMENTATION B 3.3.8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation BASES APPLICABLE * *

SAFETY ANALYSES, LCOs, 9. Pressurizer Water Level - High 2 and APPLICABILITY A signal to close the CVS isolation valves is generated on Pressurizer Water Level - High 2. This Function results from the coincidence of pressurizer level above the High 2 setpoint in any two of the four divisions. ThisThe PMS allows this Function canto be manually blocked when the pressurizer pressure is below the P-19 permissive setpoint. The operator can manually block this function once it is no longer required to be OPERABLE when at least one RCS cold leg temperature is 275°F to permit pressurizer water solid conditions with the plant cold and to permit level makeup during plant cooldowns.

This Function is automatically unblocked when RCS pressure is above the P-19 (RCS Pressure) setpoint.

This Function is required to be OPERABLE in MODES 1, 2, and 3, and in MODE 4 when all four cold leg temperatures are > 275°Fwhen above the P-19 interlock and the RCS is not being cooled by the RNS.

This Function is not required to be OPERABLE in MODE 4 with at least one cold leg temperature 275°F or MODES 5 and 6 because it is not required to mitigate a DBA in these MODES.

Page 4 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.3.8 Applicable Safety Analyses, LCOs, and Applicability as follows:

B 3.3 INSTRUMENTATION B 3.3.8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation BASES APPLICABLE * *

SAFETY ANALYSES, LCOs, 10. Pressurizer Water Level - High 3 and APPLICABILITY PRHR is actuated and the pressurizer heaters are tripped when the pressurizer water level reaches its High 3 setpoint. This signal provides protection against a pressurizer overfill following an inadvertent core makeup tank actuation with consequential loss of offsite power. This Function is automatically unblocked when RCS pressure is above the P-19 (RCS pressure) setpoint.

The ESFAS protective functions actuated by Pressurizer Water Level

- High 3 are:

PRHR Heat Exchanger Actuation; and

Pressurizer Heater Trip.

This Function is required to be OPERABLE in MODES 1, 2, and 3, and in MODE 4 when all four cold leg temperatures are > 275°Fthe RCS is not being cooled by the RNS and above the P-19 interlock.

This Function is not required to be OPERABLE in MODE 4 with at least one cold leg temperature 275°F or in MODES 5 and 6 because it is not required to mitigate DBA in these MODES.

Page 5 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.3.8 to add Actions Q.1 and Q.2 as follows:

B 3.3 INSTRUMENTATION B 3.3.8 Engineered Safety Feature Actuation System (ESFAS) Instrumentation BASES ACTIONS * *

P.1, P.2, and P.3 The primary means of opening a containment air flow path is by establishing a VFS air flow path into containment. Manual actuation and maintenance as necessary to open a purge supply, purge exhaust, or vacuum relief flow path are available means to open a containment air flow path. In addition, opening of a spare penetration is an acceptable means to provide the necessary flow path. Opening of an equipment hatch or a containment airlock is acceptable. Containment air flow paths opened must comply with LCO 3.6.7, Containment Penetrations.

The 44 hour5.092593e-4 days 0.0122 hours 7.275132e-5 weeks 1.6742e-5 months Completion Time is reasonable for opening a containment air flow path in an orderly manner.

Q.1 and Q.2 If the Required Action and associated Completion Time of Condition A or B is not met or if three or more channels are inoperable, the plant must be placed in a MODE in which the LCO does not apply. This is accomplished by placing the plant in MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in MODE 4 with at least one cold leg temperature 275°F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The allowed time is reasonable, based on operating experience, to reach the required plant conditions in an orderly manner without challenging plant systems.

Page 6 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.3.9 Applicable Safety Analyses, LCOs, and Applicability as follows:

B 3.3 INSTRUMENTATION B 3.3.9 Engineered Safety Feature Actuation System (ESFAS) Manual Initiation BASES APPLICABLE * *

SAFETY ANALYSES, LCOs, 10. Chemical and Volume Control System Makeup Isolation - Manual and APPLICABILITY Initiation The CVS makeup line, auxiliary spray line, and letdown purification line are isolated following certain events to prevent overfilling of the RCS.

This Function is required to be OPERABLE in MODES 1 through 3, and MODE 4 with all four cold leg temperatures > 275°F. This Function is not required to be OPERABLE in MODE 4 with at least one cold leg temperature 275°F or in MODES 5 and 6 because it is not required to mitigate a DBA in these MODES.the RCS not being cooled by the RNS.

Page 7 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.3.15 Surveillance Requirements follows:

B 3.3 INSTRUMENTATION B 3.3.15 Engineered Safety Feature Actuation System (ESFAS) Actuation Logic - Operating BASES SURVEILLANCE REQUIREMENTS SR 3.3.15.2 The Frequency of 24 months is based on the need to perform this surveillance during periods in which the plant is shutdown for refueling to prevent any upsets of plant operation. This Frequency is adequate based on the use of multiple circuit breakers to prevent the failure of any single circuit breaker from disabling the function and that all circuit breakers are tested.

This Surveillance Requirement is modified by a Note that states that the SR is only required to be met when all four cold leg temperatures are

> 275°Fin MODE 4 above the P-19 (RCS Pressure) interlock with the RCS not being cooled by the Normal Residual Heat Removal System (RNS).

Page 8 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.3 LCO as follows:

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.3 RCS Pressure and Temperature (P/T) Limits BASES LCO Violating the LCO limits places the reactor vessel outside of the bounds of the stress analyses and can increase stresses in other RCPB components. The consequences depend on several factors, as follow:

a. The severity of the departure from the allowable operating P/T regime or the severity of the rate of change of temperature;

b. The length of time the limits were violated (longer violations allow the temperature gradient in the thick vessel walls to become more pronounced); and

c. The existences, sizes, and orientations of flaws in the vessel material.

The LCO is modified by a Note that requires the secondary side water temperature of each SG to be 50°F above each of the RCS cold leg temperatures before the start of an RCP with at least one RCS cold leg temperature 350°F, and the RCP must be started at 25% of rated RCP speed. This limitation helps to ensure that the RNS system pressure remains below both the piping design pressure and the acceptable RNS relief valve inlet pressure. This restraint also assures the thermal transient when an RCP is started is within the bounds of the low temperature overpressure event analysis.

Page 9 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.3 Actions as follows:

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.3 RCS Pressure and Temperature (P/T) Limits BASES Actions A.1 and A.2 Operation outside the P/T limits of the LCO must be restored to within the limits. The RCPB must be returned to a condition that has been verified by stress analyses.

C.1 and C.2 Actions must be initiated immediately to correct operation outside of the P/T limits of the LCO at times other than when in MODE 1, 2, 3, or 4, so that the RCPB is returned to a condition that has been verified by stress analysis.

Page 10 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.4 LCO as follows:

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.4 RCS Loops BASES LCO Note 1 prohibits startup of an RCP when the RCS temperature is 350°F unless pressurizer level is < 92%. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 2 requires that the secondary side water temperature of each SG be 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature 350°F, and the RCP must be started at 25% of RCP speed. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started. This limitation also helps to ensure that the RNS system pressure remains below both the piping design pressure and the acceptable RNS relief valve inlet pressure.

Note 3The LCO is modified by a Note that permits all RCPs to be removed from operation in MODE 3, 4, or 5 for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months Page 11 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.5 Applicable Safety Analyses as follows:

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.5 Pressurizer BASES APPLICABLE In MODES 1, 2, and 3, and MODE 4 with all four cold leg temperatures SAFETY > 275°F, the LCO requirement for a steam bubble is reflected implicitly in ANALYSES the accident analyses. A steam bubble is credited in the safety analyses whenever the PSVs provide overpressure protection of the RCS. Safety analyses performed for lower MODES are not limiting. All analyses performed from a critical reactor condition assume the existence of a steam bubble and saturated conditions in the pressurizer. In making this assumption, the analyses neglect the small fraction of noncondensible gases normally present.

Page 12 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.5 Applicability and Actions as follows:

B 3.4 REACTOR COOLANT SYSTEM (RCS)

B 3.4.5 Pressurizer BASES APPLICABILITY The need for pressure control is most pertinent when core heat can cause the greatest effect on RCS temperature, resulting in the greatest effect on pressurizer level and RCS pressure control. Thus, applicability has been designated for MODES 1 and 2. The applicability is also provided for MODE 3 and for MODE 4 with all four cold leg temperatures > 275°F. The purpose is to prevent solid water RCS operation during heatup and cooldown to avoid rapid pressure rises caused by normal operational perturbation, such as reactor coolant pump startup. With at least one cold leg temperature 275°F, overpressure protection is provided by LCO 3.4.14, Low Temperature Overpressure Protection (LTOP), and a steam bubble is not required.

ACTIONS A.1, A.2, A.3, AND A.4 If the pressurizer water level is above the limit, action must be taken to restore the plant to operation within the bounds of the safety analyses.

This is done by placing the unit in MODE 3 with the Plant Control System in a condition incapable of rod withdrawal and action initiated to fully insert all control rods within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months , and placing the unit in MODE 4 with at least one cold leg temperature 275°F within 1224 hours0.0142 days 0.34 hours 0.00202 weeks 4.65732e-4 months . This takes the unit out of the applicable MODES and restores the unit to operation within the bounds of the safety analyses.

Page 13 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.6 Background and Applicability as follows:

B 3.4.6 Pressurizer Safety Valves BASES BACKGROUND * *

Overpressure protection is required in MODES 1, 2, 3, 4, 5, and 6 when the reactor vessel head is on; however, in MODE 4 with the RNS aligned at least one RCS cold leg temperature 275°F, MODE 5, and MODE 6 with the reactor vessel head on, overpressure protection is provided by operating procedures and by meeting the requirements of LCO 3.4.14, Low Temperature Overpressure Protection (LTOP).

APPLICABILITY In MODES 1, 2, and 3, and portions of MODE 4 with the Normal Residual Heat Removal System (RNS) isolated and portions of MODE 4 with the RCS all four cold leg temperatures > 275°F, OPERABILITY of two valves is required because the combined capacity is required to keep reactor coolant pressure below 110% of its design value during certain accidents. MODE 3 and portions of MODE 4 are conservatively included although the listed accidents may not require the safety valves for protection.

The LCO is not applicable in MODE 4 with RNS not isolated, in MODE 4 with RCS any cold leg temperature 275F and in MODE 5, because LTOP is providedoverpressure protection is provided by LCO 3.4.14, Low Temperature Overpressure Protection (LTOP). Overpressure protection is not required in MODE 6 with reactor vessel head detensioned.

Page 14 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.6 Actions as follows:

B 3.4.6 Pressurizer Safety Valves BASES ACTIONS * *

B.1 and B.2 If the Required Action of A.1 cannot be met within the required Completion Time or if two pressurizer safety valves are inoperable, the plant must be placed in a MODE in which the requirement does not apply.

To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 with the RNS aligned to the RCS and RCS at least one cold leg temperature < 275°F within 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months .

The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner and without challenging plant systems.

With the RNS aligned to the RCSat least one cold leg temperature 275°F, overpressure protection is provided by the LTOP System per LCO 3.4.14. The change from MODE 1, 2, or 3 to MODE 4 with at least one cold leg temperature 275°F reduces the RCS energy (core power and pressure), lowers the potential for large pressurizer insurges, and thereby removes the need for overpressure protection by two pressurizer safety valves.

Page 15 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.8 LCO as follows:

B 3.4.8 Minimum RCS Flow BASES LCO * *

Note 1The LCO is modified by a Note that permits all RCPS to be removed from operation for 1 hour1.157407e-5 days 2.777778e-4 hours 1.653439e-6 weeks 3.805e-7 months per 8 hour9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months period. * *

Note 2 prohibits startup of an RCP when the RCS temperature is 350°F unless pressurizer level is < 92%. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 3 requires that the secondary side water temperature of each SG be 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature 350°F, and the RCP must be started at 25% of RCP speed. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started. This limitation also helps to ensure that the RNS system pressure remains below both the piping design pressure and the acceptable RNS relief valve inlet pressure.

Page 16 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.14 Applicable Safety Analyses as follows:

B 3.4.14 Low Temperature Overpressure Protection (LTOP)

BASES APPLICABLE Safety analyses (Ref. 4) demonstrate that the reactor vessel is SAFETY adequately protected against exceeding the Reference 1 P/T limits. In ANALYSES MODES 1, 2, and 3, and in MODE 4 with the RCSall four cold leg temperatures above> 275°F, the pressurizer safety valves will prevent RCS pressure from exceeding the Reference 1 limits. When the RNS is aligned and open to the RCS, overpressure protection is provided by the RNS suction relief valve, or a depressurized RCS and a sufficiently sized open RCS vent.

RNS Suction Relief Valve Performance To prevent the possibility of a heat input transient, and thereby limit the required flow rate of the RNS suction relief valves, administrative requirements in the LCO Note for LCO 3.4.3, RCS Pressure and Temperature (P/T) Limits, have been imposed for starting an RCP.

Page 17 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.14 LCO as follows:

B 3.4.14 Low Temperature Overpressure Protection (LTOP)

BASES LCO * * *

b. A depressurized RCS and an RCS vent path is open with an area of 4.15 square inches.

Each of these methods of overpressure prevention is capable of mitigating the limiting LTOP transient.

Note 1 prohibits startup of an RCP when the RCS temperature is 350°F unless pressurizer level is < 92%. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started.

Note 2 requires that the secondary side water temperature of each SG be 50°F above each of the RCS cold leg temperatures before the start of an RCP with any RCS cold leg temperature 350°F, and the RCP must be started at 25% of RCP speed. This restraint is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started. This limitation also helps to ensure that the RNS system pressure remains below both the piping design pressure and the acceptable RNS relief valve inlet pressure.

Note 3The LCO is modified by a Note that provides that accumulator isolation is only required when the accumulator pressure is more than or at the maximum RCS pressure for the existing temperature, as allowed by the P/T limit curves. This Note permits the accumulator discharge isolation valve Surveillance to be performed only under these pressure and temperature conditions.

Page 18 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.14 Applicability as follows:

B 3.4.14 Low Temperature Overpressure Protection (LTOP)

BASES APPLICABILITY This LCO is applicable in MODE 4 when any cold leg temperature is below 275°F, MODE 5, and in MODE 6 when the reactor vessel head is on. The pressurizer safety valves provide overpressure protection that meets the Reference 1 P/T limits with all four cold leg temperatures above 275°F. In MODE 6 with the reactor vessel head off an overpressurization cannot occur.

LCO 3.4.3 provides the operational P/T limits for all MODES. LCO 3.4.6, Pressurizer Safety Valves, requires the OPERABILITY of the pressurizer safety valves that provide overpressure protection during MODES 1, 2, and 3, and MODE 4 with the RNS isolated or RCS all four cold leg temperatures > 275°F.

Page 19 of 20

ND-18-0053 Conforming Technical Specification Bases Changes (For Information Only)

(LAR-18-004)

Revise Technical Specification Bases B 3.4.16 Applicability and Actions as follows:

B 3.4.16 Reactor Vessel Head Vent (RVHV)

BASES APPLICABILITY In MODES 1, 2, and 3, and MODE 4 with the RCS not being cooled by the RNS all four cold leg temperatures > 275°F, the RVHV must be OPERABLE to mitigate the potential consequences of any event which causes an increase in the pressurizer water level that could otherwise result in overfilling of the pressurizer.

In MODE 4, with the RCS being cooled by the RNS any cold leg temperature 275°F, and in MODES 5 and 6, operation of the CMTs or CVS will not result in a pressurizer overfill event pressurizer overfill is not a concern since overpressure protection in these MODES is provided by LCO 3.4.14, Low Temperature Overpressure Protection (LTOP), and the credited valves are designed for water relief.

ACTIONS * *

C.1 and C.2 If the Required Actions and associated Completion Times are not met the plant must be brought to MODE 4 with the RCS cooling provided by the RNS at least one cold leg temperature 275°F where the probability and consequences of an event are minimized. To achieve this status, the plant must be brought to at least MODE 3 within 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and to MODE 4 with the RCS cooling provided by the RNS at least one cold leg temperature 275°F within 1224 hours0.0142 days 0.34 hours 0.00202 weeks 4.65732e-4 months . The allowed Completion Times are reasonable, based on operating experience, to reach the required plant conditions from full power conditions in an orderly manner, without challenging plant systems.

Page 20 of 20

ND-18-0053, Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

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ND-18-0053, Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004)

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