ND-18-0060, Request for License Amendment: Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC Revision (LAR-18-008)
| ML18271A116 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/28/2018 |
| From: | Whitley B Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of New Reactors |
| Shared Package | |
| ML18271A115 | List: |
| References | |
| LAR-18-008, ND-18-0060 | |
| Download: ML18271A116 (18) | |
Text
Brian H. Whitley Southern Nuclear Director Operating Company, Inc.
Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 September 28, 2018 Docket Nos.: 52-025 ND-18-0060 52-026 10 CFR 50.90 10 CFR 50.54(p)
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:
Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC Revision (LAR-18-008)
Ladies and Gentlemen:
Pursuant to 10 CFR 50.54(p) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests an amendment to the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 (License Numbers NPF-91 and NPF-92, respectively).
The requested amendment proposes changes to Appendix E of the VEGP Units 3 and 4 Physical Security Plan (COL PSP) to describe the Transitional Security Measures (TSMs) that will be implemented in the event that Unit 3 is ready to load fuel and begin operation with a contiguous Protected Area (PA) boundary and vehicle barrier system (VBS) and a secure boundary is needed between Units 3 and 4. The COL PSP that addresses VEGP 3 and 4 is distinguished from the Physical Security Plan (SNC Fleet Plan) that defines security-related measures for VEGP 1 and 2 in addition to plants Farley and Hatch. In the event that Units 3 and 4 complete construction within a few months of each other, and the Unit 3 TSMs are not required, then the site PA as currently described in the COL PSP will be implemented and the physical protection program for Units 1 through 4 will be incorporated into the SNC Fleet Plan. A Probable Maximum Precipitation (PMP) Analysis is being completed to confirm that the installation of the transitional barrier does not adversely impact the capability of the runoff routes and drainage systems to handle a PMP event.
Additionally, in accordance with 10 CFR 50.90, SNC requests an amendment to the COL for VEGP Unit 4 (License Number NPF-92). The requested amendment will also revise a plant-specific emergency planning inspections, tests, analyses, and acceptance criteria (ITAAC) in Appendix C of the VEGP Unit 4 COL. The proposed change to the emergency planning ITAAC is necessary to support implementation of the TSMs described in the previous paragraph. The proposed change does not involve changes to the approved emergency plan or the plant-specific Tier 2 Design Control Document.
U.S Nuclear Regulatory Commission ND-18-0060 Page 2 of 5 provides the description, technical evaluation. regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed changes.
Enclosure 2 identifies the requested changes and provides markups depicting the requested changes to the VEGP Units 3 and 4 COL PSP. The information in Enclosure 2 contains Security-Related Information and, therefore, cannot be disclosed to the public in accordance with 10 CFR 2.390. identifies the requested change to the VEGP Unit 4 COL Appendix C plant-specific emergency planning ITAAC and provides markups depicting the requested change.
This letter contains no regulatory commitments.
In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this Licensing Amendment Request by transmitting a copy of this letter and Enclosures 1 through 3 to the designated State Official.
SNC requests NRC staff approval of the license amendment by May 3, 2019, to support installation of the TSMs on the western boundary of Unit 3 that include the regulatory required intrusion detection, assessment, lighting, and the VBS as well as any delay features or other security features determined to be needed as part of the protective strategy development.
Delayed approval of this license amendment could result in a delay in completion of the PA boundary and the VBS and subsequent dependent construction and testing activities which will impact the declaration of an operational PA. SNC expects to process this proposed amendment within 30 days of approval of the requested changes by incorporating the changes into Appendix E of the COL PSP.
Should you have any questions. please contact Stephanie Agee at (205) 992-7556.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 281h of September 2018.
Respectfully submitted, Brian H. Whitley Director, Regulatory Affairs Southern Nuclear Operating Company
U.S Nuclear Regulatory Commission ND-18-0060 Page 3 of 5
Enclosures:
- 1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR-18-008)
- 2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to Licensing Basis Documents (LAR-18-008) (Security-Related Information
- Withhold from Public Disclosure Under 10 CFR 2.390(d))
- 3) Vogtle Electric Generating Plant (VEGP) Unit 4 - Proposed Markup to VEGP Unit 4 COL Appendix C Plant-Specific Emergency Planning ITAAC (LAR 008)
U.S Nuclear Regulatory Commission ND-18-0060 Page 4 of 5 cc:
Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)
Mr. D. G. Bost (w/o enclosures)
Mr. M. D. Meier (w/o enclosures)
Mr. D. H. Jones (w/o enclosures)
Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)
Mr. T. W. Yelverton (w/o enclosures)
Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. Mr. D. L. Fulton Mr. M. J. Yox Mr. C. T. Defnall Mr. J. Tupik Mr. B. H. Whitley Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Ms. P. Reister Ms. K. Roberts Ms. P. Ridgway 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. C. J. Even Mr. A. Lerch Mr. S. Walker State of Georgia Mr. R. Dunn (w/o enclosure 2)
Oglethorpe Power Corporation Mr. M. W. Price (w/o enclosure 2)
Ms. A. Whaley (w/o enclosure 2)
U.S Nuclear Regulatory Commission ND-18-0060 Page 5 of 5 Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 2)
Mr. S. M. Jackson (w/o enclosure 2)
Dalton Utilities Mr. T. Bundros (w/o enclosure 2)
Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures)
Mr. C. Churchman (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. (w/o enclosure 2)
Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. (w/o enclosure 2)
Mr. S. Roetger, Georgia Public Service Commission (w/o enclosure 2)
Ms. S. W. Kernizan, Georgia Public Service Commission (w/o enclosure 2)
Mr. K. C. Greene, Troutman Sanders (w/o enclosure 2)
Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy (w/o enclosure 2)
Mr. S. Franzone, Florida Power & Light (w/o enclosure 2)
Southern Nuclear Operating Company ND-18-0060 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:
Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR-18-008)
(This Enclosure consists of 11 pages, including this cover page)
ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008)
Table of Contents
- 1.
SUMMARY
DESCRIPTION
- 2. DETAILED DESCRIPTION
- 3. TECHNICAL EVALUATION
- 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 11
ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008)
Pursuant to 10 CFR 50.54(p) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Combined License Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.
- 1.
SUMMARY
DESCRIPTION Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures The proposed changes will revise the Combined Licenses (COLs) in regard to Appendix E, Measures During New Plant Construction of the COL Physical Security Plan (COL PSP) that was approved as part of issuing the COLs. The changes propose to modify Appendix E by adding information describing the Protected Area (PA) barrier, intrusion detection, assessment, lighting, and vehicle barrier system (VBS) in addition to any delay features or other security-related features determined to be needed for protective strategy development (hereafter referred to as Transitional Security Measures (TSMs)) to be installed on the western boundary of Unit 3. These TSMs, combined with the permanent security features, create a contiguous PA barrier, delay barriers, and VBS that will circumscribe VEGP Units 1 through 3. This LAR will allow establishment of the western most PA barrier and VBS supporting contiguous boundaries for the three VEGP units in accordance with regulatory requirements in 10 CFR 73.55 in the event Unit 4 is still under construction when Unit 3 construction is complete, and Unit 3 is ready for fuel load.
This License Amendment Request (LAR) requests the NRCs determination that the Unit 3 western boundary TSMs described herein meet the applicable requirements of 10 CFR 73.55.
The requested amendment proposes changes to Appendix E of the VEGP COL PSP to meet 10 CFR 73.55 (a)(2). This enclosure requests approval of the license amendment necessary to make these changes to Appendix E to address the western boundary TSMs.
Unit 4 Plant-Specific Emergency Planning ITAAC Revision This proposed change will also revise the plant-specific VEGP Unit 4 COL Appendix C Emergency Planning (EP) inspections, tests, analyses, and acceptance criteria (ITAAC) Table E.3.9-5 item No. 852 to remove the Verified on VEGP Unit 3 annotation and insert an ITAAC number, Program Commitment wording, Inspections, Tests, Analyses (ITA) wording and Acceptance Criteria (AC) wording to match the existing VEGP Unit 3 COL Appendix C EP ITAAC No.
E.3.9.05.01.04 wording. With the addition of the Unit 3 western boundary TSMs, the Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 cannot be verified on Unit 3 COL Appendix C EP ITAAC No. E.3.9.05.01.04.
- 2. DETAILED DESCRIPTION Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures The VEGP Units 3 and 4 COL PSP currently describes the completed VEGP site PA that will encompass Units 1 through 4. Appendix E of the COL PSP describes security provisions that will be implemented during construction of a new commercial power reactor within one mile of the operating plants PA. For Unit 3 to load fuel and start operation if Unit 4 is still under construction, TSMs must be installed on the western boundary of Unit 3 to meet 10 CFR 73.55 requirements for a contiguous PA, delay barriers and VBS. The TSMs will remain in place until the physical security measures for the four-unit site are in their final configuration. The TSMs in Appendix E will subsequently be removed or altered to reflect the final site status. The proposed changes add detailed information to Appendix E of the COL PSP to describe the design of the TSMs that Page 3 of 11
ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008) will connect to the Unit 3 northern and southern boundaries (PA, delay and VBS barriers) to form the western boundary of Unit 3.
Licensing Basis Change Descriptions:
Proposed Licensing Basis Changes Text, Table, or Figure Description of the Proposed Changes PSP, App. E Add detailed information related to the design of TSMs that will connect to Unit 3 northern and southern security boundaries to form the western boundary of Unit 3.
Unit 4 Plant-Specific Emergency Planning ITAAC Revision The plant-specific VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 is currently annotated as Verified on VEGP Unit 3. The basis for this annotation is that the Technical Support Center (TSC) is common to both VEGP Units 3 and 4 and would be located in a PA common to VEGP Units 3 and 4. The addition of the Unit 3 western boundary TSMs will result in a major security barrier between the common VEGP Unit 3 and 4 TSC and the Unit 4 control room. Thus, the Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 cannot be verified using the Unit 3 COL Appendix C EP ITAAC No. E.3.9.05.01.04 Completion Notice, while the Unit 3 western boundary TSMs are in place. The proposed change will revise the Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 to confirm no major security barriers exist between the TSC and the Unit 4 control room, matching the wording contained in the Unit 3 COL Appendix C EP ITAAC No. E.3.9.05.01.04 Program Commitment, ITA and AC. Once the physical security measures for the site are in their final configuration, and the western boundary TSMs removed or altered (opened), the revised Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 Completion Notice may be submitted.
Licensing Basis Change
Description:
Proposed Licensing Basis Change Text, Table, or Figure Description of the Proposed Change VEGP Unit 4 COL Appendix Replace ITAAC Table E.3.9-5 item No. 852, with Program C Table E.3.9-5 Commitment, ITA and AC wording that matches Unit 3 ITAAC No. E.3.9.05.01.04.
- 3. TECHNICAL EVALUATION Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures The proposed changes provide TSMs in the event a secure boundary is needed between Units 3 and 4. Because Appendix E of the COL PSP addresses the security provisions for an operating plant in close proximity to a new reactor plant under construction, it is the logical place to address the TSMs needed for Unit 3 operation. 10 CFR 73.55 has specific requirements for PA, delay, and VBS barriers. The design details to be added to Appendix E describe how the Licensee will meet those requirements as part of the installation of the transitional barriers. The implementation Page 4 of 11
ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008) of these TSMs on the western boundary of Unit 3, in conjunction with the northern and southern PA boundaries of Unit 3, will form a contiguous PA boundary encompassing VEGP Units 1 through 3. The addition of the TSMs will not impact the safe operation of Unit 3. Movement of operations and emergency response personnel will not be hampered by these physical barriers.
These barriers will not introduce any industrial safety hazards. Flow of personnel and equipment will be through the Units 1 and 2 Plant Entry Security Building (PESB) and the Unit 3 primary access point (PAP) building and vehicle access portal. There will be no access points between Unit 3 and the Unit 4 construction site through these western boundary barriers. The barriers will include the PA barrier and several delay barriers as described in the change request. Intrusion detection, assessment and lighting will be added along the PA barrier. A VBS barrier will also be installed at a standoff distance to protect safe shutdown equipment and soft targets. Defensive fighting positions will be utilized to provide early engagement along the new PA boundary.
No radiation zone changes are required because of the installation of the TSMs. The changes do not introduce new or different amounts or types of radioactive materials, nor do they involve changes to radiation zone boundaries, including walls, floors, or other structures that provide shielding features. Therefore, there are no changes to the controls required under 10 CFR Part 20 that preclude a significant increase in occupational radiation exposure.
The proposed changes do not affect the containment, control, channeling, monitoring, processing or releasing of radioactive or non-radioactive materials. Accordingly, no effluent release path is affected. In addition, the types and quantities of expected effluents are not changed by the proposed changes. Therefore, the proposed changes do not affect radioactive or non-radioactive material effluents.
The transitional barriers will not have an adverse impact on the environment in the area where they will be installed. A Probable Maximum Precipitation (PMP) Analysis is being completed to confirm that installation of the transitional barrier does not adversely impact the capability of the runoff routes and drainage systems to handle a PMP event.
Unit 4 Plant-Specific Emergency Planning ITAAC Revision The VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 will be revised to remove the Verified on VEGP Unit 3 annotation and insert an ITAAC number (E.3.9.05.01.04),
Program Commitment wording, ITA wording and AC wording that matches the existing VEGP Unit 3 COL Appendix C EP ITAAC No. E.3.9.05.01.04 wording.
10 CFR 52.97(b) requires that the Commission identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commissions rules and regulations.
NUREG-1923, Safety Evaluation Report for an Early Site Permit (ESP) at the Vogtle Electric Generating Plant ESP Site, Chapter 3, Table 13.3.5, VEGP Unit 3 ITAAC, established the emergency planning ITAAC associated with 10 CFR 50.47(b)(8), which states, "Adequate emergency facilities and equipment to support the emergency response are provided and maintained." The Unit 3 ESP emergency planning ITAAC identifying the TSC location states The TSC is located within the protected area, and no major security barriers exist between the TSC and the control room. NUREG-1923, Table 13.3.6, VEGP Unit 4 ITAAC did not require a corresponding ITAAC since the TSC would be common to both VEGP Units 3 and 4 and would Page 5 of 11
ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008) be located in a PA common to VEGP Units 3 and 4. With the proposed change to the PSP, this is no longer true and, therefore, the VEGP Unit 4 ITAAC is proposed to be revised.
The proposed change to VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 will provide reasonable assurance, in part, that the requirements of 10 CFR 50.47(b)(8) are met since the revised VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 Program Commitment, ITA and AC will be identical to the VEGP Unit 3 COL Appendix C EP ITAAC No.
E.3.9.05.01.04. Therefore, the proposed change to the VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No. 852 is acceptable.
Summary Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures The proposed changes add TSMs on the western boundary of VEGP Unit 3 in the event a secure boundary is needed between Units 3 and 4. This LAR proposes changes to the COL PSP to describe how the proposed TSMs satisfy 10 CFR 73.55 requirements. With the western boundary TSMs installed, the COL PSP will support a defensive strategy for the combined site of Units 1 through 3 and be ready to be incorporated into the SNC Fleet Plan at the appropriate time based on the status of construction of VEGP Units 3 and 4.
Unit 4 Plant-Specific Emergency Planning ITAAC Revision The proposed change to the VEGP Unit 4 COL Appendix C EP ITAAC Table E.3.9-5 item No.
852 is in compliance with applicable emergency preparedness and ITAAC regulations. The proposed change does not affect the design of a system, structure or component used to meet the design bases of the nuclear plant. Nor does the change affect the construction or operation of a nuclear plant. Therefore, based on the technical evaluation above and the regulatory analysis provided in section 4.1 below, the proposed change to the VEGP Unit 4 COL Appendix C emergency planning ITAAC is acceptable.
- 4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures 10 CFR 50.54(p)(1) requires prior NRC approval for any change that would decrease the effectiveness of the physical security plan. A licensee desiring to make a change that has potential for a decrease in effectiveness shall submit an application for amendment to its license under 10 CFR 50.90. The Transitional Security Measures (TSMs) to install a transitional PA barrier, intrusion detection, assessment, lighting, and a transitional Vehicle Barrier System (VBS) on the western boundary of VEGP Unit 3, in addition to any delay barriers, have been determined to be significant changes to the Combined License (COL)
Physical Security Plan (PSP) that were not reviewed as part of the COL issuance. The unit configuration contained in the PSP previously reviewed and approved by the NRC, was a Units 1 through 4 configuration. The configuration being requested by this change is a Units 1 through 3 configuration. The other aspects of the plan are not being changed. These changes are being submitted to meet 10 CFR 73.55 (a)(2) and NRC approval is requested prior to making the changes described herein.
Page 6 of 11
ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008) 10 CFR 73.55 provides the requirements for physical protection of licensed activities in nuclear power reactors against radiological sabotage. Included in 10 CFR 73.55 are requirements that each operating nuclear reactor have a protected area (PA) barrier and associated intrusion detection equipment, illumination, assessment equipment, tamper indication, backup power capability, and be monitored by redundant alarm stations. This change installs the necessary structures and equipment along the western boundary of Unit 3 as a plant modification to meet these regulatory requirements and to integrate these features with those currently described in the COL PSP for the northern and southern boundaries of Unit 3. Therefore, the proposed changes comply with the requirements of 10 CFR 73.55.
More specifically, 10 CFR 73.55(e) provides the requirements for physical barriers needed to satisfy the physical protection program design requirements of § 73.55(b), including those required to protect the PA perimeter. The proposed changes describe the transitional VBS along the western boundary of Unit 3 to meet this regulatory requirement for a contiguous VBS around an operating plant at a minimum safe standoff distance that protects the plant and needed personnel from the Design Basis Threat (DBT) vehicle bombs. Therefore, the proposed changes comply with the requirements of 73.55(e).
10 CFR 73.58 requires licensees to assess and manage the potential for adverse effects on safety and security, including the site emergency plan, before implementing changes to plant configurations, facility conditions, or security. The TSMs proposed by this license amendment request have been assessed for nuclear safety, personnel safety, and physical security. No issues were identified.
The VEGP Unit 3 Plant Security System Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) only cover the Unit 3 plant security system design commitment scope approved as part of the COL. The transitional PA barrier and associated security components will be designed and installed to meet applicable 10 CFR 73.55 requirements. Although the scope of the Unit 3 Plant Security System ITAAC do not cover the integration of VEGP Units 1 and 2 with Unit 3, the transitional PA barrier and associated security components, which this LAR proposes to add to the COL PSP, will be included in the scope of the Unit 3 Plant Security System ITAAC. Similarly, the transitional VBS will be designed and installed to meet applicable 10 CFR 73.55 requirements and will be included in the scope of the Unit 3 Plant Security System ITAAC.
Unit 4 Plant-Specific Emergency Planning ITAAC Revision 10 CFR 52.98(f) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL. The proposed change involves a change to COL Appendix C ITAAC information. Therefore, NRC approval is required prior to making the plant-specific proposed change in this license amendment request (LAR).
10 CFR 52.97(b) requires that the Commission shall identify within the combined license the inspections, tests, and analyses, including those applicable to emergency planning, that the licensee shall perform, and the acceptance criteria that, if met, are necessary and sufficient to provide reasonable assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commissions rules and regulations. Based on the technical evaluation provided in Section 3 above, the proposed change to the emergency planning ITAAC continues to meet the requirements of 10 CFR 52.97(b).
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ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008) 4.2 Precedent No precedent is identified.
4.3 Significant Hazards Consideration Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures The proposed amendment will revise Appendix E, Measures During New Plant Construction of the Combined License (COL) Physical Security Plan (COL PSP) that was approved as part of issuance of the Unit 3 and 4 COLs. The changes propose to modify Appendix E by adding information describing the Protected Area (PA) barrier, intrusion detection, assessment, lighting, and vehicle barrier system (VBS) in addition to any delay features or other security-related features determined to be needed for protective strategy development (hereafter referred to as Transitional Security Measures (TSMs)) to be installed on the western boundary of Unit 3. These TSMs combined with the permanent security features create a contiguous PA, delay barriers, and VBS that will circumscribe Vogtle Electric Generating Plant (VEGP)
Units 1 through 3. This License Amendment Request (LAR) will allow nuclear fuel to be received and loaded into Unit 3 and establishment of a western PA barrier and a VBS barrier supporting contiguous boundaries for the three VEGP units in accordance with regulatory requirements in 10 CFR 73.55 in the event Unit 4 is still under construction when Unit 3 construction is complete and Unit 3 is ready for fuel load.
Unit 4 Plant-Specific Emergency Planning ITAAC Revision The proposed amendment will revise the plant-specific VEGP Unit 4 COL Appendix C Emergency Planning inspections, tests, analyses, and acceptance criteria (ITAAC) Table E.3.9-5 item No. 852 to remove the Verified on VEGP Unit 3 annotation and insert an ITAAC number, Program Commitment wording, Inspections, Tests, Analyses (ITA) wording and Acceptance Criteria (AC) wording which matches the existing VEGP Unit 3 COL Appendix C emergency planning ITAAC No. E.3.9.05.01.04 wording.
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 to implement TSMs on the western boundary of Unit 3 do not involve any new accident. The changes do not affect the operation of any systems or equipment that initiate an analyzed accident or alter any structures, systems, or components (SSCs) accident initiator or initiating sequence of events. The changes do not impact the design, construction, or operation of any mechanical and fluid systems.
There is no change to plant systems or the response of systems to postulated accident conditions. There is no change to the predicted radioactive releases due to postulated Page 8 of 11
ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008) accident conditions. Consequently, the plant response to previously evaluated accidents or external events is not adversely affected, nor do the proposed changes create any new accident precursors.
The VEGP Unit 4 COL Appendix C Emergency Planning ITAAC provide assurance that the facility has been constructed and will be operated in conformity with the license, the provisions of the Act, and the Commissions rules and regulations. The proposed change to the VEGP Unit 4 COL Appendix C Emergency Planning ITAAC Table E.3.9-5 item No. 852 does not affect the design of a system, structure, or component (SSC) used to meet the design bases of the nuclear plant. Nor does the change affect the construction or operation of the nuclear plant itself, so there is no change to the probability or consequences of an accident previously evaluated. Changing the VEGP Unit 4 COL Appendix C Emergency Planning ITAAC Table E.3.9-5 item No. 852 does not affect prevention and mitigation of abnormal events (e.g., accidents, anticipated operational occurrences, earthquakes, floods, or turbine missiles) or their safety or design analyses.
No safety-related SSC or function is adversely affected. The change does not involve or interface with any SSC accident initiator or initiating sequence of events, so the probabilities of the accidents evaluated in the Updated Final Safety Analysis Report (UFSAR) are not affected.
Because the change does not involve any safety-related SSC or function used to mitigate an accident, 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.
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. Therefore, the proposed 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 to implement TSMs on the western boundary of Unit 3 do not alter any safety-related equipment, applicable design codes, code compliance, design function, or safety analysis. Consequently, no safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the proposed changes, thus the margin of safety is not reduced. The added barriers are designed, constructed, and controlled in accordance with applicable regulations.
The revision to VEGP Unit 4 COL Appendix C Emergency Planning ITAAC Table E.3.9-5 item No. 852 does not adversely affect safety-related equipment or fission product barriers. No safety analysis or design basis acceptance limit or criterion is challenged or exceeded by the proposed change.
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ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008)
Therefore, the proposed amendment does not involve a significant reduction in a 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.
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. 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.
- 5. ENVIRONMENTAL CONSIDERATIONS The details of the proposed changes are provided in Sections 2 and 3 of this license amendment request.
Physical Security Plan, Appendix E Additions for Unit 3 Transitional Security Measures The proposed changes will revise Appendix E, Measures During New Plant Construction of the COL Physical Security Plan (COL PSP) that was approved as part of issuance of the Unit 3 and 4 COLs. The changes propose to modify Appendix E by adding information describing the Protected Area (PA) barrier, intrusion detection, assessment, lighting, and vehicle barrier system (VBS) barrier in addition to any delay features or other security-related features determined to be needed for protective strategy development (hereafter referred to as Transitional Security Measures (TSMs)) to be installed on the western boundary of Unit 3. These TSMs combined with the permanent security features create a contiguous PA, delay barriers, and VBS barrier that will circumscribe VEGP Units 1 through 3. This License Amendment Request (LAR) will allow nuclear fuel to be received and loaded into Unit 3 and establishment of western PA barrier and VBS barrier supporting contiguous boundaries for the three VEGP units in accordance with regulatory requirements in 10 CFR 73.55 in the event Unit 4 is still under construction when Unit 3 construction is complete and Unit 3 is ready for fuel load.
Unit 4 Plant-Specific Emergency Planning ITAAC Revision The proposed change will revise the plant-specific VEGP Unit 4 COL Appendix C Emergency Planning inspections, tests, analyses, and acceptance criteria (ITAAC) Table E.3.9-5 item No.
852 to remove the Verified on VEGP Unit 3 annotation and insert an ITAAC number, Program Commitment wording, Inspections, Tests, Analyses (ITA) wording and Acceptance Criteria (AC) wording which matches the existing VEGP Unit 3 COL Appendix C Emergency Planning ITAAC No. E.3.9.05.01.04 wording.
This review has determined that the proposed changes require an amendment to the COL.
However, a review of the anticipated construction and operational effects of the requested amendment has determined that the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:
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ND-18-0060 Request for License Amendment: Physical Security Plan, Appendix E Changes for Unit 3 Transitional Security Measures and Unit 4 Plant-Specific Emergency Planning ITAAC (LAR 008)
(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 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 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 requested 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.
(iii) There is no significant increase in individual or cumulative occupational radiation exposure.
Plant radiation zones (addressed in UFSAR Section 12.3) are not affected by these changes, and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure. Therefore, the requested 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), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.
- 6. REFERENCES None.
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Southern Nuclear Operating Company ND-18-0060 Enclosure 3 Vogtle Electric Generating Plant (VEGP) Unit 4 Proposed Markup to VEGP Unit 4 COL Appendix C Plant-Specific Emergency Planning ITAAC (LAR-18-008)
Note: Added text is in Blue Italic Underline Deleted text is Red Italic Strikethrough Omitted text is shown as three asterisks (*...*...*)
(This Enclosure consists of 2 pages, including this cover page)
ND-18-0060 Proposed Markup to VEGP Unit 4 COL Appendix C Plant-Specific Emergency Planning ITAAC (LAR 18-008)
E.3.9.4 Not Used E.3.9.5 Emergency Facilities and Equipment Table E.3.9-5 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Program Commitment Inspection, Tests, Analyses Acceptance Criteria 851 E.3.9.05.01.03 5.1 The licensee has established a 5.1 An inspection of the as-built 5.1.4 The plant parameters technical support center (TSC) and TSC and OSC will be performed, listed in UFSAR 7.5-1, an onsite operations support center including a test of the capabilities. Post-Accident Monitoring (OSC). [H.1] System can be retrieved and displayed in the TSC 852 E.3.9.05.01.04 Verified on VEGP Unit 3 5.1 An inspection of the as-built 5.1.4 The TSC is located TSC and OSC will be performed, within the protected area, and 5.1 The licensee has established a including a test of the capabilities. no major security barriers technical support center (TSC) and exist between the TSC and an onsite operations support center the control room.
(OSC). [H.1]
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