ND-18-0610, Supplement to Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004S1)

Supplement to Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004S1)

ML18122A132
Person / Time
Site:	Vogtle
Issue date:	05/02/2018
From:	Whitley B Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
LAR-18-004S1, ND-18-0610
Download: ML18122A132 (6)

Text

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

Regulatory Affairs 42 Inverness Center Parkway Birmingham, AL 35242 Tel 205.992.7079 Fax 205.992.5296 May 2, 2018 Docket Nos.: 52-025 ND-18-0610 52-026 10 CFR 50.90 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Supplement to Request for License Amendment:

Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004S1)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requested 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), by SNC letter ND-18-0053, dated January 31, 2018 [ADAMS Accession Number ML18031B131].

The request 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 proposed 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. to this letter supplements LAR-18-004 to address a Draft Request for Additional Information (RAI) from the NRC Staff, which was transmitted by electronic mail (email) on April 2, 2018 [ADAMS Accession Number ML18092A258], to support review of LAR-18-004. This supplement does not impact the scope, document markups, technical content, or conclusions of the Technical Evaluation, Significant Hazards Consideration Determination, or Environmental Considerations of the original License Amendment Request (LAR) provided in Enclosures 1, 2 and 3 of SNC letter ND-18-0053.

This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security related information.

U.S. Nuclear Regulatory Commission

, ND-18-0610 Page 2 of 4 SNC requests staff approval of the license amendment by July 31, 2018 (as originally requested) to support Operator training updates. Delayed approval of this license amendment could result in a delay in Operator training updates and subsequent dependent construction activities. SNC expects to implement the proposed amendment within 30 days of approval of the requested changes.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia by transmitting a copy of this letter and enclosure 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 2nd of May 2018.

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

Enclosure:

4) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Response to NRC Draft Request for Additional Information (RAI) Regarding LAR 18-004 (LAR-18-004S1)

U.S. Nuclear Regulatory Commission ND-18-0610 Page 3 of 4 cc:

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

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

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

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

Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosure)

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

Mr. B. H. Whitley Ms. C. A. Gayheart (w/o enclosure)

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

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-18-0610 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 enclosure)

Mr. G. Koucheravy (w/o enclosure)

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-18-0610 Enclosure 4 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Draft Request for Additional Information (RAI) Regarding LAR 18-004 (LAR-18-004S1)

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

ND-18-0610 Response to NRC Draft Request for Additional Information (RAI) Regarding LAR-18-004 (LAR-18-004S1)

The following draft request for additional information (RAI) [ADAMS Accession Number ML18092A258] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)18-004, submitted by SNC letter ND-18-0053, was provided by the NRC Staff on April 2, 2018.

Draft Request for Additional Information (RAI):

The following is the regulatory basis as well as the draft Request for Additional Information question related to LAR 18-004 for Vogtle Units 3 and 4.

The NRC regulations in 10 CFR Part 50, Appendix A, General Design Criteria for Nuclear Power Plants, General Design Criterion (GDC) 14, Reactor coolant pressure boundary, state that the reactor coolant pressure boundary (RCPB) 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. In addition, GDC 30, Quality of reactor coolant pressure boundary, in 10 CFR Part 50, Appendix A, states, in part, that components which are part of the RCPB shall be designed, fabricated, erected, and tested to the highest quality standards practical.

In License Amendment Request (LAR)18-004 (dated January 31, 2018), Southern Nuclear Operating Company (SNC) requested an amendment to the Combined Licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 to modify the VEGP Units 3 and 4 COL Appendix A, Technical Specifications (TS). Among the proposed changes in LAR-18-004, SNC requests 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. The NRC staff requests that SNC indicate whether any changes in the performance requirements or operating conditions are necessary for the PSVs or any other valves for the implementation of LAR-18-004. If so, the staff requests that SNC describe the plans to incorporate those performance requirements and operating conditions as part of the qualification of those valves in accordance with American Society of Mechanical Engineers (ASME) Standard QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants, as accepted in NRC Regulatory Guide 1.100 (Revision 3), Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants.

SNC Response to Draft RAI:

There are no changes necessary to the performance requirements or operating conditions for the pressurizer safety valves (PSVs) or any other valves for the implementation of LAR-18-004.

LAR-18-004 changes the Technical Specification (TS) 3.4.6, Pressurizer Safety Valves, Applicability for Mode 4 from MODE 4 with RNS isolated or RCS temperature 275°F. to MODE 4 with all four cold leg temperatures > 275°F. The change aligns the Mode 4 applicability of TS 3.4.6 with TS 3.4.14, Low Temperature Overpressure Protection (LTOP). The changes impose operational restrictions different from what was previously defined, but the PSVs and other valves, including the LTOP valves, will continue to operate within the requirements of the design specifications and meet the performance requirements specified in the system specifications and Technical Specifications with no necessary modifications to the valves.

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