ND-18-0871, Supplement to Request for License Amendment: Technical Specification Updates for Reactivity Controls and Other Miscellaneous Changes (LAR-17-024S3)

Supplement to Request for License Amendment: Technical Specification Updates for Reactivity Controls and Other Miscellaneous Changes (LAR-17-024S3)

ML18172A154
Person / Time
Site:	Vogtle
Issue date:	06/21/2018
From:	Aughtman A Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
LAR-17-024S3, ND-18-0871
Download: ML18172A154 (13)

Text

Southern Nuclear Operating Company, Inc.

3535 Colonnade Parkway Birmingham, AL 35243 June 21, 2018 Docket Nos.: 52-025 ND-18-0871 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 Supplement to Request for License Amendment:

Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes (LAR-17-024S3)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) previously 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). The requested amendment proposes to depart from approved COL Appendix A, Technical Specifications.

SNC originally submitted this request by SNC letter ND-17-1279, dated July 28, 2017 [ADAMS Accession No. ML17209A755] and supplemented by SNC letter ND-18-0058, dated January 23, 2018 [ADAMS Accession No. ML18023A440] and by SNC letter ND-18-0364, dated March 23, 2018 [ADAMS Accession No. ML18082B370].

Enclosures 1 through 3 were provided with the original License Amendment Request (LAR),

Enclosures 4 and 5 were provided with the first LAR supplement, and Enclosures 6, 7, and 8 were provided with the second LAR supplement. provides a revised description of change and technical evaluation for Change L07 in the original LAR based upon discussions held with the NRC staff on May 31, 2018 and June 14, 2018. 0 provides the applicable revised markups depicting the requested change to the licensing basis documents requiring NRC staff approval. 1 provides the applicable revised conforming Technical Specifications Bases changes for information only.

The information provided in this LAR supplement does not expand the scope of the request, or alter the conclusions of the Significant Hazards Consideration Determination or Environmental Considerations submitted in LAR-17-024.

U.S. Nuclear Regulatory Commission ND-18-0871 Page 2 of 5 This letter contains no regulatory commttments. This letter has been reviewed and determined not to contain security-related information.

SNC now requests NRC staff approval of this license amendment by July 20, 2018 to support Operator training updates. Delayed approval of this license amendment could result in a delay in Operator training updates. 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 of this LAR supplement by transmitting a copy of this letter and its enclosure to the designated State Official.

Should you have any questions, please contact Mr. Ryan Henderson at (205) 992-6426.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 21st of June 2018.

Respectfully submitted, Amy G. Aughtman Director, Licensing Southern Nuclear Operating Company

U.S. Nuclear Regulatory Commission ND-18-0871 Page 3 of 5

Enclosures:

1) - 3) (previously submitted with the original LAR, LAR-17-024, in SNC letter ND-17-1279)

4) - 5) (previously submitted as supplemental information with LAR-17-024S1 in SNC letter ND-18-0058)

6) - 8) (previously submitted as supplemental information with LAR-17-024S2 in SNC letter ND-18-0364)

9) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Request for License Amendment: Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes (LAR-17-024S3)

10) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Proposed Changes to Licensing Basis Documents (LAR-17-024S3)

11) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Conforming Technical Specifications Bases Changes (For Information Only) (LAR-17-024S3)

U.S. Nuclear Regulatory Commission ND-18-0871 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)

Mr. B. H. Whitley Ms. C. A. Gayheart 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. 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

U.S. Nuclear Regulatory Commission ND-18-0871 Page 5 of 5 Oglethorpe Power Corporation Mr. M. W. Price Mr. K. T. Haynes Ms. A. Whaley 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-18-0871 Enclosure 9 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Request for License Amendment:

Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes (LAR-17-024S3)

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

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

ND-18-0871 Supplement to Request for License Amendment: Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes (LAR-17-024S3)

Vogtle Electric Generating Plant (VEGP) Units 3 and 4 submitted License Amendment Request LAR-17-024 via Southern Nuclear Operating Company (SNC) letter ND-17-1279 on July 28, 2017. The portion of the LAR identified as change L07 on Page 11 of 39 and Page 34 of 39 of proposed a change to Technical Specification (TS) Table 3.3.5-1. This change included:

1. Change the Table 3.3.5-1 Function 1, Manual Reactor Trip Required Channels from 2 to 2 switches.

2. Change the Table 3.3.5-1 Function 2, Safeguards Actuation Input from Engineered Safety Feature Actuation System - Manual Required Channels from 2 to 2 switches.

3. Change the Table 3.3.5-1 Function 4, Core Makeup Tank Actuation Input from Engineered Safety Feature Actuation System - Manual Required Channels from 2 switch sets to 2 switches.

Based on discussion with the NRC staff in the public meetings on May 31, 2018 and June 14, 2018, SNC is withdrawing the proposed changes to Function 1 and Function 2 and is proposing to revise the change to Function 4 in order to improve the presentation of the requirement. There are no changes to the design or operation of the functions. The updated proposed change continues to reflect an editorial presentation preference only.

The revision to the original LAR reflects an improvement to the LAR and does not expand the scope of the request, or alter the conclusions of the Significant Hazards Consideration Determination or Environmental Considerations submitted in LAR-17-024.

Changes to Original LAR-17-024:

Changes to Enclosure 1 Revise Page 11 of 39 of Enclosure 1 to ND-17-1279 as indicated below:

L07 Detailed Description 3.3.5-3 1. Change the Table 3.3.5-1 Function 1, Manual Reactor Trip Required Channels from 2 to 2 switches.

LR

2. Change the Table 3.3.5-1, Function 2, Safeguards Actuation Input from Engineered Safety Feature Actuation System - Manual Required Channels from 2 to 2 switches.

3. Change the Table 3.3.5-1, Function 4, Core Makeup Tank Actuation Input from Engineered Safety Feature Actuation System - Manual Required Channels from to 2 switch sets to 2 switches.

Technical Evaluation A manual actuation switch set refers to a pair of redundant switches on the Primary Dedicated Safety Panel (PDSP), and for some protective functions, one switch on the Secondary Dedicated Safety Panel (SDSP). The second set of redundant switches is located on the SDSP for the actuation of all Page 2 of 3

ND-18-0871 Supplement to Request for License Amendment: Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes (LAR-17-024S3) safety functions that cause the operation of components with onerous consequences. In order to initiate the protective function of switch sets that have both a PDSP switch and associated SDSP switch, they must be actuated simultaneously. For Reactor Trip and Engineered Safety Features Actuation System (ESFAS) functions with manual actuation switches located only on the PDSP, the term switch set does not apply.

Table 3.3.5-1, Functions 1 and 2 states 2 channels, and Function 4, states 2 switch sets for the manual actuation reactor trip function under the Required Channels column. The Protection and Safety Monitoring System (PMS) design of the manual actuation reactor trip provides two redundant switches controls on the PDSP, with no corresponding switches controls on the SDSP. This is consistent with the description of the manual actuation of Function 4 in UFSAR (plant-specific DCD) Subsection 7.2.1.1.8 and Figure 7.2-1 Sheet 12. For this configuration, the term switch set does not reflect the design. Operation of either control will result in a CMT actuation signal and also will result in a reactor trip signal. For this configuration, the term switches for Functions 1, 2 and 4, manual reactor trip is applicable for this proposed change. There is no change in manual actuation reactor trip functions with these this changes, or any change in PMS function. The proposed changes to the Reactor Trip and ESFAS manual actuation is being made for consistency with the design.

Revise the description of change L07 on Page 34 of 39 to match the above discussion as follows:

L07 SNC proposes to amend TS, Section 3.3.5, "Reactor Trip System Manual Actuation," Table 3.3.5-1 Reactor Trip System Manual Actuation, Functions 1. Manual Reactor Trip, 2. Safeguards Actuation Input from Engineered Safety Feature Actuation System - Manual and 4., Core Makeup Tank Actuation Input from Engineered Safety Feature Actuation System - Manual for Required Channels to 2 (delete switch sets) switches.

Page 3 of 3

Southern Nuclear Operating Company ND-18-0871 Enclosure 10 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Proposed Changes to Licensing Basis Documents (LAR-17-024S3)

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

Withdrawal of added text Denoted by Blue Strikethrough with Yellow Highlight (This Enclosure consists of 2 pages, including this cover page)

ND-18-0871 0 Supplement to Proposed Changes to Licensing Basis Documents (LAR-17-024S3)

On Page 8 of 9 of Enclosure 2 of SNC letter ND-17-1279, replace change L07 with the following:

Revised COL Appendix A (Technical Specifications), TS 3.3.5, RTS Manual Actuation, as follows (L07):

APPLICABLE MODES OR OTHER SPECIFIED FUNCTION CONDITIONS REQUIRED CHANNELS

1. Manual Reactor Trip * *

• 2 switches

2. Safeguards Actuation Input from Engineered

• *

• 2 switches Safety Feature Actuation System - Manual

3. ADS Stages 1, 2, and 3 Actuation Input from 2 switch sets Engineered Safety Feature Actuation System - * *

• Manual

4. Core Makeup Tank Actuation Input from 2 switchesswitch sets Engineered Safety Feature Actuation System - * *

• Manual Page 2 of 2

Southern Nuclear Operating Company ND-18-0871 Enclosure 11 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Conforming Technical Specifications Bases Changes (For Information Only)

(LAR-17-024S3)

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

Withdrawal of inserted text Denoted by Blue Strikethrough with Yellow Highlight Withdrawal of change to existing text Denoted by Black with Yellow Highlight (This Enclosure consists of 3 pages, including this cover page)

ND-18-0871 1 Supplement to Conforming Technical Specifications Bases Changes (For Information Only)

(LAR-17-024S3)

On Page 10 and 11 of 12 of Enclosure 3 to SNC letter ND-17-1279, replace change L07 with the following:

Revised Technical Specification Bases, Section B 3.3.5, RTS Manual Actuation, as follows (L07):

APPLICABLE * *

• SAFETY ANALYSES, LCOs, 1. Manual Reactor Trip and APPLICABILITY The LCO requires two Manual Reactor Trip actuation channelsswitches to be OPERABLE in MODES 1 and 2, and in MODES 3, 4, and 5 when the Plant Control System (PLS) is capable of rod withdrawal, or one or more rods are not fully inserted. Two independent actuation channelsswitches are required to be OPERABLE so that no single random failure will disable the Manual Reactor Trip Function.

2. Safeguards Actuation Input from Engineered Safety Feature Actuation System - Manual The LCO requires two manual channelsswitches of Safeguards Actuation Input from ESFAS to be OPERABLE in MODES 1 and 2.

Page 2 of 3

ND-18-0871 1 Supplement to Conforming Technical Specifications Bases Changes (For Information Only)

(LAR-17-024S3)

4. Core Makeup Tank (CMT) Actuation Input from Engineered Safety Feature Actuation System - Manual The LCO requires two manual actuation switch setsswitcheschannels for the CMT Actuation Input from Engineered Safety Feature Actuation System to be OPERABLE.

Two OPERABLE manual actuation switch setsswitcheschannels are provided to ensure that random failure of a single logic channel will not prevent reactor trip.

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