ND-18-1058, Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

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Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)
ML18271A188
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 09/28/2018
From: Whitley B
Southern Nuclear Operating Co
To:
Document Control Desk, Office of New Reactors
Shared Package
ML18271A187 List:
References
LAR-17-043S1, ND-18-1058
Download: ML18271A188 (33)
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Text

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

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7079 Fax 205.992.7722 September 28, 2018 Docket Nos.: 52-025 ND-18-1058 52-026 10 CFR 50.90 10 CFR 2.390 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 and Exemption:

Containment Pressure Analysis (LAR-17-043S1)

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 includes changes to the Updated Final Safety Analysis Report (UFSAR) in the form of departures from the incorporated plant-specific Design Control Document (DCD) Tier 2* and Tier 2 information and related changes to the VEGP Units 3 and 4 COL Appendix A and COL Appendix C (and corresponding plant-specific DCD Tier 1) information.

SNC originally submitted this request by SNC letter ND-17-2074, dated December 21, 2017

[ADAMS Accession No. ML18029A243]. The requested amendment involves changes to incorporate the results of the updated analyses within the information presented in COL Appendix A, COL Appendix C (and corresponding plant-specific Tier 1) and the UFSAR.

Enclosures 1 through 10 were provided with the original License Amendment Request (LAR). 1 provides the public version of the responses to Requests for Additional Information (RAIs) requested by the NRC Staff on July 13, 2018 [ADAMS Accession No. ML18197A105] and on September 5, 2018 [ML18248A161]. 2 provides the proprietary version of the responses to Requests for Additional Information (RAIs) requested by the NRC Staff as identified above. 3 provides the applicable revised markups depicting the requested change to the licensing basis documents requiring NRC staff approval. Note that the ITAAC markups are also updated to be consistent with the ITAAC consolidation approved in Amendment Nos. 113 and 112 for VEGP Units 3 and 4, respectively.

U.S. Nuclear Regulatory Commission ND-18-1058 Page 2 of 5 2 contains information that is considered proprietary; therefore, Enclosure 12 is requested to be withheld from disclosure to the public under 10 CFR 2.390.

An affidavit from SNC supporting withholding under 10 CFR 2.390 is provided as Enclosure 14. 5 is Westinghouse's Proprietary Information Notice, Copyright Notice and CAW-18-4790, Application for Withholding Proprietary Information from Public Disclosure and Affidavit. The affidavit sets forth the basis upon which the information may be withheld from public disclosure by the Commission and addresses with specificity the considerations listed in paragraph (b)(4) of Section 2.390 of the Commission's regulations. Accordingly, it is respectfully requested that the information that is proprietary to Westinghouse be withheld from public disclosure in accordance with 10 CFR Section 2.390 of the Commission's regulations.

The information provided in this LAR supplement does not expand the scope of the request, nor alter the conclusions of the Significant Hazards Consideration Determination or Environmental Considerations submitted in LAA-17-043.

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

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

Should you have any questions, please contact Ms. Amy C. Chamberlain at (205) 992-6361 .

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-18-1058 Page 3 of 5

Enclosures:

1) - 10) (previously submitted with the original LAR, LAR-17-043, in SNC letter ND-17-2074)
11) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)
12) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proprietary Supplement to Request for License Amendment and Exemption:

Containment Pressure Analysis (LAR-17-043S1) (Withheld Information)

13) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Supplement to Proposed Changes to Licensing Basis Documents (LAR-17-043S1)
14) Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390
15) Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-18-4790, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice

U.S. Nuclear Regulatory Commission ND-18-1058 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. 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 12)

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

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

U.S. Nuclear Regulatory Commission ND-18-1058 Page 5 of 5 Municipal Electric Authority of Georgia Mr. J. E. Fuller (w/o enclosure 12)

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

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

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 12)

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

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

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

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

Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy (w/o enclosure 12)

Mr. S. Franzone, Florida Power & Light (w/o enclosure 12)

Southern Nuclear Operating Company ND-18-1058 Enclosure 11 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Request for License Amendment and Exemption:

Containment Pressure Analysis (LAR-17-043S1)

(This enclosure consists of 10 pages, including this cover page)

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

Vogtle Electric Generating Plant (VEGP) Units 3 and 4 submitted License Amendment Request LAR-17-043 via Southern Nuclear Operating Company (SNC) ND-17-2074, dated December 21, 2017 [ADAMS Accession No. ML18029A243]. This portion of the enclosure addresses questions from the NRC Staff which were received on July 13, 2018 as Requests for Additional Information (RAIs) [ADAMS Accession No. ML18197A105].

Question 1: ITAAC cleanup General Design Criterion 40, Testing of Containment Heat Removal System, requires in part that the containment heat removal system be designed to permit appropriate functional testing to assure the operability of the system as a whole, and under conditions as close to the design as practical the performance of the full operational sequence that brings the system into operation, including operation of the associated cooling water system.

Section 3.1.5 of the LAR requests a revision to an ITAAC criterion allowing for analysis showing that as-tested performance of the passive containment cooling system (PCS) is greater than that assumed in the peak pressure analyses as a result of PCS water flow testing conducted on other AP1000 plants. However, it was not clear from the additional criteria proposed what the nature of the analysis would be in the event the flow criteria were not satisfied. While the proposed analysis would generally satisfy the design commitment, the analysis itself is not described in sufficient detail in the LAR for staff to conclude that the report referenced in the ITAAC could meet the intent of the proposed change.

Therefore, staff requests that the licensee clarify the submittal to define the acceptance criteria (i.e. a report exists and concludes that the as-measured flow rates provide the PCS with sufficient heat removal capability such that the limiting safety analysis values (for the chosen figures of merit - flow rate, etc.) assumed in the peak containment pressure and temperature analyses remain bounding), and provide a summary in the response describing the role of the calculation in more detail than the LAR. Further, the staff review requires the submittal contain a detailed description of how the expected calculation (i.e., a comparison of a calculation performed in WGOTHIC demonstrating the heat transfer for the test exceeds the obtained results) shows that the, as-tested delivered flow rates were compared to the minimum safety analysis delivered flow rates showing that although the flow at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> did not meet the minimum 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> flow rate, the system (including uncertainties) performed better than expected. This information is requested so that the staff can make a finding on the suitability of the revised ITAAC and to ensure the new, proposed ITAAC has clearly inspectable acceptance criteria in the event that the flow criteria are not satisfied.

SNC Response to Question 1 Note that the ITAAC markups in Enclosure 13 are updated to be consistent with the ITAAC consolidation approved in Amendment Nos. 113 and 112 for VEGP Units 3 and 4, respectively. The references in this response are similarly revised.

Section 3.1.5 of LAR-17-043 requests a revision to the criterion of ITAAC 2.2.02.07b to state or a report exists and concludes that the as-measured flow rates bound the Page 2 of 10

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1) 72-hour containment peak pressure and temperature results. The intention of this addition is to clarify if passive containment cooling system (PCS) flow test results indicate lower flowrates at any time during the 72-hour testing than specified in ITAAC 2.2.02.07b, the proposed ITAAC wording change would allow an alternate means of meeting the ITAAC design commitment by performing an analysis. The analysis would be a sensitivity to the limiting UFSAR Chapter 6 design basis accident (DBA) WGOTHIC cases. The analysis would use PCS flowrates from the test results, accounting for measurement uncertainties, as input to the containment cooling calculation. This may include higher PCS flowrates at some points of time relative to the minimum flowrates in the analysis of record (which are consistent with the ITAAC acceptance criteria). All other analysis assumptions will remain the same. The acceptance criteria for the sensitivity cases will be as follows:

Peak containment pressures will be no greater than those reported in UFSAR Table 6.2.1.1-1.

Peak containment temperatures will be no greater than those reported in UFSAR Table 6.2.1.1-1.

Containment temperature transient will remain below the EQ limits in UFSAR Figure 3D.5-8 (Sheet 1 of 2).

Containment pressure transient will remain below the EQ limits in UFSAR Figure 3D.5-8 (Sheet 2 of 2).

Containment pressure is reduced to at least half of design pressure (29.5 psig) at 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> consistent with GDC 38 as listed in Table 6.2.1.1-3.

If the above acceptance criteria are met, the sensitivity analysis will be documented, according to our NRC approved QMS and detailed policies and procedures that conform to 10CFR50 Appendix B, and the report will be the basis for the ITAAC being met.

The proposed text addition to ITAAC 2.2.02.07b will be changed as follows to both acceptance criterion i) and ii):

Or a report exists and concludes that the as-measured flow rates delivered by the PCCWST to the containment vessel provides sufficient heat removal capability such that the limiting containment pressure and temperature values are not affected, and the PCS is able to perform its safety function to remove heat from containment to maintain plant safety.

Question 2: Code update language General Design Criterion 38, Containment Heat Removal, requires in part that a system to remove heat from the reactor containment be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

Page 3 of 10

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

As stated in the LAR, WGOTHIC is the code used to demonstrate the capability of the AP1000 containment to satisfy the aforementioned requirements. Enclosure 2 of the LAR, the revised WCAP-15846, describes the methodology as implemented in WGOTHIC used to calculate the containment performance parameters.

In Section 3.2 of WCAP-15846, the revisions to WGOTHIC proposed as part of the LAR are described. Additionally, the document states that, subsequent code version updates will be made to address changes in computing platforms, correction of errors, and updates to enhance the user experience without it being a change in methodology. Therefore, updates will not be made to this document unless a methodology-changing code change is made.

Staff understands the basis for the statement, which generally aligns with the provisions of 10 CFR 50.59, 52.98, or other like change processes. However, as written, it is not clear to the staff that, correction of errors would always fall within the constraints of those change processes.

Therefore, the staff requests that the text in Section 3.2 of WCAP-15846 be clarified to identify the types of errors that would rise to the level of a, methodology-changing code change.

SNC Response to Question 2 Westinghouse Electric Company (WEC) manages computer codes in accordance with its NRC-approved Quality Management System (QMS) and detailed policies and procedures that conform to 10CFR50 Appendix B via the endorsed edition of ASME NQA-1. A tracking mechanism in the Westinghouse AP1000 document management system, Known Issue 00000419, is opened against WCAP-15846 and documents that the wording in Section 3.2 is required to be updated during a future revision or update of WCAP-15846 consistent with the text provided below.

Changes and errors to the methodology or implementation of the methodology that also necessitate a change in software will require an update to this document. Code version updates that do not involve a change in methodology (e.g., updates for changes in computing platforms, user interface improvements, correction of non-methodology errors such as typographical errors, additional functionality not related to the methodology documented herein) will not require a change to this document in the future.

SNC Commits to ensuring the above change is included in WCAP-15846 when the WCAP is updated in the future. SNC will track this commitment and WECs incorporation through our commitment tracking system.

Question 3: Heat sinks General Design Criterion 50, Containment Design Basis, requires in part that the reactor containment structure, including access openings, penetrations, and the containment heat removal system be designed so that the containment structure and its internal compartments can accommodate, without exceeding the design leakage rate and with sufficient margin, the calculated pressure and temperature conditions resulting from any loss-of-coolant accident.

Page 4 of 10

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

This margin shall reflect consideration the conservatism of the calculational model and input parameters.

In order to demonstrate adequate containment performance, the analytical model credits a number of thermal conductors as heat sinks. These heat sinks are documented at a high level in the FSAR and LAR, and described in further detail in WCAP-15846 and the supporting documentation. As part of the LAR, additional heat sinks are being credited in addition to refinements to the heat sink parameters resulting from more information becoming available during detailed design.

In order to support the staffs review of the revised heat sink inventory, the staff requests additional information documenting or quantifying the relative impacts of the conservatism in the heat sink parameters. Specifically, given that the model as proposed credits a stated conservative inventory of heat sinks, staff requests a sensitivity case for the calculated containment pressure with a nominal heat sink area credited, as well as any sensitivity cases for the calculated pressure for other relevant parameters that have a quantifiable impact on the conservatism in the analysis.

Response to Question 3 - Heat sinks The updated containment peak pressure safety analyses submitted as part of LAR 043 have used conservative heat sink modeling that is consistent with the current licensing basis. As described in Section 13.4 of WCAP-15846, Revision 5, the heat sinks (also known as thermal conductors) in the WGOTHIC peak containment pressure evaluation model (EM) have the following modeling elements which address uncertainties and add conservatism to the analysis results.

1. All heat sink structures are assumed to be at the maximum containment operating temperature. Only structures at ambient containment conditions are credited for heat transfer.
2. Coatings are applied to carbon steel and concrete surfaces and perform an insulating function (increase in resistance to heat transfer) with the assumptions of:

maximum thickness and minimum thermal conductivity

3. The thermal conductivity and volumetric heat capacity of the metal heat sink materials are reduced by 10% from the nominal values in ASME, Part II Appendix D.
4. [Rebar within concrete is not credited.]a,c
5. [A 20 mil air-gap is assumed for all steel-jacketed concrete walls.]a,c
6. [Heat transfer in dead-end compartments is not credited after the loss of coolant accident (LOCA) blow-down (approximately the first 30 seconds).]a,c
7. [Heat transfer to large horizontal surfaces is not credited.]a,c
8. [10% of the quantified metal heat sinks inside containment are turned off, with a bias towards at least half of that being below the operating deck.]a,c Page 5 of 10

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

The effect of the above modeling elements that address uncertainties and conservatisms accounts for an approximately 8 psi impact on the peak containment pressure for the limiting LOCA case and approximately 5 psi for the limiting steamline break (SLB) case.

This effect is based on sensitivities that alter the above assumptions by modeling nominal heat sink material properties, initializing the heat sinks at a more realistic containment temperature, and crediting all quantified heat sinks for the duration of the transient. Turning off additional quantified heat sink metal inside containment, the last item in the list above, is responsible for approximately 1 psi of the conservatism.

The sensitivities performed do not include impacts of the following:

The containment vessel that is modeled with the use of the WGOTHIC climes, the portion that transfers heat to the environment via the passive containment cooling system (PCS), remains unchanged from the EM.

[The air gap for steel-jacketed concrete walls is unchanged.]a,c

[Structures at elevated temperatures are not credited.]a,c There has been no increase of heat sinks to compensate for those that are known to be under-quantified or have not been quantified in the WGOTHIC peak containment pressure EM.

The effect of rebar remains unquantified.

Coating thicknesses are not changed.

Question 4: Baffle support flow losses General Design Criterion 38, Containment Heat Removal, requires in part that a system to remove heat from the reactor containment be provided. The system safety function shall be to reduce rapidly, consistent with the functioning of other associated systems, the containment pressure and temperature following any loss-of-coolant accident and maintain them at acceptably low levels.

As described in WCAP-15846, film losses from the containment shell from welds and baffle support attachments are modeled based on a combination of testing and a set of bounding assumptions. Specifically, Section 7.2.6 of the WCAP references, phase 2 condensation tests and states that, while the tests were designed to simulate conditions inside the containment, some of the conclusions are applicable to the issue of film stripping by the baffle supports on the outside the containment. The majority of the testing described in the WCAP has been reviewed by the NRC either as part of the design certification application or other licensing actions.

Although staff has audited the material related to this application, the level of detail of docketed information related to this testing is insufficient to reference in the staff safety evaluation.

In order to make a reasonable assurance finding regarding the suitability of the assumptions made for condensation losses over the containment shell, staff requests the licensee provide a high level summary of the test program and relevant outputs from the testing related to this LAR and to describe and justify the applicability of the testing performed to the current amendment, Page 6 of 10

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1) including identifying any discrepancies between the actual test conditions and expected facility conditions and their relevance to the results.

SNC Response to Question 4 Phase 2 of the condensate return test program was performed at the Westinghouse Churchill, PA facility from July 2014 to March 2015 with the purpose of providing test data to quantify how much of the condensate formed on the inside of the containment vessel walls and dome is captured by the system that returns the water to the in-containment refueling water storage tank (IRWST). The test facility consisted of a 7 long x 3 wide flat plate that could be positioned at varying angles. The plate was housed in a stainless steel pressure vessel rated for pressure and temperature conditions expected during a station blackout event. To simulate film flow entering the control surface, a film was applied at the upper 1 length of the test plate. In addition to the applied film, cooling channels were located next to the plate which caused condensation. Troughs and tanks were configured to separately collect condensate that remained on the test plate versus condensate that was lost from the plate and attachment plates. There were six test configurations which included a flat plate only, an attachment plate affixed to the flat plate, and a circumferential weld seam on the flat plate. Over 200 tests were run that varied the plate angle, the plate heat flux, the applied film flow rate, and the temperature of the environment.

As noted in Section 7.2.6 of WCAP-15846, the condensate testing conditions varied from the exterior PCS flow in both the flowrate and the difference in the film behavior for condensation versus evaporation. Therefore, the condensate return testing result that water film bypassed supports and remained attached to the vertical containment vessel wall was not credited in the application to the PCS rainout modeling in the WGOTHIC evaluation model. Instead it is conservatively assumed that all PCS water that encounters a baffle support on the vertical section of the outside of the containment vessel region is stripped from the surface and thus not credited for heat transfer.

Approximately 90% of the baffle supports are on the vertical region of the containment vessel.

The remaining approximately 10% of the baffle supports are located on the containment dome and no PCS rainout losses are assumed to occur for this region. As noted in Section 7.2.6 of WCAP-15846, any water that might splash off this row would fall vertically downward and contact the dome located below the support.

Qualitative test observations were used to assess that there are no additional losses due to the longitudinal welds of the baffle supports. The 1/4 bevel weld on each longitudinal side of the baffle U-support is similar to both 1/4 and 1/2 welds used in the condensate return testing that did not result in any additional condensate losses. The low profile of the welds makes it so this conclusion is applicable for PCS water flowrates which are larger than the test conditions of the condensate return test program.

Page 7 of 10

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

Therefore, only qualitative observations from the condensate return testing are noted and there are no specific quantitative outputs used to support LAR-17-043. The primary purpose of referring to the condensate return testing was to illustrate the conservative approach applied to quantifying the PCS rainout losses for the containment evaluation model compared to the results as seen in the condensate return testing. There are no discrepancies between expected test facility conditions and actual test conditions that are relevant to the observations applied to WCAP-15846 and LAR-17-043.

This portion of the enclosure addresses questions from the NRC Staff which were received on September 5, 2018 as Requests for Additional Information (RAIs) [ADAMS Accession No. ML18248A161].

Question 1: Submergence 10 CFR 50.49(e) states that the electric equipment qualification program must include and be based on temperature, pressure, humidity, chemical effects, radiation, aging, submergence, synergistic effects and margins.

VEGP 3&4 UFSAR Section 3.D.4.3, "Mild Versus Harsh Environments," states that the AP1000 equipment qualification program conforms to the requirements of 10 CFR 50.49 for the qualification of harsh environment equipment. Furthermore, UFSAR Section 3.11.1.2, "Environmental Conditions," states that in the event of potential flooding/wetting, one of the following criteria is applied for protection of equipment for service in such an environment: 1) equipment will be qualified for submergence due to flooding/wetting, 2) equipment will be protected from wetting due to spray and 3) equipment will be evaluated to show that failure of the equipment due to flooding/wetting is acceptable since its safety-related function is not required or has otherwise been accomplished.

Staff reviewed LAR-17-043, APP-SSAR-GSC-157, Revision 1, "AP1000 Long-Term LOCA Containment Integrity Analysis with WGOTHIC," APP-SSAR-GSC-166, Revision 1, "AP1000 Steamline Break Containment Integrity Analysis," and APP-GW-VPR-008, Revision 0, "Evaluation of Environmental Conditions Envelope Exceedances."

The applicant in LAR-17-043, stated that mass and energy (M&E) releases for Loss of Coolant Accident (LOCA) and Main Steam Line Break (MSLB) events are also recalculated. Furthermore, the applicant stated in LAR 17-043, Section 3.1.4, "Updates to Containment Integrity (Containment Peak Pressure) Analyses," that the updated containment pressure and temperature does not result in a change to the limiting profiles assumed in the equipment qualification testing program. In addition, the applicant stated in the LAR that there are no radiation zone changes or radiological access control changes required due to the proposed changes.

Staff finds that the applicant has addressed the aspects of equipment qualification related to containment pressure and temperature as well as radiation but did not address equipment subject to submergence. Please discuss how the proposed changes affect equipment subject to submergence or please confirm that submerged equipment remains qualified as a result of the proposed changes. Please add a discussion in the LAR regarding the qualification of submerged equipment, as applicable.

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ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

SNC Response to Question 1 As identified in the submittal, the updated containment pressure and temperature analysis results do not present a change to the limiting profiles used in the equipment qualification testing program. Specifically, the containment pressure and vapor temperature analysis results continue to support the profiles as defined in UFSAR Subsection 3D.5.5.1.5 (and Figure 3D.5-8); a small number of exceedances were identified and dispositioned as acceptable in the Evaluation of Environmental Conditions Envelope Exceedances document (APP-GW-VPR-008) without needing to change the equipment qualification (EQ) profiles. The Evaluation of Environmental Conditions Envelope Exceedances document dispositions exceedances and includes submergence information (level, pressure, and temperature) for the direct vessel injection (DVI) line break located in the passive core cooling system (PXS) rooms. The information below addresses the exceedances of the submergence temperatures resulting from a double ended cold leg (DECL) loss of coolant accident (LOCA) that was not included with the other exceedances dispositioned in the above-referenced Evaluation of Environmental Conditions Envelope Exceedances document.

Submergence test conditions are not explicitly identified in the UFSAR; however, Subsection 3D.5.5.1.7 of the UFSAR states that for submergence Performance of equipment in a submerged condition is verified by a test that replicates the actual conditions with appropriate margin. EQ submergence test conditions for parameters such as timing of floodup and liquid temperatures in the flooded compartments are defined from various calculations and design documentation. Unlike the general vapor containment temperature and pressure profiles that are specifically linked to the containment peak pressure DBA analyses, submergence conditions are more complex and varied relative to the specific components being tested and their location in containment.

Revision 1 to the AP1000 Long-Term LOCA Containment Integrity Analysis with WGOTHIC (APP-SSAR-GSC-157) provides the containment pressure and temperature results of the DECL LOCA containment analysis. In particular, Subsection 5.2.1.3 compares the calculated liquid temperatures (representative following a design basis accident) to Table 2.1.3-14 of Revision 5 of the AP1000 Environmental Conditions for Equipment Qualification document (APP-GW-VP-030). As noted in Figures 5-48 through 5-51, the updated results in Revision 1 to the AP1000 Long-Term LOCA Containment Integrity Analysis with WGOTHIC (APP-SSAR-GSC-157) vary from the equipment qualification envelope in the early parts of the transient. As such, the AP1000 floodup liquid temperature curve in the AP1000 Environmental Conditions for Equipment Qualification document (APP-GW-VP-030) was updated to be more representative of the latest WGOTHIC DECL LOCA liquid temperatures based on Revision 1 to the AP1000 Long-Term LOCA Containment Integrity Analysis with WGOTHIC (APP-SSAR-GSC-157).

An Engineering & Design Coordination Report (E&DCR) (APP-PXS-GEF-363) implemented the change in liquid temperatures, from Table 2.1.3-14 of Revision 5 of the above-reference AP1000 Environmental Conditions for Equipment Qualification document to what became Table 6.1.3-15 in Revision 6 of the AP1000 Environmental Conditions for Equipment Qualification document (Note that Revision 6 was reformatted and the sections Page 9 of 10

ND-18-1058 1 Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1) and tables were renumbered). Thus, the liquid temperature profile from Revision 1 to the AP1000 Long-Term LOCA Containment Integrity Analysis with WGOTHIC (APP-SSAR-GSC-157) is the interface of the AP1000 plant floodup liquid temperatures for submergence equipment qualification moving forward. As noted in the E&DCR which implemented the change in liquid temperatures (APP-PXS-GEF-363), commodities that have previously undergone qualification testing with consideration to liquid temperatures were deemed to remain acceptable because reviews of the actual, as-tested liquid temperature profile compared to the updated profile showed that there was sufficient margin and that the results and conclusions of the qualification testing remained valid for these components.

Thus, the updated DECL LOCA peak containment pressure and temperature analysis provides updated submergence liquid temperatures but did not affect equipment previously tested for submergence and submerged equipment remains qualified as a result of the proposed changes that are detailed in LAR-17-043.

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Southern Nuclear Operating Company ND-18-1058 Enclosure 13 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Supplement to Proposed Changes to Licensing Basis Documents (LAR-17-043S1)

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

Highlighted items updated per ITAAC consolidation Amendment Nos. 113 and 112 for VEGP Units 3 and 4, respectively (This enclosure consists of 3 pages, including this cover page)

ND-18-1058 Enclosure 13 Supplement to Proposed Changes to Licensing Basis Documents (LAR-17-043S1)

On Pages 2, 3 and 4 of 76 of Enclosure 3 of SNC letter ND-17-2074, replace change to ITAAC 2.2.02.07a and 2.2.02.07b with the following:

COL Appendix C and Plant-Specific Tier 1 Changes COL, Appendix C, Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) Number 138 Acceptance Criteria and corresponding Plant Specific Tier 1 Subsection 2.2.2 Passive Containment Cooling System Table 2.2.2-3 is revised as follows:

Table 2.2.2-3 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 138 2.2.02.07b.i 7.a) The PCS delivers water from i) Testing will be performed to i) When tested, each one of the the PCCWST to the outside, top of measure the PCCWST three flow paths delivers water at the containment vessel. delivery rate from each one of greater than or equal to:

the three parallel flow paths. - 469.1 gpm when * * *

- 226.6 gpm when * * *

- 176.3 gpm when * * *

- 144.2 gpm when the PCCWST water level uncovers the third tallest standpipe

- or a report exists and concludes that the as-measured flow rates delivered by the PCCWST to the containment vessel provides sufficient heat removal capability such that the limiting containment pressure and temperature values are not affected and the PCS is able to perform its safety function to remove heat from containment to maintain plant safety.

Page 2 of 3

ND-18-1058 Enclosure 13 Supplement to Proposed Changes to Licensing Basis Documents (LAR-17-043S1)

Table 2.2.2-3 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria ii) Testing and or analysis will ii) When tested and/or analyzed be performed to demonstrate with all flow paths delivering and the PCCWST inventory an initial water level at 27.4 +

provides 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of adequate 0.2, - 0.00 ft, the PCCWST water water flow. inventory provides greater than or equal to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> of flow, and the flow rate at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is greater than or equal to 100.7 gpm or a report exists and concludes that the as-measured flow rates delivered by the PCCWST to the containment vessel provides sufficient heat removal capability such that the limiting containment pressure and temperature values are not affected and the PCS is able to perform its safety function to remove heat from containment to maintain plant safety.

7.b) The PCS wets the outside i) * *

  • i) * *
  • surface of the containment vessel. ii) * *
  • ii) * *
  • The inside and the outside of the iii) Inspection of the iii) A report exists and concludes containment vessel above the containment vessel interior that the containment vessel operating deck are coated with an coating will be conducted. interior surface is coated with an inorganic zinc material.

inorganic zinc coating above 7' above the operating deck.

Page 3 of 3

Southern Nuclear Operating Company ND-18-1058 Enclosure 14 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (This enclosure consists of 2 pages, plus this cover page.)

ND-18-1058 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-17-043S1)

Affidavit of Brian H. Whitley

1. My name is Brian H. Whitley. I am the Regulatory Affairs Director for Southern Nuclear Operating Company (SNC). I have been delegated the function of reviewing proprietary information sought to be withheld from public disclosure and am authorized to apply for its withholding on behalf of SNC.
2. I am making this affidavit on personal knowledge, in conformance with the provisions of 10 CFR Section 2.390 of the Commissions regulations, and in conjunction with SNCs filing on dockets52-025 and 52-026, Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1) . I have personal knowledge of the criteria and procedures used by SNC to designate information as a trade secret, privileged or as confidential commercial or financial information.
3. Based on the reason(s) at 10 CFR 2.390(a)(4), this affidavit seeks to withhold from public disclosure Enclosure 12 of SNC letter ND-18-1058 for Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1).
4. The following is furnished for consideration by the Commission in determining whether the information sought to be withheld from public disclosure should be withheld.
a. The information sought to be withheld from public disclosure has been held in confidence by SNC and Westinghouse Electric Company.
b. The information is of a type customarily held in confidence by SNC and Westinghouse Electric Company and not customarily disclosed to the public.

Page 2 of 3

ND-18-1058 4 Affidavit from Southern Nuclear Operating Company for Withholding Under 10 CFR 2.390 (LAR-17-043S 1)

c. The release of the information might result in the loss of an existing or potential competitive advantage to SNC and/or Westinghouse Electric Company.
d. Other reasons identified in Enclosure 15 of SNC letter ND-18-1 058 for Vogtle Electric Generating Plant Units 3 and 4, Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1), and those reasons are incorporated here by reference.
5. Additionally, release of the information may harm SNC because SNC has a contractual relationship with the Westinghouse Electric Company regarding proprietary information. SNC is contractually obligated to seek confidential and proprietary treatment of the information.
6. The information is being transmitted to the Commission in confidence and, under the provisions of 10 CFR Section 2.390, it is to be received in confidence by the Commission.
7. To the best of my knowledge and belief, the information sought to be protected is not available in public sources or available information has not been previously employed in the same original manner or method.

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

_ ____._A_.-_~U_-_..;,V0_tf4_*""::T---------

Bnan H. Whitley Executed on '1/~8/rf)

Date Page 3 of 3

Southern Nuclear Operating Company ND-18-1058 Enclosure 15 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Westinghouse Application for Withholding Proprietary Information from Public Disclosure CAW-18-4790, accompanying Affidavit, Proprietary Information Notice, and Copyright Notice (This enclosure consists of 11 pages, plus this cover page.)

August 23, 2018 SVP_SV0_005278 Page 1 of 11 ENCLOSURE 2 to SVP_SV0_005278 Application for Withholding Proprietary Information from Public Disclosure, CAW-18-4790, Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1)

August 23, 2018 SVP_SV0_005278 Page 2 of 11 August 23, 2018 SVP_SV0_005278 Page 3 of 11 Westinghouse Non-Proprietary Class 3 Westinghouse Electric Company 1000 Westinghouse Drive Cranberry Township, Pennsylvania 16066 USA Enclosures to CAW-18-4790

1. AFFIDAVIT
2. PROPRIETARY INFORMATION NOTICE and COPYRIGHT NOTICE

© 2018 Westinghouse Electric Company LLC. All Rights Reserved.

August 23, 2018 SVP_SV0_005278 Page 4 of 11 ENCLOSURE 1 to CAW-18-4790 AFFIDAVIT August 23, 2018 SVP_SV0_005278 Page 5 of 11 August 23, 2018 SVP_SV0_005278 Page 6 of 11 3 CAW-18-4790 (1) I am Manager, Licensing Inspections and Special Programs, Westinghouse Electric Company LLC (Westinghouse), and as such, I have been specifically delegated the function of reviewing the proprietary information sought to be withheld from public disclosure in connection with nuclear power plant licensing and rule making proceedings, and am authorized to apply for its withholding on behalf of Westinghouse.

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

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

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

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

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

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

(a) The information reveals the distinguishing aspects of a process (or component, structure, tool, method, etc.) where prevention of its use by any of August 23, 2018 SVP_SV0_005278 Page 7 of 11 4 CAW-18-4790 Westinghouses competitors without license from Westinghouse constitutes a competitive economic advantage over other companies.

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

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

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

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

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

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

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

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

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

August 23, 2018 SVP_SV0_005278 Page 8 of 11 5 CAW-18-4790 (d) Each component of proprietary information pertinent to a particular competitive advantage is potentially as valuable as the total competitive advantage. If competitors acquire components of proprietary information, any one component may be the key to the entire puzzle, thereby depriving Westinghouse of a competitive advantage.

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

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

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

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

(vi) The proprietary information sought to be withheld in this submittal is that which is appropriately marked in ND-18-1058, Supplement to Request for License Amendment and Exemption: Containment Pressure Analysis (LAR-17-043S1), for submittal to the Commission, being transmitted by Southern Nuclear Operating Company letter. The proprietary information as submitted by Westinghouse is that associated with Southern Nuclear Operating Company License Amendment Request in ND-17-2074 (WEC LAR-079; Southern LAR-17-043), and may be used only for that purpose.

(a) This information is part of that which will enable Westinghouse to (i) Manufacture and deliver products to utilities based on proprietary designs.

August 23, 2018 SVP_SV0_005278 Page 9 of 11 6 CAW-18-4790 (b) Further, this information has substantial commercial value as follows:

(i) Westinghouse plans to sell the use of similar information to its customers for the purpose of licensing of new nuclear power stations.

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

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

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

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

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

Further the deponent sayeth not.

August 23, 2018 SVP_SV0_005278 Page 10 of 11 ENCLOSURE 2 to CAW-18-4790 PROPRIETARY INFORMATION NOTICE and COPYRIGHT NOTICE August 23, 2018 SVP_SV0_005278 Page 11 of 11 PROPRIETARY INFORMATION NOTICE Transmitted herewith are proprietary and non-proprietary versions of a document, furnished to the NRC in connection with requests for generic and/or plant-specific review and approval.

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

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

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