NL-24-0128, License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency

License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency

ML24095A354
Person / Time
Site:	Vogtle
Issue date:	04/04/2024
From:	Coleman J Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-24-0128
Download: ML24095A354 (1)

Text

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.5000 April 4, 2024 NL-24-0128 10 CFR 50.90 Docket Nos.: 52-025 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Unit 3 License Amendment Request: Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) Testing Frequency Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Vogtle Electric Generating Plant (VEGP) Unit 3 combined license (COL) NPF-91. The license amendment request (LAR) proposes changes to COL Appendix A, Technical Specification (TS) 5.5.13, Ventilation Filter Testing Program (VFTP), to provide an exception to the 24-month testing frequency. The exception proposes to defer the next required performance until prior to startup from the first refueling outage. This exception would apply to inplace penetration and system bypass testing of the high efficiency particulate air (HEPA) filter, inplace penetration and system bypass testing of the charcoal adsorber, and pressure drop testing across the HEPA filter, the charcoal adsorber, and the post filter, as specified in TS 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4, respectively.

The Enclosure provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration determination) and environmental considerations for the proposed change.

SNC requests approval of the proposed license amendment request on or before May 10, 2024 based on the current due date schedule for these tests. The challenge associated with the increased risk to plant safety of attempting to perform this test at power was only recently fully realized. As such, SNC requests an accelerated review schedule.

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, a copy of this application, with enclosures, is being provided to the designated State official(s).

If you have any questions, please contact Mr. Ryan Joyce at (205) 992-6468.

U. S. Nuclear Regulatory Commission NL-24-0128 Page 2 I declare under penalty of perjury that the foregoing is true and correct.

Executed on the 4th day of April 2024.

Respectfully submitted, Jaime M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Company Enclosure Evaluation of Proposed Changes cc:

NRC Regional Administrator, Region ll NRR Project Manager - Vogtle 3 Senior Resident Inspector - Vogtle 3 State of Georgia Environmental Protection Division Document Services RTYPE: VND.LI.L00

Enclosure to NL-24-0128 Evaluation of Proposed Changes Enclosure to NL-24-0128 Evaluation of Proposed Changes

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION 2.1. System Design and Operation 2.2. Current Technical Specifications Requirements 2.3. Reason for the Proposed Change 2.4. Description of the Proposed Change

3.

TECHNICAL EVALUATION

4.

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

5.

ENVIRONMENTAL CONSIDERATION Attachments

1. Technical Specification Marked-up Pages

2. Revised Technical Specification Pages (This enclosure consists of 10 pages, including this cover page.)

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-2 1.0

SUMMARY

DESCRIPTION The proposed change would revise the Combined License (COL) for Vogtle Electric Generating Plant (VEGP) Unit 3 by revising COL Appendix A Technical Specification (TS) 5.5.13, Ventilation Filter Testing Program (VFTP), to provide an exception to the 24-month testing frequency. The exception proposes to defer the next required performance until prior to startup from the first refueling outage. This exception would apply to inplace penetration and system bypass testing of the high efficiency particulate air (HEPA) filter, inplace penetration and system bypass testing of the charcoal adsorber, and pressure drop testing across the HEPA filter, the charcoal adsorber, and the post filter, as specified in TS 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4, respectively.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation As described in VEGP Updated Final Safety Analysis Report (UFSAR) Subsection 9.4.1.1, Safety Design Basis, the nuclear island nonradioactive ventilation system (VBS) normally serves the main control room (MCR). VBS is designed to control the radiological habitability in the MCR within the guidelines presented in Standard Review Plan (SRP) 6.4, Control Room Habitability System, when AC power is available. This includes providing a reliable source of heating, ventilation, and cooling to the MCR (and other areas served) when AC power is available. The system equipment and component functional capabilities minimize the potential for actuation of the main control room emergency habitability system (VES) or the potential reliance on passive equipment cooling. This is achieved through the use of redundant equipment and components that are connected to standby onsite AC power sources.

The VES operation in maintaining the MCR habitable is discussed in UFSAR Section 6.4, Habitability Systems. The Engineered Safeguards Feature(ESF) VES provides a protected environment from which operators can control the plant following an uncontrolled release of radioactivity, hazardous chemicals, or smoke. The system is designed to operate following a Design Basis Accident (DBA) that requires protection from the release of radioactivity. In these events, VBS would continue to function if AC power is available. VES is actuated and the MCR pressure boundary isolated on either a High-2 particulate or iodine signal in the VBS supply ducting, a sustained loss of control room differential pressure, a sustained loss of all AC power, or manually by the operators.

The major functions of the VES are to: 1) provide forced ventilation to deliver an adequate supply of breathable air for the MCR occupants; 2) provide forced ventilation to maintain the MCR at a positive pressure with respect to the surrounding areas; 3) provide passive filtration to filter potential contaminated air in the MCR; and 4) maintain MCR temperature within acceptable limits to assure the MCR equipment and facilities that remain functional during design bases events.

The VES consists of 32 compressed air storage tanks arranged in four banks of eight tanks each, two air delivery flow paths, an eductor, a filtration flow path, and associated valves or dampers, piping, and instrumentation. The main control room passive filtration flow path contains a high-efficiency particulate (HEPA) filter in series with a charcoal

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-3 adsorber and a postfilter. They work to remove particulate and iodine from the air to reduce potential control room dose during VES operation.

As described in UFSAR subsection 6.4.4, System Safety Evaluation, in the event of an accident involving the release of radioactivity to the environment, VBS is expected to switch from the normal operating mode to the supplemental air filtration mode to protect the main control room personnel. Although the VBS is not a safety-related system, it is expected to be available to provide the necessary protection for realistic events. However, the design basis accident doses reported in UFSAR Chapter 15 utilize conservative assumptions, and the main control room doses are calculated based on operation of the safety-related VES. The analyses assume that the VBS is initially in operation but fails to enter the supplemental air filtration mode on a High-1 radioactivity indication in the main control room atmosphere. VES operation is then assumed to be initiated once the High-2 level for control room atmosphere iodine or particulate radioactivity is reached. Doses are also calculated assuming that the VBS does operate in the supplemental air filtration mode as designed, but with no switchover to VES operation. This VBS operating case demonstrates the defense-in-depth that is provided by the system and also shows that, in the event of an accident with realistic assumptions, the VBS is adequate to protect the control room operators without depending on VES operation. With VES operating the resultant conservatively calculated doses provide margin to the General Design Criterion 19 dose limit for control room operators.

2.2 Current Technical Specifications Requirements TS 5.5.13.a requires testing once each 24 months for:

5.5.13.a.1 for inplace penetration and system bypass testing of the high efficiency particulate air (HEPA) filter, 5.5.13.a.2 for inplace penetration and system bypass testing of the charcoal adsorber, and 5.5.13.a.4 for pressure drop testing across the HEPA filter, the charcoal adsorber, and the post filter.

2.3 Reason for the Proposed Change TS 3.7.6, Main Control Room Emergency Habitability System (VES), and its SR 3.7.6.10 (Perform required VES Passive Filtration system filter testing in accordance with the Ventilation Filter Testing Program (VFTP)) require operability of the filtration train to protect the control room operator, and when the filtration train is inoperable at power, entry into Condition F (second portion), VES inoperable for reasons other than Condition A, B, C, D, or E in MODE 1, 2, 3, or 4, is required, which imposes the Required Actions to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 in 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />.

The testing required by TS 5.5.13.a for 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4 for VEGP Unit 3 was last performed on November 11, 2021. As provided in TS 5.5.13.b, the provisions of Surveillance Requirement (SR) 3.0.2 apply and result in May 11, 2024 being the latest time for performance of the next required test. At this time, Unit 3 is at 100%

power, and is anticipated to remain at power until the refueling outage currently planned for the fourth quarter 2024. This results in the necessity to perform these tests while at power. Performance of these tests requires access to the filtration train such that it results

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-4 in the inoperability of the filtration train when in Modes 1, 2, 3, and 4, and the resultant requirement (in accordance with TS 3.7.6 Action F) to be in Mode 3 in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> solely due to the performance of the test.

As described and approved in NRC Final Safety Evaluation Report (FSER), Supplement 2 (ADAMS Accession No. ML112061231), subsection 6.4.2.2.6, Evaluation of the Single Failure of the Passive Filtration Line, VES filtration is a single-train passive feature. It is assumed to function during the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of an accident. Any inoperability of this filtration train in the first 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is a loss of that assumed safety function. As such, SNC proposes to defer the required periodic VFTP testing to the next scheduled outage, where in Mode 5 or 6, or defueled, and not moving irradiated fuel, VES operability is not required.

This reflects a more appropriate time to perform periodic testing on the single train ESF filtration train.

It is noted that the AP1000 VES single-train ESF filtration design differs from typical MCR habitability systems, where the system consists of two redundant trains such that removal of one of the two trains from service to perform the testing allows seven days for completing the testing and restoration of the system to operable status. This typical design is seen in various Standard Technical Specifications (STS) for MCR habitability systems as well as other ESF filtration systems.

Furthermore, while SNC believes the VFTP test would be satisfactorily performed with the time allowed by TS 3.7.6 Action F, concerns have recently been identified regarding scenarios where there is an unanticipated delay(s) once the system has been removed from service for testing. With only 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> to complete the test and return the filtration train system to operable status, any unanticipated testing setup difficulties, or unanticipated results caused by an improper test setup configuration, could challenge completing the testing and restoration activities within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and would increase the likelihood of an unnecessary shutdown of the plant.

Testing of single-train ESF systems that would require introducing a loss of an assumed safety function at power should only be required during periods when that safety function is not assumed; Mode 5 or 6, or defueled, and not moving irradiated fuel. For VES and the VFTP test proposed for deferral, the 24-month testing frequency provides the flexibility to schedule the testing during a refueling outage shutdown. However, since VEGP Unit 3 experienced an extended startup and testing program, the period between the initial performance and the subsequent 24-month required performance does not allow reaching the first refueling outage without exceeding the Surveillance grace period defined in TS SR 3.0.2. Prior to these delays, the first refueling outage was projected such that the VFTP testing would have been performed during the refueling outage.

The challenge associated with the increased risk to plant safety of attempting to perform this test at power was only recently fully realized. As such, SNC requests an accelerated review schedule.

2.4 Description of the Proposed Change The TS 5.5.13.a once each 24 months testing frequency for 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4 is revised to add except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage.

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-5 The markup showing the specific changes to TS 5.5.13.a is shown in Attachment 1.

=

Background===

As provided in TS SR 3.0.3, there are provisions for unplanned discoveries of missed Surveillances. While the current situation for the required VFTP testing is not an unplanned discovery (and therefore, SR 3.0.3 is not being utilized), the provisions of SR 3.0.3 do provide guidance applicable to evaluating the acceptability of deferring a surveillance. Specifically, SR 3.0.3 requires (emphasis added):

If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, which ever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.

The TS Bases for SR 3.0.3 also provide:

The basis for this delay period includes consideration of unit conditions, adequate planning, availability of personnel, the time required to perform the Surveillance, the safety significance of the delay in completing the required Surveillance, and the recognition that the most probable result of any particular Surveillance being performed is the verification of conformance with the requirements....

... While up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or the limit of the specified Frequency is provided to perform the missed Surveillance, it is expected that the missed Surveillance will be performed at the first reasonable opportunity. The determination of the first reasonable opportunity should include consideration of the impact on plant risk (from delaying the Surveillance as well as any plant configuration changes required or shutting the plant down to perform the Surveillance) and impact on any analysis assumptions, in addition to unit conditions, planning, availability of personnel, and the time required to perform the Surveillance.

The portion of SR 3.0.3 that allows the greater delay of up to the limit of the specified Frequency and the portion A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed were included in the VEGP Unit 3 original issued COL and originated from TSTF-358, Missed Surveillance Requirements. TSTF-358 (now included in each STS, including NUREG-2194, Standard Technical Specifications Westinghouse Advanced Passive 1000 (AP1000) Plants) included the following discussions:

TSTF-358

Background:

... SR 3.0.3 is based on NRC Generic Letter 87-09. GL 87-09 was published to address three specific issues with the application of Technical

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-6 Specifications. One of those issues was missed Surveillances. The Generic Letter states, "The second problem involves unnecessary shutdowns caused by Specification 4.0.3 [sic: now numbered SR 3.0.3] when surveillance intervals are inadvertently exceeded.... It is overly conservative to assume that systems or components are inoperable when a surveillance has not been performed because the vast majority of surveillances do in fact demonstrate that systems or components are OPERABLE.

TSTF-358 Proposed Change:... The risk evaluation can be qualitative for a missed Surveillance for a component that is either not modeled in the plant's PSA or has been shown to be of low importance in the plant's IPE, PSA, and / or Maintenance Rule results.

TSTF-358 Justification:... Overall, due to the avoidance of unnecessary shutdowns, the low number of potentially risk-significant Surveillances, and the requirements for a risk evaluation if a Surveillance is extended, the change is considered a risk reduction to risk neutral. Additionally, the change represents a burden reduction for both the plant and the NRC.

Reasonable Expectation The Surveillance Will Be Met When Performed VES passed the initial VFTP performance with significant margin (see results below).

VES has operated satisfactorily for TS SR 3.7.6.3 monthly required testing.

The prior VFTP penetration and leakage testing (required by TS 5.5.13.a.1 and 5.5.13.a.2, respectively) results are as follows:

Date Test Result Limit 11/11/2021 HEPA

< 0.01%

< 0.05%

11/11/2021 Charcoal Adsorber 0.018%

< 0.05%

The prior testing of VES to measure the pressure drop across the combined HEPA filter, the charcoal adsorber, and the post filter, results are as follows:

Date Test Result Limit 11/11/2021 Delta P 1.2035 in water gauge 5 in. water gauge The TS 5.5.13.a.3 test of test of a sample of the charcoal adsorber for methyl iodide penetration was performed more recently (and is not the subject of the LAR request for deferral), and its results are shown below:

Date Test Result Limit 7/20/2022 Penetration 1.077% +/- 0.012 5%

7/20/2022 Efficiency 98.923% +/- 0.012 95%

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-7 The prior testing margin, satisfactory monthly runs, and the lack of activities that could have affected the filtration train status provides the reasonable expectation that the tests will be met when performed.

Risk Evaluation The VEGP Unit 3 Probabilistic Risk Assessment (PRA) models provide for quantitative assessment of at-power internal events, internal floods, internal fires, and seismic events.

The Vogtle 3 PRA models include credit for the VES function to provide passive control room cooling to support main control room operator actions and operation of temperature-sensitive equipment. The VES function to provide air filtration for the main control room is not modeled because it is not a necessary function to prevent or mitigate core damage.

As a result, there is no quantifiable Core Damage Frequency (CDF) or Large Early Release Frequency (LERF) change associated with deferring performance of the testing required by SR 3.7.6.10 and TS 5.5.13.a to the first refueling outage.

The VEGP Maintenance Rule non-PRA Safety Significance Classification for the VES functions concluded that VES classification is Low Safety Significant.

As discussed in the NRC Enforcement Manual, Appendix F, Notices of Enforcement Discretion (December 26, 2023 [ADAMS Accession No. ML23362A014]), Section 1.4,

Background:

The NRC has historically recognized that the two safest modes for operating a nuclear power plant are either Mode 5 (shut down) or Mode 1 (operating at power).

Transitions between these two modes may introduce situations or configurations that involve an increase in risk..

SNC is currently considering three possible scenarios for the upcoming VFTP testing:

1) the system is removed from service during full power operation, the test is performed and restored to service within the TS allowed outage time of six hours; 2) the system is removed from service during full power operation, the test is performed and cannot be restored to service within the TS allowed outage time of six hours and the unit is subsequently shutdown until operability can be established; and 3) the system is not removed from service during full power operation, the test is deferred until it can be performed during a shutdown when the system is not required to be operable.

SNC believes the least plant safety risk is provided with the third scenario of deferral of the testing until the first refueling outage.

First Reasonable Opportunity Considering that inoperability of the single-train ESF filtration train is a loss of an assumed safety function, the most appropriate time for performing tests on the filtration train is when it is not required to be operable. This is in Mode 5 or 6, or defueled, and not moving irradiated fuel. The next opportunity when VEGP Unit 3 is expected to be in these conditions is the first refueling outage. As such, SNC proposes to defer the required periodic VFTP testing to this outage where VES operability is not required. This reflects a more appropriate time to perform periodic testing on the single train ESF filtration train.

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-8 It is also noted that performance of these tests requires specially trained and qualified personnel. VEGP Unit 3 currently does not employ such personnel and schedules qualified contract services to perform these tests. These contract services require advanced planning for availability, and as such, would likely not be available on short notice should an unplanned outage occur.

Conclusion The proposed changes provide appropriate consideration of increased risk to plant safety of attempting to perform this test at power. These changes continue to provide the appropriate assurance of the required of protection for the MCR plant operations staff in meeting General Design Criterion 19. Therefore, there is reasonable assurance that the health and safety of the public, and the MCR staff, will not be endangered by operation in the proposed manner.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements General Design Criterion 19, Control room, of 10 CFR Part 50, Appendix A, requires A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents. Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions... to ensure that radiation exposures shall not exceed 0.05 Sv (5 rem) total effective dose equivalent (TEDE) as defined in § 50.2 for the duration of the accident.

No design changes are proposed, and the system is believed to be fully capable of meeting operability requirements. Thus, the approved control room design and capabilities are not impacted and GDC 19 continues to be met.

10 CFR 50.34(f)(2)(xxviii), requires the applicant to Evaluate potential pathways for radioactivity and radiation that may lead to control room habitability problems under accident conditions resulting in an accident source term release, and make necessary design provisions to preclude such problems.

No design changes are proposed, and the system is believed to be fully capable of meeting operability requirements. Thus, the approved control room design and capabilities are not impacted and the required evaluation and design provisions continue to be met.

4.2 Precedent None.

4.3 Significant Hazards Consideration Southern Nuclear Operating Company (SNC) is requesting an amendment to the Technical Specifications (TS) for Vogtle Electric Generating Plant (VEGP) Unit 3 by

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-9 revising the Combined License (COL) Appendix A Technical Specification (TS) 5.5.13, Ventilation Filter Testing Program (VFTP), to provide an exception to the 24-month testing frequency. The exception proposes to defer the next required performance until prior to startup from the first refueling outage. This exception would apply to inplace penetration and system bypass testing of the high efficiency particulate air (HEPA) filter, inplace penetration and system bypass testing of the charcoal adsorber, and pressure drop testing across the HEPA filter, the charcoal adsorber, and the post filter, as specified in TS 5.5.13.a.1, 5.5.13.a.2, and 5.5.13.a.4, respectively.

SNC has evaluated the proposed changes to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed changes do not involve a significant hazards consideration, as discussed below.

1.

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

Response: No The proposed change relaxes the time allowed to perform a Surveillance. The time between Surveillances is not an initiator to any accident previously evaluated.

Consequently, the probability of an accident previously evaluated is not significantly increased. The equipment being tested is still required to be operable and capable of performing the accident mitigation function assumed in the accident analysis. As a result, the consequences of any accident previously evaluated are not significantly affected.

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

2.

Does the proposed change create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or a change in the methods governing normal plant operation.

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

3.

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

Response: No The relaxed time allowed to perform a Surveillance does not result in a significant reduction in the margin of safety. As supported by the historical data, the likely outcome of any Surveillance is verification that the requirement is met. Failure to perform a Surveillance within the currently prescribed Frequency does not cause equipment to become inoperable. The only effect of the additional time allowed to perform the Surveillance on the margin of safety is the extension of the time until inoperable

Enclosure to NL-24-0128 Evaluation of Proposed Changes E-10 equipment is discovered to be inoperable by the missed Surveillance. Balancing the rare occurrence of an undiscovered inoperability against the actual risk of manipulating the plant equipment to perform the Surveillance, leads to a conclusion of enhanced plant safety margins. In addition, the diesel-backed normal ventilation system can perform the safety function of the filtration train should there be an undiscovered inoperability. Thus, there is confidence that plant safety margins are maintained.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based upon the reasoning presented above, SNC concludes that the requested change involves no significant hazards consideration, as set forth in 10 CFR 50.92(c), Issuance of Amendment.

4.4 Conclusions In conclusion, based on 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 the health and safety of the public.

5.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement.

However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion 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.

Technical Specification Marked-up Pages NL-24-0128 ATTACHMENT 1 Technical Specification Marked-up Pages Insertions Denoted by underlined Blue text (This attachment consists of 2 pages, including this cover page.)

Technical Specifications Programs and Manuals 5.5 VEGP Units 3 and 4 5.5 - 12 Amendment No.___183 (Unit 3)

Amendment No.___181 (Unit 4) 5.5 Programs and Manuals 5.5.13 Ventilation Filter Testing Program (VFTP)

a.

A program shall be established to implement the following required testing of the VES.

Tests described in Specification 5.5.13.a.1 and 5.5.13.a.2 shall be performed: i) initially, ii) once each 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage, iii) after partial or complete replacement of a HEPA filter or charcoal adsorber, iv) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the filters, and v) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the system.

Tests described in Specification 5.5.13.a.3 shall be performed: i) after each 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation or at least once each 24 months, whichever comes first, ii) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the carbon media, and iii) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the carbon media.

Tests described in 5.5.13.a.4 shall be performed once per 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage.

1.

Demonstrate for the VES that an inplace test of the high efficiency particulate air (HEPA) filter shows a penetration and system bypass 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 3, and ASME N510-1989 at a flow rate at least 600 cfm greater than the VES makeup flow rate.

Ventilation System Flow Rate VES 600 + VES makeup flow rate (cfm)

2.

Demonstrate for the VES that an inplace test of the charcoal adsorber shows a penetration and system bypass 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 3, and ASME N510-1989 at a flow rate at least 600 cfm greater than the VES makeup flow rate.

Ventilation System Flow Rate VES 600 + VES makeup flow rate (cfm)

Revised Technical Specification Pages NL-24-0128 ATTACHMENT 2 Revised Technical Specification Pages (This attachment consists of 2 pages, including this cover page.)

Technical Specifications Programs and Manuals 5.5 VEGP Units 3 and 4 5.5 - 11 Amendment No. ___ (Unit 3)

Amendment No. ___ (Unit 4) 5.5 Programs and Manuals 5.5.13 Ventilation Filter Testing Program (VFTP)

a.

A program shall be established to implement the following required testing of the VES.

Tests described in Specification 5.5.13.a.1 and 5.5.13.a.2 shall be performed: i) initially, ii) once each 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage, iii) after partial or complete replacement of a HEPA filter or charcoal adsorber, iv) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the filters, and v) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the system.

Tests described in Specification 5.5.13.a.3 shall be performed: i) after each 720 hours0.00833 days <br />0.2 hours <br />0.00119 weeks <br />2.7396e-4 months <br /> of system operation or at least once each 24 months, whichever comes first, ii) following painting, fire, or chemical release in any ventilation zone communicating with the VES that may have an adverse effect on the functional capability of the carbon media, and iii) following detection of, or evidence of, penetration or intrusion of water or other material into any portion of the VES that may have an adverse effect on the functional capability of the carbon media.

Tests described in 5.5.13.a.4 shall be performed once per 24 months except for Unit 3 cycle 1 when testing shall be performed prior to startup from first refueling outage.

1.

Demonstrate for the VES that an inplace test of the high efficiency particulate air (HEPA) filter shows a penetration and system bypass 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 3, and ASME N510-1989 at a flow rate at least 600 cfm greater than the VES makeup flow rate.

Ventilation System Flow Rate VES 600 + VES makeup flow rate (cfm)

2.

Demonstrate for the VES that an inplace test of the charcoal adsorber shows a penetration and system bypass 0.05% when tested in accordance with Regulatory Guide 1.52, Revision 3, and ASME N510-1989 at a flow rate at least 600 cfm greater than the VES makeup flow rate.

Ventilation System Flow Rate VES 600 + VES makeup flow rate (cfm)