NL-24-0231, License Amendment Request: Technical Specification Revised Entry Condition
| ML25090A305 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 03/31/2025 |
| From: | Coleman J Southern Nuclear Operating Co |
| To: | Office of Nuclear Reactor Regulation, Document Control Desk |
| References | |
| NL-24-0231 | |
| Download: ML25090A305 (1) | |
Text
A Southern Nuclear March 31, 2025 Docket Nos.: 52-025 52-026 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Regulatory Affairs Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 3535 Colonnade Parkway Birmingham, AL 35243 Tel. 205.992.5000 NL-24-0231 10 CFR 50.90 License Amendment Request: Technical Specification Revised Entry Condition Ladies and Gentlemen:
Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests an amendment to the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Unit 3 (License No. NPF-91) and 4 (License No. NPF-92).
The license amendment request (LAR) proposes a change to the COLs Appendix A, Technical Specifications (TS) to provide additional, appropriate entry conditions for TS 3.8.2, DC Sources
- Shutdown.
The Enclosure provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed change. provides markups of the existing TS to show the proposed change. Attachment 2 provides the clean revised TS pages with the proposed change. Attachment 3 provides a markup of the existing TS Bases language to show an associated change for information only.
SNC requests approval of the proposed license amendment request no later than twelve months from acceptance. SNC expects to implement the proposed amendment within 30 days of issuance.
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 of Georgia official.
U. S. Nuclear Regulatory Commission NL-24-0231 Page 2 If you have any questions, please contact Mr. Ryan Joyce at (205) 992-6468.
I declare under penalty of perjury that the foregoing is true and correct.
Executed on the 31 st day of March 2025.
Respectfully submitted, Jamie M. Coleman Regulatory Affairs Director Enclosure Evaluation of Proposed Change cc:
NRC Regional Administrator, Region II NRR Project Manager - Vogtle 3&4 Senior Resident Inspector - Vogtle 3&4 Director, Environmental Protection Division - State of Georgia Document Services RTYPE: VND.LI.L00
ENCLOSURE to NL-24-0231 Evaluation of Proposed Change License Amendment Request:
Technical Specification Revised Entry Condition
- 1.
SUMMARY
DESCRIPTION
- 2.
DETAILED DESCRIPTION 2.1. System Design and Operation 2.2. Current Requirements 2.3. Description of, and Reason for, the Proposed Change
- 3.
TECHNICAL EVALUATION
- 4.
REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria 4.2. Precedent 4.3. Significant Hazards Consideration 4.4. Conclusions
- 5.
ENVIRONMENTAL CONSIDERATION Attachments 1. Proposed Technical Specification Change (Mark-ups)
- 2. Clean Revised Technical Specification Pages
- 3. Associated Technical Specification Bases Change (for information only)
Enclosure to NL-24-0231 Evaluation of Proposed Change 1.0
SUMMARY
DESCRIPTION In accordance with 10 CFR 50.90, "Application for amendment of license, construction permit, or early site permit," Southern Nuclear Operating Company (SNC) is requesting an amendment to the Technical Specifications (TS) for the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4. This request is to revise the COLs Appendix A TS to provide additional, appropriate entry conditions for TS 3.8.2, DC Sources - Shutdown.
2.0 DETAILED DESCRIPTION 2.1 System Design and Operation Each unit's COL incorporates by reference an Appendix A, which identifies TS requirements applicable to the plant as required by 10 CFR 50.36. The VEGP TS are generally written following the guidance of TSTF-GG-05-01, Revision 1, for format and content. In addition, VEGP considers for applicability to VEGP changes identified for the Standard TS (STS) within travelers developed by the industry and reviewed by the NRC.
2.2 Current Requirements 10 CFR 50.36 contains requirements for what is to be included in a licensee's TS. Section 1 of the approved TS provide accepted rules for use and application of those TS, and TSTF-GG-05-01, Revision 1, provides accepted guidance for the content of conditions that are entered as a result of failing to satisfactorily complete another Required Action.
2.3 Description of, and Reason for, the Proposed Change The proposed change to the COL Appendix A would revise TS 3.8.2, DC Sources - Shutdown, to expand entry Condition B to indicate that entry into Condition A is separate from the conditions that would require entry into Condition B, and to identify that Condition B entry is required if any Condition A Required Action and associated Completion Time is not met. The current TS could be read to require entry into both Conditions A and B for some inoperabilities and the current TS does not provide for a default action if the Condition A Required Actions and associated Completion Time is not met.
3.0 TECHNICAL EVALUATION
TS 3.8.2, DC Sources - Shutdown, currently includes two TS Actions entry Conditions.
Condition A is entered when one (or more) required battery charger(s) in one division is (are) inoperable. Condition Bis entered when one (or more) required DC electrical power subsystem(s) is (are) inoperable. The Bases for Condition A state "Condition A represents one division with one or two battery chargers inoperable (e.g., the voltage limit of SR 3.8.1.1 is not maintained)." The docketed Bases for Condition B state "With one or more of the required (per LCO 3.8.6, "Distribution Systems - Shutdown") Class 1 E DC power subsystems inoperable for reasons other than Condition A.... "
E-2 of 5
Enclosure to NL-24-0231 Evaluation of Proposed Change Condition B has been recently revised to remove the phrase of "for reasons other than Condition A" which was identified as the intent in the Bases in order to match the existing TS.
The Bases phrase "for reasons other than Condition A" will be restored with approval and implementation of this request. This phrase, "for reasons other than Condition A," should be added to entry Condition B to prevent entering both Condition A and Condition B when the subsystem is inoperable due to the required battery charger being inoperable. Entering both Conditions is not appropriate or necessary since appropriate and sufficient actions for safety in the condition are required by Condition A.
It is also proposed to add a second entry Condition for Condition B of "Required Action and associated Completion Time of Condition A not met." Without this phrase, the standard default Condition for failure to meet the Required Action and associated Completion Time of Condition A would be LCO 3.0.3. However, LCO 3.0.3 identifies that it is only applicable in MODES 1, 2, 3, and 4. Thus, there is no identified default Condition. Thus, since Condition B includes the appropriate actions for the Condition; i.e., sufficiently conservative actions, Condition B is proposed to become the default condition for the Required Action and associated Completion Time of Condition A not met.
Both additions to the described conditions for entry of Condition B are consistent with the DC Sources - Shutdown STS 3.8.2 in the Westinghouse AP1000 STS NUREG-2194 Revision 1.
Further, both additions to enter Condition Bare also consistent with the similar DC Sources -
Shutdown STS 3.8.5 in the Westinghouse STS NUREG-1431 Revision 5, the Combustion Engineering STS NUREG-1432 Revision 5, the Babcock and Wilcox STS NUREG-1430 Revision 5, the General Electric BWR/4 STS NUREG-1433, and the General Electric BWR/6 STS NUREG-1434 Revision 5.
A complementary change to the TS 3.8.2 change is made to the Bases of TS 3.8.2 as shown in.
4.0 REGULATORY EVALUATION
4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36 contains requirements for what is to be included in a licensee's TS. The proposed change is consistent with, and provides clarity for implementation of, 10 CFR 50.36.
4.2 Precedent The proposed change is consistent with similar Condition C of Southern Nuclear Company Edwin I. Hatch Nuclear Plant, Units 1 and 2, Technical Specification 3.8.5, DC Sources -
Shutdown, as approved by Amendment Nos. 287 and 232, respectively, on August 29, 2017
[ML17208A231]
4.3 Significant Hazards Evaluation Southern Nuclear Operating Company (SNC) is requesting an amendment to the Technical Specifications (TS) to provide additional, appropriate entry conditions for TS 3.8.2, DC Sources
- Shutdown.
E-3 of 5
Enclosure to NL-24-0231 Evaluation of Proposed Change SNC has evaluated the proposed change to the TS using the criteria in 10 CFR 50.92 and has determined that the proposed change does 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 provides additions to the entry conditions for the Actions associated with inoperable direct current (DC) systems equipment while shutdown. The additions are consistent with previously approved entry conditions for similar Specifications and provide sufficiently conservative actions for the continued safety provided by the plant TS. The change involves no increase in the probability or consequences of an accident.
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 alter the plant configuration, require installation of new equipment, alter assumptions about previously analyzed accidents, or impact the operation or function of plant equipment or systems.
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 proposed change does not impact any safety assumptions or have the potential to reduce a margin of safety as described in the TS Bases.
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 Commission's 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.
E-4 of 5
Enclosure to NL-24-0231 Evaluation of Proposed Change
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to the format of the license or otherwise makes editorial, corrective, or other minor changes. Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(1 0)(v). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed change.
E-5 of 5
ATTACHMENT 1 to NL-24-0231 Proposed Technical Specification Change (Mark-ups)
License Amendment Request:
Technical Specification Revised Entry Condition (This enclosure consists of 2 pages, including this cover page)
ACTIONS (continued)
CONDITION B. One or more required DC electrical power subsystems inoperable for reasons other than Condition A.
OR Required Action and associated Completion Time of Condition A not met.
VEGP Units 3 and 4 Technical Specifications REQUIRED ACTION B.1 Declare affected required features inoperable.
OR B.2.1 Suspend movement of irradiated fuel assemblies.
AND B.2.2 Suspend operations with a potential for draining the reactor vessel.
AND B.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SOM or boron concentration.
AND B.2.4 Initiate action to restore required DC electrical power subsystems to OPERABLE status.
DC Sources - Shutdown 3.8.2 COMPLETION TIME Immediately Immediately Immediately Immediately Immediately 3.8.2 - 2 Amendment No. '1#1-~
(Unit 3)
Amendment No. '1#1-~
(Unit 4)
ATTACHMENT 2 to NL-24-0231 Clean Revised Technical Specification Pages License Amendment Request:
Technical Specification Revised Entry Condition (This enclosure consists of 2 pages, including this cover page)
ACTIONS (continued)
CONDITION B. One or more required DC electrical power subsystems inoperable for reasons other than Condition A.
OR Required Action and associated Completion Time of Condition A not met.
VEGP Units 3 and 4 Technical Specifications DC Sources - Shutdown 3.8.2 REQUIRED ACTION COMPLETION TIME B.1 Declare affected required features inoperable.
OR B.2.1 Suspend movement of irradiated fuel assemblies.
AND Immediately Immediately B.2.2 Suspend operations with Immediately a potential for draining the reactor vessel.
AND B.2.3 Suspend operations involving positive reactivity additions that could result in loss of required SOM or boron concentration.
AND B.2.4 Initiate action to restore required DC electrical power subsystems to OPERABLE status.
Immediately Immediately 3.8.2 - 2 Amendment No.
Amendment No.
(Unit 3)
(Unit 4)
ATTACHMENT 3 to NL-24-0231 Associated Technical Specification Bases Change
{for information only)
License Amendment Request:
Technical Specification Revised Entry Condition (This enclosure consists of 2 pages, including this cover page) to NL-24-0231 Associated Technical Specifications Bases Change (for information only)
In association with the change to TS 3.8.2, DC Sources - Shutdown, the Bases for Condition B are revised as shown below (Bases page B 3.8.2 - 4 ).
B.1, B.2.1, B.2.2, B.2.3, and B.2.4 With one or more of the required (per LCO 3.8.6, "Distribution Systems -
Shutdown") Class 1 E DC power subsystems inoperable for reasons other than Condition A or if the Required Actions and associated Completion Times of Condition A are not met, the remaining subsystems may be capable of supporting sufficient systems to allow continuation of fuel movement and/or operations with a potential for draining the reactor vessel. By allowing the option to declare required features inoperable with the associated DC power source(s) inoperable, appropriate restrictions will be implemented in accordance with the affected required features LCO....