ML18351A195

Safety Evaluation - Vogtle Electric Generating Plant Units 3 and 4 LAR 18-017

ML18351A195
Person / Time
Site:	Vogtle
Issue date:	01/15/2019
From:	Jordan Hoellman NRC/NRO/DLSE/LB4
To:	City of Dalton, GA, Georgia Power Co, MEAG Power, Oglethorpe Power Corp, Southern Nuclear Operating Co
hoellman j/415-5481
Shared Package
ML18351A189	List: ML18351A190 ML18351A191 ML18351A192 ML18351A193 ML18351A194 ML18351A195
References
EPID L-2018-LLA-0206, LAR 18-017
Download: ML18351A195 (8)

Text

SAFETY EVALUATION BY THE OFFICE OF NEW REACTORS RELATED TO AMENDMENT NOS. 150 AND 149 TO THE COMBINED LICENSE NOS. NPF-91 AND NPF-92, RESPECTIVELY SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026

1.0 INTRODUCTION

By letter dated July 20, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18201A610), as revised by letter dated December 3, 2018 (ADAMS Accession No. ML18337A358), Southern Nuclear Operating Company, Inc. (SNC) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Combined License (COL) Nos. NPF-91 and NPF-92, respectively. The License Amendment Request (LAR)18-017 requested changes to COL Appendix A, Technical Specifications (TS).

The LAR proposed changes to revise the operability requirements for the Engineered Safety Features Actuation System (ESFAS) Spent Fuel Pool Level - Low 2 and In-Containment Refueling Water Storage Tank (IRWST) Wide Range Level - Low instrumentation functions for Refueling Cavity and Spent Fuel Pool Cooling System (SFS) Isolation. Additional changes are proposed to add TS operability requirements for the SFS containment isolation valves in MODES 5 and 6.

2.0 REGULATORY EVALUATION

The LAR proposes to change TS regarding operability requirements for two instrumentation functions for Refueling Cavity and SFS Isolation and add TS operability requirements for the

SFS containment isolation valves in MODES 5 and 6. The staff considered the following regulatory requirements in reviewing the LAR.

Title 10 of the Code of Federal Regulations (10 CFR) Part 52, Appendix D, VIII.C.6 states that after issuance of a license, Changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90. 10 CFR 50.90 addresses the application for amendment of license, construction permit, or early site permit. The proposed LAR requires changes to the TS, and therefore an LAR is required to be submitted for NRC approval.

10 CFR 50.36, Technical specifications, impose limits, operating conditions, and other requirements upon reactor facility operation for the public health and safety. The TS are derived from the analyses and evaluations in the safety analysis report. TS must contain: (1) safety limits and limiting safety system settings; (2) limiting conditions for operation; (3) surveillance requirements (SR); (4) design features; and (5) administrative controls. This regulation is applicable to the evaluation of this LAR because changes to the TS are proposed in this LAR.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 13, Instrumentation and control, requires that instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges. This regulatory requirement is applicable for the evaluation of this LAR because the proposed changes in this LAR impact the operability of the affected instrumentation functions.

10 CFR 50 Appendix A, GDC 20, Protection system functions, requires that the protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences, and (2) to sense accident conditions and to initiate the operation of systems and components important to safety. This regulatory requirement is also applicable for the review of this LAR because the proposed changes in this LAR are related to the plant safety protection functions.

3.0 TECHNICAL EVALUATION

In LAR 18-017, SNC proposed the following changes to the COL Appendix A, plant-specific TS for VEGP Units 3 and 4:

1. TS 3.3.14 is revised as follows:

a. Applicability for the Spent Fuel Pool Level - Low 2 instrumentation function is changed from MODE 6 to MODE 6 with refueling cavity and spent fuel pool volumes in communication.

b. Requirement is added for the ESFAS IRWST Wide Range Level - Low instrumentation function to be OPERABLE in MODES 1, 2, 3, and 4.

c. A new Condition C is added to provide the Required Action for when the Required Action and associated Completion Time of Condition B is not met.

d. A new TS Table 3.3.14-1 is added, referencing the table in the limiting condition for operation (LCO), renaming the TS and the LCO to ESFAS Refueling Cavity and SFS Isolation Instrumentation, explicitly referring to the two instrumentation function names in Conditions A and B, and adding a Note allowing for separate Condition entry for each function.

2. TS 3.5.7 SR and TS 3.5.8 SR are added to require the SFS containment isolation valves to be verified closed and only opened intermittently under administrative controls in MODE 5 and in MODE 6 with refueling cavity and spent fuel pool volumes not in communication.

3. New TS 3.7.13 is added requiring the SFS containment isolation valves to be OPERABLE in MODE 6 with refueling cavity and spent fuel pool volumes in communication to support the proposed requirements of TS 3.3.14.

4. The following editorial changes are made for clarity in response to the request for additional information (RAI), dated November 13, 2018 (ADAMS Accession No.

ML18317A093):

a. The title of TS 3.3.14 is revised to ESFAS IRWST and Spent Fuel Pool Level Instrumentation.

b. In the Required Action statements retain the s on the word paths but without the parentheses since each entry into the Condition impacts both flow paths.

c. Include penetration prior to each reference to flow path consistent with TS 3.6.3.

d. Remove SR 3.3.16.5 since it is redundant to SR 3.3.16.4.

e. The Table of Contents are revised consistent with the changes.

f. Other editorial changes are made to be consistent with the Writers Guide.

The staffs review of each proposed TS change described above is provided below.

The safety-related protection and safety monitoring system (PMS) is actuated when safety system setpoints are reached for selected plant parameters. Once the required logic combination is generated, the PMS equipment sends the signals to actuate appropriate engineered safety features components. Signals for isolating the SFS lines by closing the safety-related SFS containment isolation motor-operated valves (SFS-PL-V034, SFS-PL-V035, and SFS-PL-V038) are generated from either of the following conditions:

1. Low-2 spent fuel pool level

2. Low IRWST wide range level Condition 1 results from the coincidence of spent fuel pool level below the Low-2 setpoint in two of three divisions. In the LAR, SNC stated that Condition 1 provides protection against a loss of

refueling cavity water inventory in the event of a leak in the nonsafety-related, nonseismic SFS in MODE 6 with refueling cavity and spent fuel pool volumes in communication that could result in reduction of the combined IRWST and refueling cavity water inventory below the minimum volume requirement of TS 3.5.8.

Condition 2 results from IRWST wide range level below the Low setpoint in one of two divisions.

In the LAR, SNC stated that Condition 2 provides protection against a loss of IRWST water inventory in the event of a leak in the SFS in MODES 1, 2, 3, and 4 that could result in reduction of IRWST water inventory below the minimum volume requirements of TS 3.5.6.

Low IRWST wide range level can be manually blocked when the reactor coolant system average temperature is below the P-9 permissive setpoint and the plant is in Mode 6, to allow the SFS to transfer the IRWST inventory to the refueling cavity. In the LAR, SNC stated that when automatic isolation is blocked below P-9, manual closure capability of the SFS containment isolation valves is available to terminate draining of the IRWST to ensure the remaining combined IRWST and refueling cavity water inventory provides adequate decay heat removal in MODES 5 and 6.

The staff reviewed the proposed revisions to TS 3.3.14, ESFAS IRWST and Spent Fuel Pool Level Instrumentation, and found that the revision of the APPLICABILITY (addition of Table 3.3.14-1) and of conditions A and B, and the addition of condition C does not change the initiation logic of Condition 1: Low-2 spent fuel pool level and Condition 2: Low IRWST wide range level. Also, the staff reviewed the proposed addition of TS 3.7.13, SFS Containment Isolation Valves, and found that the addition of this TS does not change the initiation logic of Condition 1: Low-2 spent fuel pool level and Condition 2: Low IRWST wide range level. The proposed changes do not make any physical modifications to any structure, system, or component (SSC), and do not impact the design of the PMS and continues to support the ability of the PMS to monitor for spent fuel pool level and IRWST level below their respective setpoints and to isolate the SFS lines. Therefore, the staff finds that the proposed changes comply with the requirements of GDC 13 and 20.

The staff reviewed the proposed addition of TS SR 3.5.7.1 and SR 3.5.8.3 and found that the addition of these TS SRs does not change the initiation logic of the SFS isolation block control.

The proposed changes do not make any physical modifications to any SSC, and do not impact the design of the PMS and continues to support the ability of the PMS to monitor the reactor coolant system average temperature in relation to the P-9 permissive setpoint and to isolate the SFS lines. Therefore, the staff finds that the proposed changes comply with the requirements of GDC 13 and 20.

The existing safety analysis remains applicable because the proposed changes to the plant-specific TS require explicit requirements for the operability of the affected instrumentation functions and SFS containment isolation valves, and appropriate actions when the affected instrumentation functions and SFS containment isolation valves are inoperable, thereby maintaining the initial conditions and operating limits required by the accident analysis, and the analyses of normal operation and anticipated operational occurrences, so that the safety functions of the affected SSCs are met. The proposed changes do not involve physical modifications or addition of SSCs, and do not change the operating ranges or setpoints of the affected instrumentation functions. Based on the evaluation above, the staff concludes the proposed TS changes in LAR 18-017 are acceptable, continue to comply with GDCs 13 and 20, and do not change the safety analysis presented in the VEGP Units 3 and 4 Updated Final

Safety Analysis Report. In addition, the proposed TS Bases changes are consistent with the TS changes.

Based on these findings, the staff concludes that there is reasonable assurance that the requirements of GDC 13, GDC 20, and 10 CFR 50.36 will continue to be met. Therefore, the staff finds the proposed changes acceptable.

4.0 STATE CONSULTATION

In accordance with the Commission's regulations in 10 CFR 50.91(b)(2), on December 17, 2018, the Georgia State official was consulted. The State official had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, Standards for Protection Against Radiation. The staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite. Also, there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (83 FR 45986, dated September 11, 2018). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Under 10 CFR 51.22(b), no environmental impact statement or environmental assessment needs to be prepared in connection with the issuance of the amendment.

6.0 CONCLUSION

The staff has concluded, based on the considerations discussed in Section 3.0 that there is reasonable assurance that: (1) the health and safety of the public will not be endangered by operation in the proposed manner; (2) there is reasonable assurance that 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 to the health and safety of the public. Therefore, the staff finds the changes proposed in this license amendment to be acceptable.

7.0 REFERENCES

1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4, Request for License Amendment: Technical Specification Changes for Spent Fuel Pool Level - Low 2 and In-Containment Refueling Water Storage Tank (IRWST) Wide Range Level - Low Operability (LAR-18-017), dated July 20, 2018 (ADAMS Accession No.

ML18201A610).

2. Request for Additional Information (RAI) Transmittal for Vogtle Units 3 and 4 LAR 18-017, dated November 13, 2018 (ADAMS Accession No. ML18317A093).

3. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4, Revised Request for License Amendment: Technical Specification Changes for Spent Fuel Pool Level - Low 2 and In-Containment Refueling Water Storage Tank (IRWST) Wide Range Level - Low Operability (LAR-18-017R1), dated December 3, 2018 (ADAMS Accession No. ML18337A358).

4. Vogtle Units 3 and 4 Updated Final Safety Analysis Report, Tier 1, Technical Requirements Manual and Technical Specifications Bases Annual Submittal, dated June 15, 2018 (ADAMS Accession No. ML18179A227).

5. AP1000 Design Control Document, Revision 19, dated June 13, 2011 (ADAMS Accession No. ML11171A500).

6. Combined License NPF-91 for Vogtle Electric Generating Plant Unit 3, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A106).

7. Combined License NPF-92 for Vogtle Electric Generating Plant Unit 4, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A135).