ND-19-0162, Request for License Amendment and Exemption: Consolidation of Structural Building ITAAC (LAR-19-005)

Request for License Amendment and Exemption: Consolidation of Structural Building ITAAC (LAR-19-005)

ML19088A274
Person / Time
Site:	Vogtle
Issue date:	03/29/2019
From:	Yox M Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
ND-19-0162
Download: ML19088A274 (37)

Text

Michael J. Yox Southern Nuclear Regulatory Affairs Director 7825 River Road Waynesboro, GA 30830 Vogtle 3 & 4 706-848-6459 March 29, 2019 Docket Nos.: 52-025 ND-19-0162 52-026 10CFR 50.90 10CFR 52.63 U.S. Nuclear Regulatory Commission Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment and Exemption:

Consolidation of Structural Building ITAAC (LAR-19-005)

Ladles and Gentlemen:

Pursuant to 10 CFR 52.98(c) and In accordance with 10 CFR 50.90, Southern Nuclear Operating Company(SNC), the licensee for Vogtle Electric Generating Plant(VEGP) Units 3 and 4, requests an amendment to Combined License Numbers NPF-91 and NPF-92, for VEGP Units 3 and 4, respectively. The requested amendment Includes changes to the VEGP Unit 3 and Unit 4 COL Appendix C (and corresponding plant-specific DCD Tier 1) Information. Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design as certified In the 10 CFR Part 52, Appendix D, design certification rule Is also requested for the plant-specific Tier 1 material departures.

This License Amendment Request (LAR) proposes the consolidation of certain building and structure related Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC). Specifically, SNC has determined that some building and structure related ITAAC Acceptance Criteria are dupllcatlve. To correct this condition, SNC proposes to revise COL Appendix C (and plant-specific Tier 1 Information) to consolidate dupllcatlve ITAAC Acceptance Criteria for certain structures and clarify that evaluations of thickness deviations will be Included In the reconciliation and thickness reports described In ITAAC Acceptance Criteria. provides the description, technical evaluation, regulatory evaluation (Including the Significant Hazards Consideration Determination), and environmental considerations for the proposed changes. provides the background and supporting basis for the requested exemption.

U.S. Nuclear Regulatory Commission ND-19-0162 Page 2 of 4 Enclosure 3 provides the proposed changes to the VEGP Unit 3 and Unit 4 licensing basis documents.

The Enclosures to this letter have been reviewed and confirmed to not contain security-related information. This letter contains no regulatory commitments.

SNC requests staff approval of this license amendment by September 30,2019to support closure of VEGP Units 3 and 4 ITAAC. Approval by this date will allow sufficient time to implement the licensing basis changes prior to the associated ITAAC activity. SNC expects to implement this proposed amendment(through incorporation into the licensing basis documents) within 30 days of approval of the requested changes.

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

Should you have any questions, please contact Mr. Steve Leighty at(706)848-6790.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 29"'day of March 2019.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Michael J. Vox Regulatory Affairs Director Vogtle 3& 4 MJY/RAS/sfr

Enclosures:

1) Vogtle Electric Generating Plant(VEGP) Units 3and 4- Request for License Amendment: Consolidation of Structural Building ITAAC(LAR-19-005)

2) Vogtle Electric Generating Plant(VEGP) Units 3and 4 - Exemption Request: Consolidation of Structural Building ITAAC (LAR-19-005)

3) Vogtle Electric Generating Plant(VEGP) Units 3and 4 - Proposed Changes to the Licensing Basis Documents(LAR-19-005)

U.S. Nuclear Regulatory Commission ND-19-0162 Page 3 of 4 go:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)

Mr. D. G. Bost(w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. D. H. Jones (w/o enclosures)

Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)

Mr. T. W. Yelverton (w/o enclosures)

Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Vox Mr. C. T. Defnall Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Mr. S. Leighty Mr. E. Riffle Ms. K. Roberts Mr. J. Haswell Mr. J. Andrews Document Services RTYPE: VND.LI.LOO File AR.01.02.06 Nuclear Reaulatorv Commission Mr. W. Jones(w/o enclosures)

Ms. J. Dixon-Herrity Mr. C. Patel Mr. B. Kemker Ms. N. Coovert Mr. P. Heher Mr. N. Karlovich Ms. K. Carrington 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 Qglethorpe Power Corporation Mr. M. W. Price

U.S. Nuclear Regulatory Commission ND-19-0162 Page 4 of 4 Municioal Electric Authority of Georoia Mr. J. E. Fuller Mr. 8. M. Jackson Dalton Utilities Mr. T. Bundros Westinohouse Electric Company. LLC Mr. L. Oriani (w/o enclosures)

T. Rubenstein (w/o enclosures)

Mr. M. Corletti Mr. M. L. Clyde Mr. D. Hawkins Mr. J. Coward Other Mr. 8. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NU8, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. 8. Roetger, Georgia Public Service Commission Ms. 8. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. 8. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. 8. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-19-0162 Enclosure 1 Vogtle Electric Generating Plant(VEGP)Units 3 and 4 Request for License Amendment:

Consolidation of Structural Building ITAAC (LAR-19-005)

(Enclosure 1 consists of 16 pages, including this cover page.)

ND-19-0162 Request for License Amendment: Consolidation of Structural Building ITAAC (LAR-19-005)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION

3. TECHNICAL EVALUATION (included in Section 2)

4. REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria 4.2. Precedent 4.3. Significant Hazards Consideration Determination 4.4. Conclusions

5. ENVIRONMENTAL CONSIDERATIONS

6. REFERENCES Page 2 of 16

ND-19-0162 Request for License Amendment Consolidation of Structural Building ITAAC(LAR-19-005)

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company(SNC, or "Licensee") hereby requests an amendment to Combined License(COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant(VEGP)

Units 3 and 4, respectively.

1.

SUMMARY

DESCRIPTION The requested amendment proposes changes to COL Appendix C information, with corresponding changes to plant-specific DCD Tier 1 information, as appropriate. The proposed changes include consolidating Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) for structural buildings and revising Acceptance Criteria to reflect evaluations of as-built deviations in wall and floor thicknesses will be provided as part of the reports described in ITAAC. This enclosure requests approval of a license amendment necessary to implement the COL Appendix C changes described below. Enclosure 2 requests the exemption necessary to implement the changes to the plant-specific DCD Tier 1 information.

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION Detailed Description COL Appendix C, Section 3.3 provides design descriptions for API000 structural buildings. The buildings described in Section 3.3 include Nuclear Island (Nl) structures as well as, the annex, turbine, and radwaste buildings. The Nl includes containment internal structures, and the shield and auxiliary buildings. The Nl structures are seismic Category I and are designed and constructed to withstand design basis loads without a loss of structural integrity and safety-related functions. The walls and floors of Nl buildings are defined in COL Appendix C Table 3.3-1. COL Appendix C Section 3.3 does not provide the structural design functions for the annex, turbine, or radwaste buildings.

However, wall and floor thicknesses for the annex building and wall thicknesses for the turbine building are defined in COL Appendix C Table 3.3-1, and wall thicknesses for the radwaste building are defined in ITAAC Index Number 782.

There are sixteen ITAAC for structural buildings. These ITAAC have two purposes, one is for verifying structural function and the other is for verifying radiation shielding function.

The ability of as-built structures to perform their structural functions is demonstrated through reconciliation reports and thickness reports. The ability of the as-built structures to perform their shielding function is demonstrated through thickness reports. The structural building ITAAC are summarized in the following Table, "Structural Building ITAAC."

It has been identified that some of the Acceptance Criteria for the building structures are duplicative. COL Appendix C (and plant-specific Tier 1) changes are proposed to consolidate ITAAC with duplicative Acceptance Criteria for building structures and clarify that evaluations of thickness deviations will be included in the reconciliation and thickness reports described in ITAAC Acceptance Criteria. The Table illustrates the duplication of building-related reports.

Page 3 of 16

ND-19-0162 Enclosure 1 Request for License Amendment: Consolidation of Structural Building ITAAC (LAR-19-005)

Table: Structural Building ITAAC Structural Function Shielding Function (ITAAC Index No.) (ITAAC Index No.)

ITAAC No. ITAAC No.

Building / Structure Reconciliation Thickness Thickness Report Report Report Containment (760) (764) (777)

Internal Structure 3.3.00.02a.i.a 3.3.00.02a.ii.a 3.3.00.03a (761) (765) (778)

Shield Building 3.3.00.02a.i.b 3.3.00.02a.ii.b 3.3.00.03b Nuciear Isiand (Nl)

Auxiliary Building (762) (766) (779)

[Non-Radiological] 3.3.00.02a.i.c 3.3.00.02a.ii.c 3.3.00.03c Auxiliary Buiiding (763) (767) (780)

[Radiological] 3.3.00.02a.i.d 3.3.00.02a.ii.d 3.3.00.03d (768) (781)

Annex Buiiding -

3.3.00.02a.ii.e 3.3.00.04a (769)

Turbine Buiiding - -

3.3.00.02a.ii.f Radwaste Bidg.

(782) 3.3.00.04b Waste Accumulation Room Proposed Chanoes to Nuclear Island Structural Function ITAAC As Illustrated in the Table above,there are three ITAAC^ for each of the Nl buildings (i.e.,

containment internal structures, shield building, auxiliary building non-radiological, and auxiliary building radiological). The structural function Design Commitment for the Nl building ITAAC is to withstand design basis loads without loss of structural integrity or safety related functions. The corresponding Acceptance Criteria are to produce reconciliation reports (ITAAC Index Numbers 760/761/762/763) and a structural thickness report(ITAAC Index Numbers 764/765/766/767) for each Nl building to verify that the as-built structures meet the Design Commitment. The Nl also has Design Commitments to provide shielding during normal operations. The corresponding IT/^C

^ Hereafter, ITAAC Index numbers are used for identification In lieu of ttie ITAAC number.

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ND-19-0162 Request for License Amendment: Consolidation of Structural Building ITAAC(LAR-19-005)

Acceptance Criteria require shielding thickness reports (ITAAC Index Numbers 777/778/779/780) be produced for each Nl building which demonstrates that the as-built structures meet the Design Commitment.

The Nl as-built reconciliation reports reconcile design changes and site-specific non-conformances between as-built and as-designed structures. Since both the reconciliation reports and thickness reports will reconcile identified wall thickness deviations, the Acceptance Criteria for the thickness reports is duplicative and can be deleted.

Accordingly, thickness reports associated with ITAAC Index Numbers 764, 765, 766, 767,777, 778,779 and 780 can be consolidated into the reconciliation reports for ITAAC Index Numbers 760, 761, 762, 763 for the Nl buildings. Similarly, the shielding Design Commitment of Nl building structures is combined with the structural Design Commitment, and the reconciliation report justifies deviations from both structural and shielding perspectives.

A note is proposed to be added to COL Appendix C Table 3.3-1 to clarify that construction thickness deviations in Nl structures, from those thicknesses specified in the table, are reconciled in the reconciliation reports in accordance with the ITAAC requirements.

Proposed Changes to Nuciear Island Shielding Function ITAAC To address duplicative shielding function Acceptance Criteria, it is proposed that ITAAC Index Numbers 760,761,762,763 in COL Appendix C Table 3.3-6 be revised to add the shielding requirements currently specified in the thickness report Design Commitment of iTAAC Index Numbers 777, 778, 779 and 780, respectively. Specifically, ITAAC Index Numbers 760, 761, 762, 763 would be revised to require analysis of radiation shielding in the Inspections, Tests and Analyses, and to require the verification of the shielding function in the associated Acceptance Criteria reconciliation report.

To ensure the consolidated reconciliation reports comply with COL Appendix C Table 3.3-1, the consolidated reconciliation report Acceptance Criteria will be revised to clarify that Nl structural deviations from the thicknesses described in COL Appendix C Table 3.3-1 will be resolved in the reconciliation reports in accordance with the ITAAC requirements.

Proposed Changes to the Annex Building and Turbine Buildinc ITAAC There are two ITAAC for the annex building structure. The first, ITAAC Index Number 768, requires a thickness report to demonstrate the structural function and the second, ITAAC Index Number 781, requires a thickness report to verify the shielding function.

Similarly, the turbine building structure has ITAAC Index Number 769 which requires a thickness report to verify the structural function. The information provided in the annex building thickness report required by ITAAC Index Number 781 is duplicative with the information in the thickness report required by iTAAC Index Number 768. Therefore, ITAAC Index Number 781 can be consolidated into ITAAC Index Number 768.

The Acceptance Criteria in ITAAC Index Numbers 768 and 769 are to produce thickness reports to demonstrate that the walls and, as applicable, floors in the annex and turbine Page 5 of 16

ND-19-0162 Request for License Amendment Consolidafion of StnictUFal Building ITAAC(LAR-19-005) buildings are consistent with the thicknesses specified In Table 3.3-1. Annex and turbine building construction thickness deviations are evaluated and dispositioned in accordance with 10 CFR 50 Appendix B processes (i.e., Nonconformance & Disposition Reports (N&D Reports)), which ensure there are no unacceptable impacts to the annex and turbine structural functions or the annex building shielding function. The inclusion of the thickness deviation evaluations in the thickness reports for the annex and turbine buildings continues to meet the design purposes of the ITAAC.

Therefore, ITAAC Index numbers 768 and 769 Acceptance Criteria can be clarified such that the thickness reports of the annex and turbine buildings also include evaluations of thickness deviations identified during construction and demonstrate there is no loss of the annex building structural and shielding functions or turbine building structural function.

Notes will be added to Table 3.3-1 to clarify that annex and turbine building construction thickness deviations are evaluated in the thickness report in accordance with the ITAAC requirements. The proposed amendment will modify ITAAC Index number 768 for the annex building in Table 3.3-6 of COL Appendix C to add the shielding requirements to the "Design Commitment."

Proposed Chances to the Radwaste Building ITAAC There is one ITAAC associated with the waste accumulation room in the radwaste building. The associated Design Commitment for the ITAAC specifies that the walls of the waste accumulation room provide shielding during normal operations. The corresponding Acceptance Criteria specifies that a report is produced that demonstrates that the shield walls of the waste accumulation room in the radwaste building are consistent with the concrete wall thickness specified in ITAAC Index Number 782.

Waste accumulation room wall and floor thicknesses that deviate from the values specified in COL Appendix C (and plant-specific Tier 1) Table 3.3-6 are evaluated and dispositioned in N&D Reports. This process demonstrates that there is no impact to the shielding function or corrective actions are taken to restore compliance. Therefore, the waste accumulation room thickness deviation evaluations demonstrate the as-built structure continues to meet the Design Commitment of ITAAC Index Number 782. It is proposed that ITAAC Index Number 782 Acceptance Criteria be clarified to specify that the waste accumulation room thickness report includes evaluations of thickness deviations identified during construction and demonstrates there is no loss of the shielding function.

It is also proposed to delete the adjective "minimum" which modifies "concrete wall thickness" from the Acceptance Criteria of ITAAC Index Number 782 to clarify that the revised Acceptance Criteria allow deviations in wall thicknesses.

Page 6 of 16

ND-19-0162 Request for License Amendment: Consotidation of Structural Building ITAAC {LAR-19-0(K)

Technical Evaluation Changes to Structural Building ITAAC The processes outlined in 10 CFR 52 Appendix D Section VIII, as supplemented by License Condition 2.D(13), and 10 CFR 50 Appendix B will continue to be followed.

10 CFR 52 Aopendix D Section VIII Processes The proposed changes do not involve changes to the design of the plant. The proposed changes do not affect any of the design functions of the structural buildings as described in the UFSAR. Deviations that could potentially affect the design functions of structural buildings or alter compliance with applicable design codes or licensing basis requirements continue to be evaluated and dispositioned under the 10 CFR 52 Appendix D Section VIII process, as supplemented by License Condition 2.D(13).

The proposed amendment does not change the requirement for Nl structures to comply with applicable concrete and structural codes as defined in the licensing basis.

Specifically, the proposed changes do not alter the requirement that seismic Category I and II structures comply with applicable design codes, including ACI 349-01 and ANSI/AISC N690-94. In addition, supplemental requirements described in UFSAR Subsection 3.8.4.4.1, "Seismic Category I Structures," UFSAR Subsection 3.8.4.5, "Structural Criteria," and the guidance contained in NRC Regulatory Guides 1.69,1.115, 1.142, and 1.143 as discussed in UFSAR Appendix 1A,"Conformance with Regulatory Guides," continue to be met.

Chance Control Process During construction and quality control inspection, deviations from the design are identified and documented in N&D Reports. The N&D procedure was developed and is maintained in accordance with 10 CFR 50 Appendix B. Each nonconformance is individually reviewed and given a disposition by site design engineering. The N&D process requires interdisciplinary reviewers to determine the level of the impact and provide justification for deviations. For example, if a section of wall is identified as being thinner than the Acceptance Criteria, the cognizant design engineering group is involved to determine if structural or radiation shielding functionality is impacted.The N&D process identifies the design document(s) that the deviation potentially affects and when completed the record is archived.

The possible dispositions in N&D Reports are: "meets requirements," "rework," "use-as-is," "repair," "return to vendor" or "scrap." Use-as-is and repair dispositions represent a deviation to the specified design requirements. This type of disposition is subject to the same design control measures as applied to the original design and are reviewed and approved by the organization that performed the original design. The design control measures are established in accordance with requirements in 10 CFR 50 Appendix B Criterion III. Repaired and reworked items are re-verified in accordance with original criteria or as specified in the disposition.

Page 7 of 16

ND-19-0162 Request for License Amendment Consolidation of Structural Building ITAAC (LAR-19-005)

Technical justification is required for use-as-is and repair dispositions that include sufficient information to justify the adequacy of the nonconforming item for its intended use. The justification assures that the structural design continues to meet the AP1000 plant design criteria documents and hence assures the structural design continues to satisfy the design criteria of UFSAR Section 3.8. The N&D process evaluates the impact of the deviations on the existing calculations or analyses upon which the design is based and identifies the impacted documents. The N&D Reports are archived as plant records and are associated (linked) with the impacted documents so that future review of an impacted document includes a review of the N&D Report to allow for systematic reconciliation.

Changes to Nuclear Island ITAAC The proposed changes revise ITAAC in COL Appendix C to consolidate duplicative ITAAC requirements and allow reconciliation of thickness deviations from COL Appendix C Table 3.3-1 in the reconciliation reports for Nl buildings. The proposed changes do not eliminate any Design Commitment for the Nl buildings. The proposed changes do not eliminate any requirement for verifying structural and shielding functions of the Nl structural buildings. For each proposed ITAAC consolidation, the associated UFSAR design information is consistent with the current plant design, and no structure, system, or component(BSC), design function, or analysis, as described in the UFSAR, is affected by the proposed changes.

According to the Acceptance Criteria for ITAAC Index Numbers 760, 761, 762, and 763, the reconciliation reports (as-built building reports) are required for each Nl building. The as-built building reports reconcile design changes and site specific nonconformances between the as-designed and as-built building structures. The Nl construction deviations from the thicknesses and tolerances specified in COL Appendix C Table 3.3-1 are individually evaluated through the nonconformance processes and are included in the as-built building reports as part of the nonconformance reconciliation. The reconciliation reports include evaluations of the shielding function of as-built thicknesses which deviate in a negative direction. Therefore, the information in the thickness report is covered by the reconciliation report. The removal of the thickness report Acceptance Criteria for Nl does not reduce the scope or intent of the ITAAC.

Changes to Annex Building ITAAC The Acceptance Criteria of ITAAC Number 768 is to verify the structural function of the as-built annex building structure through the verification of wall thickness. Similarly, the Acceptance Criteria of ITAAC Number 781 is to verify the shielding function of the as-built annex building structure through the verification of wall thickness. The information provided in the annex building thickness report required by ITAAC Index Number 781 is duplicative with the information in the thickness report required by ITAAC Index Number 768. Therefore, it is acceptable to consolidate ITAAC Index Number 781 into ITAAC Index Number 768.

The proposed change would revise ITAAC 768 Acceptance Criteria to clarify that the annex building thickness report will include evaluations of thickness deviations identified during construction and demonstrate that as-built structures will withstand design basis Page 8 of 16

ND-19-0162 Request for License Amendment Consolidation of Structural Building ITAAC (LAR-19-005) loads without loss of structural integrity and that there is no loss of the shielding function.

The proposed change would add a note in COL Appendix C Table 3.3-1 to allow evaluation of thickness deviations in the annex building thickness report. Annex building thickness deviations are evaluated by the structural group to confirm that there is no impact to the structural function. Thickness deviations in the negative direction are also evaluated by the radiation shielding group to confirm that there is no loss of the shielding function in the annex building as-built walls and floors. The thickness reports for the annex building summarize N&D Reports related to thickness deviations which were dispositioned prior to the thickness report completion and demonstrate there is no cumulative impact on the structural or shielding functions.

The proposed changes revise COL Appendix C ITAAC to consolidate duplicative requirements and allow evaluations of thickness deviations from COL Appendix C Table 3.3-1 thickness requirements. The proposed changes do not eliminate any requirement for verifying structural or shielding functions of the annex building. The proposed changes do not alter the existing design requirements for the annex building as described in UFSAR Subsection 3.7.2.8.1.

Changes to Turbine Building ITAAC The Acceptance Criteria of ITAAC Number 769 is to verify the structural function of the as-built turbine building through the verification of wall thickness. The proposed change will revise the ITAAC Acceptance Criteria to clarify that the turbine building thickness report will include evaluations of thickness deviations identified during construction and demonstrate that the as-built structure will withstand the design basis loads without loss of structural integrity.

The amendment will add a note in COL Appendix C Table 3.3-1 to allow evaluation of thickness deviations in the turbine building thickness report. Turbine building thickness deviations are evaluated by the structural group to confirm that there is no impact to the structural function. The thickness reports for the turbine building summarize N&D Reports related to thickness deviations which were dispositioned prior to the thickness report completion and demonstrate there is no cumulative impact on the structural function.

The proposed changes revise COL Appendix C ITAAC to allow evaluations of thickness deviations from COL Appendix C Table 3.3-1 thickness requirements. The proposed changes do not eliminate any requirement for verifying the structural function of the turbine building. The proposed changes do not alter the existing design requirements for the turbine building as described in UFSAR subsection 3.7.2.8.3.

Changes to Radwaste Building ITAAC The proposed radwaste building ITAAC change clarifies that the thickness report also includes the evaluations of thickness deviations identified during construction and demonstrates there is no loss of the shielding function. The radwaste building is a non-seismic steel framed structure designed in accordance with the Uniform Building Code (UBC). The radwaste building contains facilities for the handling and storage of plant wastes. Shielding is provided as necessary for the waste storage areas in the radwaste Page 9 of 16

ND-19-0162 Request for License Amendment Consolidation of Structural Building ITAAC(LAR-19-005) building to meet the radiation zone and access requirements. As discussed in the technical justification for Nl changes, construction deviations are evaluated in accordance with N&D process which applies to thickness deviations from ITAAC Index Number 782 in the radwaste building. The thickness deviation in the positive direction does not impact the shielding function. Any thickness deviation in the negative direction is dispositioned by the cognizant engineering group to confirm that there is no loss of the shielding function in the as-built walls. The thickness report for the radwaste building summarizes N&D Reports that are related to thickness deviations in the waste accumulation room which were dispositioned prior to the thickness report and were demonstrated to have no impact on the shielding function. The proposed deletion of "minimum" in front of the wall thickness from the Acceptance Criteria is consistent with the proposed change of allowing deviation evaluations in the thickness report in ITAAC Index Number 782.

The proposed changes do not impact Design Commitments for the radwaste building, because they do not eliminate any requirement for verifying the shielding function of the radwaste building accumulation room. The proposed change does not change the current plant design, or affect SSCs, design function, or analysis, as described in the UFSAR.

Summary The proposed changes to ITAAC continue to comply with the requirements of 10 CFR Part 52 Appendix D and the COL Appendix C (and plant-specific Tier 1) design descriptions, and 10 CFR 52.99 for ITAAC closure notification and completion. These ITAAC consolidations and clarifications do not make technical changes to the COL Appendix C (and plant-specific Tier 1) design descriptions, tables, and figures. No structure, system, or component(BSC) design function or analysis as described in the UFSAR is affected. No defense-in-depth safety function is affected. There are no technical changes to plant-specific ITAAC line items.

COL Appendix C (and plant-specific Tier 1) information is comprised of the design information and functions subject to verification by the ITAAC closure process. The proposed changes do not technically affect design criteria, design functions or involve a decrease in safety provided by the associated systems. COL Appendix C (and plant specific Tier 1)ITAAC information will continue to adequately validate the corresponding UFSAR (Tier 2)design commitments.

The proposed changes do not impact an BSC,function or feature used in the prevention or mitigation of accidents or their safety or design analyses. The changes do not affect any BBC accident initiator or initiating sequence of events or involve any safety-related BBC or function used to mitigate an accident.

The proposed changes do not involve a change to a fission product barrier. The changes do not result in a new failure mode, malfunction, or sequence of events that could affect safety. The changes would not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures.

Page 10 of 16

ND-19-0162 Request for License Amendment Consolidation of Stnictural Buildbig ITAAC(LAR-19-005}

The proposed changes do not affect any safety-related equipment, design code limit, safety related function, safety-related design analysis, safety analysis input or result, or design or safety margin. No safety analysis or design basis acceptance limit or criterion would be challenged or exceeded.

In conclusion,the proposed changes do not involve a technical(design, analysis,function or qualification) change, (e.g., there is no change to an associated calculation, design parameter or design requirement). Therefore, the changes would not result in a decrease in plant safety.

The proposed changes associated with this license amendment request do not affect the containment, control, channeling, monitoring, processing or releasing of radioactive and non-radioactive materials. No effluent release path is impacted. Therefore, radioactive or non-radioactive material effluents should not be affected. Plant radiation zones (as described in UFSAR Section 12.3), controls under 10 CFR 20, and expected amounts and types of radioactive materials are not affected by the proposed changes. Therefore, individual and cumulative radiation exposures will not change.

3. TECHNICAL EVALUATION(SEE SECTION 2)

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 52.98(f) requires NRG approvai for any modification to, addition to, or deletion from the terms and conditions of a COL. This amendment invoives a departure from plant specific Tier 1 information, and corresponding changes to the COL Appendix C. Therefore, this amendment requires a proposed amendment to the COL. Accordingly, NRC approval is required prior to making the piant-specific changes in this license amendment request.

10 CFR 20, Subpart C,§ 20.1201(a), Occupational dose limits for adults, requires the licensee control occupational dose to individual adults, except for planned special exposures under § 20.1206, to the more limiting of the annual limits prescribed therein. The proposed amendment does not involve an increase in plant radiation zones or a change in radiation shielding analysis methodology and will not adversely affect personnel occupational dose. The proposed amendment does not require a change in the design of any structure that provides radiation shielding.

Therefore, engineered structures used to aid compliance with 10 CFR 20.1201(a) are not adversely affected.

10 CFR 50, Appendix A, General Design Criterion (GDC)1, Quality standards and records, requires that structures, systems, and components important to safety be designed,fabricated, erected, and tested to quality standards commensurate with the importance of the safety functions to be performed. The Nl and the seismic Category II portion of the annex building and turbine building first bay continue to meet the design codes committed to in the UFSAR Subsections 3.3.2.3 and 3.8.

GDC 1 also requires that appropriate records of the design, fabrication, erection, and testing of structures, systems, and components(SSCs) important to safety be maintained by or under the control of the nuclear power unit licensee throughout Page 11 of 16

ND-19-0162 Request for License Amendment: Consotidation of Structural Building ITAAC (LAR-19-CK)5) the life of the unit. The quality assurance requirements of Appendix B to 10 CFR Part 50 are applied to activities affecting the Nl and the seismic Category II portion of the annex building and turbine building first bay. The proposed changes do not affect the quality assurance program and compliance with GDC 1 is maintained.

10 CFR 50, Appendix A, GDC 2, Design Bases for Protection Against Natural Phenomena, requires that SSCs important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornados, hurricanes, floods, tsunamis, and seiches without loss of capability to perform their safety functions. The proposed change to Nl structure ITAAC does not require revision to any of the seismic analyses for the Nl or the containment internal structures. The design of the NI structures continues to comply with the ACI 349-01 code. The proposed change to clarify the annex building ITAAC does not involve a change to the design of the annex building as described in the UFSAR.The proposed change does not require a revision to the seismic analyses for the seismic Category II area of the annex building. The proposed changes do not involve a reduction in the ability of any structure, system or component to withstand the effects of natural phenomena; and compliance with GDC 2 is maintained.

10 CFR 50, Appendix A, GDC 3, Fire Protection, requires that SSCs important to safety shall be designed and iocated to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. The proposed change does not involve a design basis change or change to the fire areas or zones described in the UFSAR. The proposed ITAAC change does not adversely affect plant fire protection features protecting SSCs important to safety. Therefore, the requirements of GDC 3continue to be met.

10 CFR 50, Appendix A, GDC 4, Environmental and Dynamic Effects Design Bases, requires SSCs important to safety be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing, and postulated accidents, including loss-of-coolant accidents. The changes to the Nl ITAAC are consolidation changes only, and do not involve a change to the design of the Nl. The changes to annex building iTAAC are also consolidations and do not involve a change to the design of the annex building. The annex building does not house SSCs important to safety.

However, the annex building is designed such that the portion of the building adjacent to the auxiliary building maintains structural integrity during a safe shutdown earthquake. The proposed change to the annex building ITAAC does not impact the seismic analysis of the Seismic Category II portion of the annex building.

Therefore, the design continues to comply with GDC 4.

10 CFR 50, Appendix A, GDC 19, Controi Room, requires a control room 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. GDC 19 also requires adequate radiation protection be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whoie body, or its equivalent to any part of the body,for the duration of the accident. The proposed changes to the Ni ITAAC are consolidation changes Page 12 of 16

ND-19-0162 Request for License Amendment Consotidation of Structural Building ITAAC (LAR-19-005) only and do not involve a change to the design of the Nl. The annex building provides the security-controlled access path to the main control room. The change to the annex building ITAAC does not involve a change to the design of the annex building, shielding for the annex building, or the normal operation or post-accident radiation zoning of the annex building. The proposed change to the annex building does not affect the radiation zone of the security-controlled access path to the main control room because the floor was not credited with radiation shielding in development of the predicted radiation zoning for the security entrance shown in UFSAR Figure 12.3-2. Therefore, the design continues to comply with GDC 19.

4.2 Precedent None.

4.3 Significant Hazards Consideration Determination The proposed changes revise COL Appendix C (and plant-specific Tier 1 information) to consolidate duplicative ITAAC Acceptance Criteria for certain structures and clarify that evaluations of thickness deviations will be included in the reconciliation and thickness reports described in the ITAAC or COL Appendix C Table 3.3-1.

An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

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

Response: ^

The proposed changes do not affect the operation or reliability of any system, structure or component(SSC) required to maintain a normal power operating condition or to mitigate anticipated transients without safety-related systems.

The changes to Nl, annex building, turbine building and Waste Accumulation Room ITAAC involves no design changes or technical reanalysis. The changes consolidate duplicative ITAAC Acceptance Criteria and clarify the evaluations of thickness deviations.

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

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

Response: No The proposed changes do not affect the operation of any safety-related SSC relied upon to mitigate design basis accidents. The proposed changes to the Page 13 of 16

ND-19-0162 Request for License Amendment: Consotidation of Structural Building ITAAC(LAR-19-005}

Nl, annex building, turbine building, and Waste Accumulation Room ITAAC do not involve a change to design or reanalysis. The proposed changes do not affect the structural integrity or seismic response of the Nl and the seismic Category II portion of the annex building and turbine building first bay. The design of these structures continues to meet the requirements of 10 CFR 50 Appendix A General Design Criterion 2, Design Bases for Protection Against Natural Phenomena. Therefore, the proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.

4.3.3 Does the proposed amendment Involve a significant reduction in a margin of safety?

Response: ^

The proposed changes do not affect existing safety margins. The proposed changes to Nl, annex building, turbine building, and Waste Accumulation Room ITAAC do not involve a change to the design or reanalysis of the structures. The proposed changes do not involve a reduction to the structural integrity of the seismic Category I or II portions of building structures. The Nl and the seismic Category II portion of the annex building and turbine building first bay will continue to support their design functions. No margin to the specified acceptable fuel design limits is affected by the proposed changes.

4.4 Conclusions Based on the 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 to the health and safety of the public.

Therefore, it is concluded that the requested amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c),

and, accordingly, a finding of "no significant hazards consideration" is justified.

5. ENVIRONMENTAL CONSIDERATIONS Section 2 of this License Amendment Request provides the details of the proposed changes.

The proposed changes affect the COL Appendix C and associated plant-specific Tier 1 information.

(i) There is no significant hazards consideration.

As described in Section 4.3, Significant Hazards Consideration Determination, an evaluation was completed to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment." The Significant Hazards Consideration Determination concluded that: (1) the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the proposed amendment Page 14 of 16

ND-19-0162 Request for License Amendment: Consolidation of Structural Building ITAAC(LAR-19-005) does not involve a significant reduction in a margin of safety. Therefore, it is concluded that the proposed amendment does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and accordingly, a finding of "no significant hazards consideration" is justified.

(ii) There is no significant change in the types or significant increase in the amounts of any effluents that may be released offsite.

The proposed changes do not affect any aspect of plant construction or operation that introduces a change to any effluent types (for example effluents containing chemicals or biocides, sanitary system effluents, and other effluents), and does not affect any plant radiological or non-radiological effluent release quantities. The proposed changes do not affect the structure or functionality of any design feature or operational arrangements credited with controlling the release of effluents during plant operation.

The proposed changes to Nl, annex building, turbine building, and Waste Accumulation Room ITAAC do not involve a change to the design of the associated structures. The proposed changes to the ITAAC do not involve a change to any system associated with containing, controlling, channeling, monitoring, or processing radioactive or non-radioactive materiais. The proposed change to the Ni, annex building, turbine building, and Waste Accumulation Room ITAAC do not involve a change to any systems or structures associated with containing, controlling, channeling, monitoring, or processing radioactive or non-radioactive materials that may be released offsite.

Therefore, there is no significant change in the types or significant increase in the amounts of any radioactive or non-radioactive effluents that may be released offsite.

(Hi) There is no significant increase in individual or cumulative occupational radiation exposure.

Company and station policies keep radiation exposure of personnel within limits defined by 10 CFR 20,"Standards for Protection Against Radiation." Administrative procedures and practices are implemented to maintain radiation exposure of personnel as low as is reasonably achievable.

The proposed changes to the Nl, annex building, turbine building, and Waste Accumulation Room ITAAC revises COL Appendix C (and plant-specific Tier 1 information) to consolidate duplicative ITAAC Acceptance Criteria for certain structures and clarify that evaluations of thickness deviations are included in the reconciliation and thickness reports described in the ITAAC. This change does not involve an increase in individual or cumulative occupational radiation exposure because the proposed change does not adversely affect radiation shielding analyses.

There are no systems in the control support area or the surrounding rooms that normally contain radioactive material, and adequate shielding from normal radiation sources is provided by the shield building and shield walls between the radiologically controlled and non-radiologically controlled areas of the auxiliary building. Therefore, the requested amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Page 15 of 16

ND-19-0162 Request for License Afnendment: Consolkfation of Structural Building ITAAC(LAR-19-005)

6. REFERENCES None.

Page 16 of 16

Southern Nuclear Operating Company ND-19-0162 Enclosure 2 Vogtle Electric Generating Plant(VEGP) Units 3 and 4 Exemption Request:

Consolidation of Structural Building ITAAC (LAR-19-005)

(Enclosure 2 consists of 8 pages, including this cover page.)

ND-19-0162 Exemption Request: Consotktation of Structural Buildirtg ITAAC(LAR-19-005) 1.0 PURPOSE Southern Nuclear Operating Company(the Licensee) requests a permanent exemption from the provisions of 10 CFR 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, to allow a plant-specific departure from elements of the certification information in Tier 1 of the plant-specific API000 Design Control Document (DCD). The regulation, 10 CFR 52, Appendix D, Section III.B, requires an applicant or licensee referencing Appendix D to 10 CFR Part 52 to incorporate by reference and comply with the requirements of Appendix D, including certified information in DCD Tier 1. The proposed changes would modify COL Appendix C(and corresponding plant-specific Tier 1) information. The changes include consolidating Inspections, Tests, Analyses, and Acceptance Criteria(ITAAC)for structural buildings and clarifying as-built deviations in wall thickness will be addressed by the appropriate structural building ITAAC.

This request for exemption will apply the requirements of 10 CFR 52, Appendix D, Section VIII.A.4 to allow departures from Tier 1 information due to the proposed changes, as described below.

Table 3.3-1

• Add Note 15 to clarify that reconciliation of the construction deviations, from the thickness and tolerances specified in this table, are included in the reconciliation reports, and demonstrate that the as-built buildings will withstand design basis loads without loss of structural integrity or safety functions and without loss of shielding functions specified in the associated ITAAC.

• Add Note 16 to clarify that the construction deviations of the annex building structural thicknesses from the table are evaluated in the thickness report by demonstrating that the structural and shielding function specified in the associated ITAAC is met.

• Add Note 17 to clarify that the construction deviations of the turbine building structural thicknesses from the table are evaluated in the thickness report which demonstrates that the structural function specified in the associated ITAAC is met.

Table 3.3-6. ITAAC Number 3.3.00.02a.i.a. containment internal structures

• Add the shielding function in "Design Commitment."

• Add the requirement for analysis of deviations due to as-built conditions for radiation shielding in "Inspections, Tests and Analyses."

• Add requirement for verification of no loss of the shielding function in the reconciliation report in "Acceptance Criteria."

• Clarify in "Acceptance Criteria" that the thickness deviations from Table 3.3-1 are reconciled in the reconciliation report.

Table 3.3-6 ITAAC Number 3.3.00.02a.i.b. shield buildino

• Add the shielding function in "Design Commitment."

Page 2 of 8

ND-19-0162 Exemption Request: Consolidation of Structural Building ITAAC(LAR-19-005)

• Add the requirement for analysis of deviations due to as-built conditions for radiation shielding in "Inspections, Tests and Analyses."

• Add requirement for verification of no loss of the shielding function in the reconciliation report in "Acceptance Criteria."

• Clarify in "Acceptance Criteria" that the thickness deviations from Table 3.3-1 are reconciled in the reconciliation report.

Table 3.3-6 ITAAC Number 3.3.00.02a.i.c. auxiliarv buildino fnon-radioloaicallv controlled)

• Add the shielding function in "Design Commitment."

• Add the requirement for analysis of deviations due to as-built conditions for radiation shielding in "Inspections, Tests and Analyses."

• Add requirement for verification of no loss of the shielding function in the reconciliation report in "Acceptance Criteria."

• Clarify in "Acceptance Criteria" that the thickness deviations from Table 3.3-1 are reconciled in the reconciliation report.

Table 3.3-6 ITAAC Number 3.3.00.02a.i.d. auxiliarv buildino fradiolooicallv controlled)

• Add the shielding function in "Design Commitment."

• Add the requirement for analysis of deviations due to as-built conditions for radiation shielding in "Inspections, Tests and Analyses."

• Add requirement of verification for no loss of the shielding function in the reconciliation report in "Acceptance Criteria."

• Clarify in "Acceptance Criteria" that the thickness deviations from Table 3.3-1 are reconciled in the reconciliation report.

Table 3.3-6 ITAAC Number 3.3.00.02a.ii.a. containment internal structures

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC No. 3.3.00.02a.ii.b. shield buildino structures

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.02a.ii.c. auxiliarv buildino fnon-radiolooicallv controlled)

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.02a.ii.d. auxiliarv buildino (radiolooicallv controlled)

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.02a.ii.e. annex buildino

• Add the shielding function in "Design Commitment."

Page 3 of 8

ND-19-0162 Exemption Request: Consolidation of Structural Building ITAAC(LAR-19-005)

• Modify "Acceptance Criteria" to clarify that the thickness report also includes evaluations of thickness deviations identified during construction and demonstrates that the as-built structures will withstand the design basis loads without loss of structural integrity and that there is no loss of the shielding function.

Table 3.3-6 ITAAC Number 3.3.00.02a.ii.f. turbine buildino

• Modify "Acceptance Criteria" to clarify that the thickness report also includes evaluations of thickness deviations identified during construction and demonstrates that the as-built structures will withstand the design basis loads without loss of structural integrity.

Table 3.3-6 ITAAC Number 3.3.00.03a. containment internal structures

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.03b. shield buildino

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.03c. auxiliarv building (non-radioloaicallv controlled)

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.03d. auxiliarv buildino (radiolooicallv controlled)

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.04a. annex buildino

• Delete the ITAAC by identifying it as "Not used per Amendment No.[XXX]."

Table 3.3-6 ITAAC Number 3.3.00.04b. waste accumulation room in the radwaste buildino

• Modify "Acceptance Criteria" to clarify that the thickness report also includes evaluations of thickness deviations identified during construction and demonstrates there is no loss of the shielding function.

• Delete "minimum" in front of the wall thickness from the "Acceptance Criteria."

This request will provide for the application of the requirements for granting exemptions from design certification information, as specified in 10 CFR Part 52, Appendix D, Section VIII.A.4, 10 CFR 52.63, §52.7, and §50.12.

2.0 BACKGROUND

The Licensee is the holder of Combined License numbers NPF-91 and NPF-92, which authorize construction and operation of two Westinghouse Electric Company API000 nuclear plants, named Vogtle Electric Generating Plant(VEGP) Units 3 and 4, respectively.

Page 4 of 8

ND-19-0162 Exemption Request: Consolidation of Structural Building ITAAC(LAR-19^005)

SNC proposes to revise COL Appendix C (and plant-specific Tier 1 information) to consolidate duplicative ITAAC Acceptance Criteria for certain structures and clarify the evaluations of thickness deviations in the reconciliation and thickness reports described in ITAAC. An exemption from elements of the AP1000 certified (Tier 1) design information to allow a departure from the Design Description is requested.

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY An exemption is requested to depart from AP1000 plant-specific DCD Tier 1 material with regard to consolidating, removing, and clarifying Ml, annex building, turbine building, and radwaste building ITAAC.

The proposed changes to Nl, annex building, turbine building, and radwaste building ITAAC presented in plant-specific Tier 1 are at a level of detail that is consistent with the information currently provided therein. The proposed changes neither adversely impact the ability to meet the design functions of the components, nor involve a significant decrease in the level of safety provided by the components. The proposed changes to information in plant-specific Tier 1 continue to provide the detail necessary to implement the corresponding ITAAC.

4.0 JUSTIFICATION OF EXEMPTION 10 CFR Part 52, Appendix D, Section VIII.A.4 and 10 CFR 52.63(b)(1) govern the issuance of exemptions from elements of the certified design information for API000 nuclear power plants. Since SNC has identified changes to the Tier 1 information related to structural building ITAAC, as discussed in Enclosure 1 of the accompanying License Amendment Request, an exemption from the certified design information in Tier 1 is needed.

10 CFR Part 52, Appendix D,and 10 CFR 50.12,§52.7, and §52.63 state that the NRC may grant exemptions from the requirements of the regulations provided six conditions are met:

1) the exemption is authorized by law [§50.12(a)(1)]; 2) the exemption will not present an undue risk to the health and safety of the public(§50.12(a)(1)]; 3)the exemption is consistent with the common defense and security [§50.12(a)(1)]; 4)special circumstances are present

[§50.12(a)(2)];5)the special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption [§52.63(b)(1)]; and 6) the design change will not result in a significant decrease in the level of safety[Part 52, App. D, VIII.A.4].

The requested exemption satisfies the criteria for granting specific exemptions, as described below.

1. This exemption Is authorized by law The NRC has authority under 10 CFR 52.63, §52.7, and §50.12 to grant exemptions from the requirements of NRC regulations. Specifically, 10 CFR 50.12 and §52.7 state that the NRC may grant exemptions from the requirements of 10 CFR Part 52 upon a proper showing. No law exists that would preclude the changes covered by this exemption request. Additionally, granting of the proposed exemption does not result in a violation of the Atomic Energy Act of 1954, as amended, or the Commission's regulations.

Page 5 of 8

ND-19-0162 Exemption Request: Corrsolidation of Structurat Building ITAAC {tJ^R-19-005)

Accordingly, this requested exemption is "authorized by law," as required by 10 CFR 50.12(a)(1).

2. This exemption wiii not present an undue risk to the heaith and safety of the pubiic The proposed exemption from the requirements of 10 CFR 52, Appendix D,Section III.B would allow changes to elements of the plant-specific DCD Tier 1 to depart from the API000 certified (Tier 1) design information. The plant-specific Tier 1 will continue to reflect the approved licensing basis for VEGP Units 3and 4 and will maintain a consistent level of detail with that which is currently provided elsewhere in Tier 1 of the DCD.

Therefore, the affected plant-specific DCD Tier 1 ITAAC will continue to serve its required purpose.

The proposed changes to the Nl, annex building, turbine building, and radwaste building ITAAC will not impact the ability of the structures, systems, or components(SSCs) to perform their design functions. The SSCs will be constructed in accordance with the design certification as verified by plant-specific Tier 1 Table 3.3-6 ITAAC. Because the changes will not alter the operation of any plant equipment or system's ability to perform their design function, these changes do not present an undue risk to existing equipment or systems. The changes do not introduce any new industrial, chemical, or radiological hazards that would represent a public health or safety risk, nor do they modify or remove any design or operational controls or safeguards that are intended to mitigate any existing on-site hazards. Furthermore, the proposed changes would not allow for a new fission product release path, result in a new fission product barrier failure mode,or create a new sequence of events that would result in significant fuel cladding failures.

Accordingly, these changes do not present an undue risk from any new equipment or systems.

Therefore, the requested exemption from 10 CFR 52, Appendix D, Section III.B, would not present an undue risk to the health and safety of the public.

3. The exemption Is consistent with the common defense and security The requested exemption from the requirements of 10 CFR 52, Appendix D, Section III.B would allow the Licensee to depart from elements of the plant-specific DCD Tier 1 design information. The requested exemption does not alter or impede the design, function, or operation of any plant SSCs that is necessary to maintain a safe and secure plant status. The proposed exemption has no impact on plant security or safeguards procedures.

Therefore, the requested exemption is consistent with the common defense and security.

4. Special circumstances are present 10 CFR 50.12(a)(2) lists six "special circumstances" for which an exemption may be granted. Pursuant to the regulation, it is necessary for one of these special circumstances to be present in order for the NRC to consider granting an exemption request. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subsection defines special circumstances as when "Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule."

Page 6 of 8

ND-19-0162 Exemption Request: Consolidation of Structural Building ITAAC(LAR-19-005)

The rule under consideration in this request for exemption is 10 CFR 52, Appendix D, Section III.B, which requires that a licensee referencing the API000 Design Certification Rule (10 CFR Part 52, Appendix D)shall incorporate by reference and comply with the requirements of Appendix D,including Tier 1 information. The VEGP Units 3and 4 COLs reference the API000 Design Certification Rule and incorporate by reference the requirements of 10 CFR Part 52, Appendix D, including Tier 1 Information. The underlying purpose of Appendix D,Section III.B is to describe and define the scope and contents of the API000 design certification, and to require compliance with the design certification Information In Appendix D.

The proposed consolidation and clarification changes to Nl, annex building, turbine building, and radwaste building ITAAC ensure that the SSCs related to this amendment are constructed In accordance with the design certification as verified by plant-specific Tier 1 Table 3.3-6 ITAAC. These changes do not Impact the ability of any SSCs to perform their functions or negatively Impact safety. Accordingly, this exemption from the certification Information will enable the licensee to safely construct and operate the API000 facility consistent with the design certified by the NRC In 10 CFR 52, Appendix D.

Therefore, special circumstances are present, because application of the current plant-specific certified design Information In Tier 1 as required by 10 CFR Part 52, Appendix D,Section III.B In the particular circumstances discussed In this request Is not necessary to achieve the underlying purpose of the rule.

5. The special circumstances outweigh any decrease in safety that may result from the reduction in standardization caused by the exemption.

Based on the nature of the changes to the plant-specific Tier 1 Information In this area and the understanding that these changes are not related to system functions, these changes will not have a negative Impact. Nevertheless, If other API000 licensees do not elect to request this exemption, the special circumstances continue to outweigh any decrease In safety from the reduction In standardization because the key design functions associated with this request will continue to be maintained. This exemption request and the associated marked-up table demonstrate that there is a minimal change from the plant-specific API000 DCD, minimizing the reduction In standardization and consequently the safety Impact from the reduction.

Therefore,the special circumstances associated with the requested exemption outweigh any decrease In safety that may result from the reduction In standardization caused by the exemption.

6. The design change will not result in a significant decrease in the level of safety.

The proposed exemption would allow consolidation of dupllcatlve ITAAC Acceptance Criteria for certain structures, and clarify that evaluations of thickness deviations will be Included In the reconciliation and thickness reports. The changes to Nl, annex building, turbine building, and radwaste building ITAAC will not Impact the functional capabilities of the structures. Because the proposed changes to ITAAC associated with this exemption request will not modify the design or operation of any systems or equipment, there are no new failure modes Introduced by these changes and the level of safety provided by the current SSCs will be unchanged.

Page 7 of 8

ND-19-0162 Exemptton Request: Consolidation of Structural Building ITAAO(LAR-19-005)

The proposed changes require revisions to plant-specific Tier 1 information; there is no technical design change or plant function change associated with this exemption.

Because the proposed changes associated with this exemption request will not adversely affect the ability of any systems or equipment to perform their design functions and the level of safety provided by the current systems and equipment is unchanged, it is concluded that the changes associated with this proposed exemption will not result in a significant decrease in the level of safety.

5.0 RISK ASSESSMENT A risk assessment was not determined to be applicable to address the acceptability of this proposal.

6.0 PRECEDENT None identified.

7.0 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 exemption 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. Specific justification is provided in Section 5 of the corresponding license amendment request.

Accordingly, the proposed exemption 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 to be prepared in connection with the proposed exemption.

8.0 CONCLUSION

The proposed changes to DCD Tier 1 are necessary to consolidate duplicative ITAAC Acceptance Criteria for certain structures and clarify that evaluations of thickness deviations will be included in the reconciliation and thickness reports. The exemption request meets the requirements of 10 CFR 52.63,10 CFR 52.7,10 CFR 50.12,10 CFR 51.22 and 10 CFR 52 Appendix D. Specifically, the exemption request meets the criteria of 10 CFR 50.12(a)(1) in that the request is authorized by law, presents no undue risk to public health and safety, and is consistent with the common defense and security. Furthermore, approval of this request does not result in a significant decrease in the level of safety, presents special circumstances, does not present a significant decrease in safety as a result of a reduction in standardization, and meets the eligibility requirements for categorical exclusion.

9.0 REFERENCES

None.

Page 8 of 8

Southern Nuclear Operating Company ND-19-0162 Enclosure 3 Vogtle Electric Generating Plant(VEGP) Units 3 and 4 Proposed Changes to the Licensing Basis Documents (LAR-19-005)

Note:

Added text Is shown as bold Blue Underline Deleted text is shown as bold Red Strikethrough

• indicates omitted existing text that is not shown.

(Enclosure 3 consists of 9 pages, including this cover page)

ND-19-0162 Proposed Changes to the Licensing Basis Documents (LAR-19-005)

Revise COL Appendix 0 Table 3.3-1, and corresponding plant-specific Tier 1 Table 3.3-1, "Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building," as shown below.

Table 3.3-1 DeHnition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building^

Applieable Radiation Floor Elevation or Concrete Shielding Wall Wall or Section Description Column Lines'" Elevation Range'""" Thickness'""'""'"' (Yes/No)

Containment Building Internal Structure

1. The column lines and floor elevations are identified and included on Figures 3.3-1 through 3.3-13.

2. These wall (and floor) thicknesses have a construction tolerance of +/- 1 inch, except as noted and for exterior walls below grade where the tolerance is +12 inches, - 1 inch. These tolerances are not applicable to the nuclear island baseniat.

For walls that are part of stractural modules, the concrete thickness also includes the steel face plates. Where faceplates with a nominal thickness of 0.5 inches are used in the construction of the wall modules, the wall thicknesses in this column apply. Where faceplates thicker than the nominal 0.5 inches are used in the construction of the structural wall modules, the wall thicknesses in the area of the thicker faceplates are greater than indicated in this column by the amount of faceplate thickness increase over the nominal 0.5 inches. Overlay plates are not considered part of the faceplates, and thus are not considered in the wall thicknesses identified in this column.

4. For floors with steel surface plates, the concrete thickness also includes the plate thickness.

5. Where a wall (or a floor) has openings, the concrete thickness does not apply at the opening.

6. The elevation ranges for the shield building items are rounded to the nearest inch.

7. The Wall or Section Description, Column Line information, and Floor Elevation or Elevation Ranges are provided as reference points to define the general location. The concrete thickness of an item intersecting other walls, roofs or floors at a designated location (e.g., column line) is not intended to be measured to the stated column line, but only to the point where the intersection occurs.

Where applicable, the upper wall portions extend to their associated roofs, which may vary in elevation, e.g., sloped roofs.

9. From one wall/floor section to another, the concrete thickness transitions from one thickness to another, consistent with the configurations in Figures 3.3-1 through 3.3-14.

10. This wall thickness has a tolerance of+/- 1-5/8 inch.

11. This wall thickness has a tolerance of +4 inches, -1 inch above grade.

12. The concrete thickness is the total floor thickness, including the metal decking, where applicable.

13. The concrete in the kitchen and restroom areas is 2 inches thinner.

14. The 6-foot concrete thickness includes the thickness of the containment vessel bottom head in a local area at the center of containment.

15. Reconciliation of construction deviations in the nuclear island structures from the thickness and tolerances specified in this table is included in the reconciliation reports,and demonstrate that the as-built structures will withstand design basis load.s without loss of structural integritv or safetv functions and without loss of shielding functions in accordance with ITAAC 3.3.00.02a.i.a. 3.3.0Q.02a.i.b. 3.3.00.02a.i.c. or 3.3.00.02a.i.d.

16. Construction deviations in the annex building from the thickness and tolerances specified in this table are evaluated in the thickness report to demonstrate that the as-huilt structures will withstand design basis loads without loss of structural integritv or safetv functions and without loss of shielding functions during normal operation in accordance with ITAAC 3.3.00.02a.ii.e.

17. Construction deviations in the turbine building from the thickness and tolerances specified in this table are evaluated in the thickness report to demonstrate that the as-hnilt structures will withstand design basis loads without loss of structural integritv or safetv functions in accordance with ITAAC 3.3.00.02a.ii.f.

Page 2 of 9

ND-19-0162 Proposed Changes to the Licensing Basis Documents (LAR-19-005)

Table 3.3-1 (cont.)

Definition of Wail Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building*

Applicable Radiation Floor Elevation or Concrete Shielding Wall Wall or Section Description Colunui Lines'" Elevation Range'"'*' Thickness'"'"'^"""' (Yes/No)

Shield Building"'

Auxiliary Building Walls/Floors Radiologically Controlled""

Auxiliary Building Walls/Floors Non-Radiologically Controlled" Annex Building" Turbine Building" Page 3 of 9

ND-19-0162 Enclosure 3 Proposed Changes to the Licensing Basis Documents(LAR-19-005)

Revise COL Appendix 0 Table 3.3-6, and corresponding plant-specific Tier 1 Table 3.3-6, "Inspections, Tests, Analyses, and Acceptance Criteria," as shown below.

Table 3.3-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 760 3.3.00.02a.i.a 2.a) The nuclear island structures, i) An inspection of the nuclear i.a) A report exists which including the critical sections listed in island structures will be reconciles deviations during Table 3.3-7, are seismic Category 1 and performed. Deviations from the construction, including Table are designed and constructed to design due to as-built conditions 3.3-1 wall and floor withstand design basis loads as will be analyzed for the design thicknesses, and concludes specified in the Design Description, basis loads, and for radiation that the as-built containment without loss of structural integrity and shielding. internal structures, including the safety-related functions. the critical sections, conform 3.) Walls and floors of the nuclear to the approved design and island structures as defined on Table will withstand the design basis 3.3-1 except for designed openings or loads specified in the Design oenetrations. nrovide shielding Description without loss of during normal operations. structural integrity or the safety-related functions, and that there is no loss of the shielding function.

761 3.3.00.02a.i.b 2.a) The nuclear island structures, i) An inspection of the nuclear i.b) A report exists which including the critical sections listed in island structures will be reconciles deviations during Table 3.3-7, are seismic Category 1 and performed. Deviations from the construction, including Table are designed and constructed to design due to as-built conditions 3.3-1 wall and floor withstand design basis loads as will be analyzed for the design thicknesses, and concludes that specified in the Design Description, basis loads, and for radiation the as-built shield building without loss of structural integrity and shielding. structures, including the critical the safety-related functions. sections, conform to the 3.) Walls and floors of the nuclear approved design and will island structures as defiined on Table withstand the design basis 3.3-1 excent for designed ooenings or loads specified in the Design penetrations, provide shielding Description without loss of during normal operations. structural integrity or the safety-related functions, and that there is no loss of the shielding function.

Page 4 of 9

ND-19-0162 Enclosure 3 Proposed Changes to the Licensing Basis Documents(LAR-19-005)

Table 3.3-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 762 3.3.00.02a.i.c 2.a) The nuclear island structures, i) An inspection of the nuclear i.c) A report exists which including the critical sections listed in island structures will be reconciles deviations during Table 3.3-7, are seismic Category I and performed. Deviations from the construction, including Table are designed and constructed to design due to as-built conditions 3.3-1 wall and floor withstand design basis loads as will be analyzed for the design thicknesses, and concludes that specified in the Design Description, basis loads, and for radiation the as-built structures in the without loss of structural integrity and shielding. non-radiologically controlled the safety-related functions. area of the auxiliary building, 3.) Walls and floors of the nuclear including the critical sections, island structures as defined on Table conform to the approved design 3.3-1 except for designed openings or and will withstand the design penetrations, provide shielding basis loads specified in the during normal operations. Design Description without loss of structural integrity or the safety-related functionSj_

and that there is no loss of the shielding function.

763 3.3.00.02a.i.d 2.a) The nuclear island structures, i) An inspection of the nuclear i.d) A report exists which including the critical sections listed in island structures will be reconciles deviations during Table 3.3-7, are seismic Category 1 and performed. Deviations from the construction, including Table are designed and constructed to design due to as-built conditions 3.3-1 wall and floor withstand design basis loads as will be analyzed for the design thicknesses, and concludes specified in the Design Description, basis loads, and for radiation that the as-built structures in without loss of structural integrity and shielding. the radiologically controlled the safety-related functions. area of the auxiliary building, 3.) Walls and floors of the nuclear including the critical sections, island structures as defined on Table conform to the approved 3.3-1 except for designed openings or design and will withstand the penetrations, provide shielding design basis loads specified in during normal operations. the Design Description without loss of structural integrity or the safety-related functions, and that there is no loss of the shielding function.

764 3.3.00.02a.ii.a Not used per Amendment No.fXXXI ii) An inspection of the ii.a) A report exists that 2.n) The nuclear island structures, as built concrete thickness will concludes that the including the critical sections listed he performed. containment internal in Table 3.3-7, arc seismic Cntcgory I structures as built concrete and arc designed and constructed to thicknesses conform to the withstand design basis loads as building sections defined in specified in the Design Description, Table 3.3 1.

without loss of structural integrity and the safety related functions.

Page 5 of 9

ND-19-0162 Enclosure 3 Table 3.3-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 765 3.3.00.02a.ii.b Not used ner Amendment No. fXXXl ii) An inspection of the ii.b) A report exists that as-built concrete thickness will in Table 3.3-7, are seismic Category I shield building sections and are designed and constructed to conform to the building

^A'W-llvIllo UC-llll^U 111 specified in the Design Description, Table 3.3 1.

without loss of structural integrity and the safety related functions.

766 3.3.00.02a.ii.c Not used ner Amendment No. fXXXl ii) An inspection of the ii.c) A report exists that 2.a) The nuclear island strncturos, as-built concrete thickness will concludes that as built IJ^l lUl lll^lXs 111 J. UUlL. J i ^ Ul v. ij^lLjllUC. U jX and are designed and constructed to area of the auxiliary withstand design basis loads as building sections conform to olJC-Wlll^U 111 Lll^ E.^^ijl^li iiji'imi^ 1.11^ IXlXllUlll^ LIH11l7 U^lllIA-U without loss of structural integrity in Table 3.3 1.

and the safety related functions.

767 3.3.00.02a.ii.d Not used ner Amendment No. fXXXl ii) An inspection of the ii.d) A report exists that 2.a) The nuclear island structures, as built concrete thickness will concludes that the as-built u^i 1 m iiiv-ix* A-LIllx.*! CLC LlllL^lWllL.oCo I.J1 LllC 111 X UHl^ i ^ 1.11 ^ (jClvjllUv. V^UWLUl \ X and are designed and constructed to area of the auxiliary withstand design basis loads as building sections conform to 111 llll^ X./L'ljI^II X./L'lj^xI^HIJII^

without loss of structural integrity in Table 3.3 1.

and the safety related functions.

Page 6 of 9

ND-19-0162 Enclosure 3 Table 3.3-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 768 3.3.00.02a.ii.e 2.a) The nuclear island structures, ii) An inspection of the ii.e) A report exists that including the critical sections listed as-huilt concrete thickness will concludes that the as-built in Table 3.3-7, are seismic Category I be performed. concrete thicknesses of the and are designed and constructed to annex building sections withstand design basis loads as conform with the building specified in the Design Description, sections defined in without loss of structural integrity Table 3.3-1, except for and the safety-related functions. designed openings or 4.a) Walls and floors of the annex penetrations, or tbe report buildinn as defined on Table 3.3-1 documents an evaluation of excent for designed onenings or thickness deviations nenetrations provide shielding identified during during normal onerations. construction and demonstrates that the as-built structures will withstand the design basis loads without loss of structural integritv and that there is no loss of the shielding function.

769 3.3.00.02a.ii.f 2.a) The nuclear island structures, ii) An inspection of the ii.f) A report exists that including the critical sections listed as-built concrete thickness will concludes that the as-built in Table 3.3-7, are seismic Category I be performed. concrete thicknesses of the and are designed and constructed to turbine building sections withstand design basis loads as conform to tbe building specified in the Design Description, sections defined in without loss of structural integrity Table 3.3-1. except for and the safety-related functions. designed openings or penetrations, or tbe report documents an evaluation of thickness deviations identified during construction and demonstrates that the as-huilt structures will withstand the design basis loads without loss of structural integritv.

Page 7 of 9

ND-19-0162 Enclosure 3 Proposed Changes to the Licensing Basts Documents(LAR-19-005)

Table 3.3-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 111 3.3.00.03a Not used per Amendment No. IXXXl

3. Walls and floors of the nuclear nuclear island structures wall concludes that the shield island structures as defined on and floor thicknesses will be walls and floors of the Table 3.3-1 except for designed performed. containment internal openings or penetrations provide structures as defined in shielding during normal operations. Table 3.3-1, except for designed openings or penetrations, are consistent with the concrete wall thicknesses provided in Table 3.3 1.

778 3.3.00.03b Not used per Amendment No. IXXX! Inspection of the as built b) A report exists and

3. Walls and floors of the nuclear nuclear island structures wall concludes that the shield island structures as defined on and floor thicknesses will be walls of the shield building Table 3.3 1 except for designed performed. structures as defined in openings or penetrations provide Table 3.3 1 except for shielding during normal operations. designed openings or penetrations are consistent with the concrete wall thicknesses provided in Table 3.3 1.

779 3.3.00.03c Not used per Amendment No.[XXXI Inspection of the as built c) A report exists and

3. Walls and floors of the nuclear nuclear island structures wall concludes that the shield island structures as defined on and floor thicknesses will be walls and floors of the Table 3.3 1 except for designed performed. non-radiologically controlled openings or penetrations provide area of the auxiliary shielding during normal operations. building as defined in Table 3.3 1 except for designed openings or penetrations are consistent with the concrete wall thicknesses provided in Table 3.3 1.

780 3.3.00.03d Not used per Amendment No.[XXXI Inspection of the as built d) A report exists and

3. Walls and floors of the nuclear nuclear island structures wall concludes that the shield island structures as defined on and floor thicknesses will be walls and floors of the Table 3.3 1 except for designed performed. radiologically controlled openings or penetrations provide area of the auxiliary shielding during normal operations. building as defined in Table 3.3 1 except for designed openings or penetrations are consistent with the concrete wall thicknesses provided in Table 3.3 1.

Page 8 of 9

ND-19-0162 Enclosure 3 Proposed Changes to the Licensing Basts Documents(LAR-19-005)

Table 3.3-6 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 781 3.3.00.04a Not used per Amendment No. IXXXI A report exists and 4.a) Wails and floors of the annex annex building wall and floor concludes that the shield building as defined on Table 3.3-1 thicknesses will be performed. walls and floors of the annex except for designed openings or building as defined on penetrations provide shielding Table 3.3 1 except for during normal operations. designed openings or penetrations arc consistent Table 3.3 1.

782 3.3.00.04b 4.b) Walls of the waste accumulation Inspection of the as-built A report exists and concludes room in the radwaste building except radwaste building wall that the shield walls of the for designed openings or penetrations thicknesses will be performed. waste accumulation room in provide shielding during normal the radwaste building except operations. for designed openings or penetrations are consistent with the minimum concrete wall thicknesses of 1-4", and a minimum concrete wall thickness of I'-S" near the radwaste bunkers, or the report documents an evaluation of thickness deviations identified during construction and demonstrates there is no loss of the shielding function.

Page 9 of 9