NL-23-0193, Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)

Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)

ML23083B967
Person / Time
Site:	Vogtle
Issue date:	03/24/2023
From:	Brown R Southern Nuclear Operating Co
To:	Office of Nuclear Reactor Regulation, Document Control Desk
References
NL-23-0193
Download: ML23083B967 (1)

Text

R. Keith Brown Southern Nuclear

~ Southern Nuclear Director, Regulatory Affairs Operating Company, Inc.

3535 Colonnade Parkway Birmingham, AL 35243 March 24, 2023 Docket Nos: 52-025 NL-23-0193 52-026 10 CFR 50.90 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment:

Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests an amendment to the combined licenses (COLs) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4 (License Numbers NPF-91 and NPF-92, respectively).

The requested amendment proposes to depart from Updated Final Safety Analysis Report (UFSAR) Tier 2 information (which includes the plant-specific Design Control Document (DCD) Tier 2 information) and involves related changes to COL Appendix A, Technical Specifications (TS).

The requested amendment proposes relocating TS 3.7.9, Spent Fuel Pool Makeup Water Sources, to the VEGP Technical Requirements Manual (TRM) as UFSAR Standard Content, which is controlled in accordance with 10 CFR 50.59.

The enclosure to this letter provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed changes. provides markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents. describes the associated Regulatory Commitment to fulfill the basis for this change. provides the proposed VEGP Units 3 and 4 Technical Specifications clean pages.

This letter has been reviewed and determined not to contain security-related information.

SNC requests NRC staff review and approval of the license amendment request (LAR) no later than April 15, 2024. Approval by this date will allow sufficient time to implement licensing basis changes necessary to support outage activities. SNC expects to implement the proposed amendment within 90 days of approval of the LAR.

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

U.S. Nuclear Regulatory Commission NL-23-0193 Page 2 of 2 Should you have any questions, please contact Ms. Amy Chamberlain at (205) 992-6361.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 24th of March 2023.

Respectfully submitted, OV)) ~(J R. Keith Brown Director, Regulatory Affairs Southern Nuclear Operating Company

Enclosure:

Evaluation of the Proposed Change Attachments 1: Proposed VEGP Units 3 and 4 Licensing Basis Markups 2: Regulatory Commitment 3: Proposed VEGP Units 3 and 4 Technical Specifications Changes (Clean Pages) cc: Regional Administrator, Region ll VPO Project Manager Senior Resident Inspector - Vogtle 3 & 4 Director, Environmental Protection Division - State of Georgia Document Services RTYPE: VND.LI.L00 File AR.01.02.06

Southern Nuclear Operating Company Enclosure to NL-23-0193 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)

Evaluation of the Proposed Change

Enclosure to NL-23-0193 Evaluation of the Proposed Change 1.0

SUMMARY

DESCRIPTION In accordance with the provisions of 10 CFR 50.90 of Title 10 of the Code of Federal Regulations, Southern Nuclear Operating Company (SNC) is submitting a request for amendments to the Technical Specifications (TS), for Vogtle Electric Generating Plant (VEGP), Units 3 and 4. The proposed amendment relocates TS 3.7.9, Spent Fuel Pool Makeup Water Sources, to the VEGP Technical Requirements Manual (TRM) as UFSAR Standard Content, which is controlled in accordance with 10 CFR 50.59. The proposed change also involves changes to plant-specific design control document (PS-DCD) Tier 2 information affected by the relocation.

2.0 DETAILED DESCRIPTION 2.1 System Design and Operation The spent fuel pool is normally cooled by the non-safety spent fuel pool cooling system. In the event the normal cooling system is unavailable, the spent fuel pool can be cooled by the normal residual heat removal system. Alternatively, the spent fuel pool and fuel transfer canal contain sufficient water inventory for decay heat removal as needed. To support extended periods of loss of normal pool cooling, makeup water can be supplied to provide additional cooling as needed.

Both safety and non-safety makeup water sources are available on site.

Safety-related, gravity fed sources of makeup water are provided to the spent fuel pool. These makeup water sources contain sufficient water to maintain spent fuel pool cooling for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> with the worst-case decay heat load (decay heat > 7.0 MWt) produced by a full core off-load following a refueling plus fifteen years of spent fuel. These makeup water sources vary depending on plant status and include the fuel transfer canal, cask loading pit, cask washdown pit, and the Passive Containment Cooling Water Storage Tank (PCCWST). Additional on-site makeup water sources are available to provide spent fuel pool cooling between 3 and 7 days.

The worst-case event is also analyzed assuming a seismic event concurrent with a station blackout where the spent fuel pool cooling suction line to the spent fuel pool is assumed to fail, and the water in the pool and makeup sources are assumed to drain to the bottom elevation of the spent fuel pool cooling suction piping attachment to the spent fuel pool.

A general description of the spent fuel pool design is given in UFSAR (plant-specific DCD Tier 2)

Subsection 9.1.2. A description of the Spent Fuel Pool Cooling and Cleanup System is given in UFSAR Subsection 9.1.3.

2.2 Current Technical Specifications Requirements The current TS 3.7.9, Spent Fuel Pool Makeup Water Sources, requires that spent fuel pool makeup water sources shall be OPERABLE when irradiated fuel assemblies are stored in the spent fuel pool. The spent fuel pool makeup water sources include the fuel transfer canal, cask washdown pit, cask loading pit, and the PCCWST (and their flow paths into the spent fuel pool) at varying decay heat levels. Since none of the FSAR Chapter 15 Design Basis Accident analyses assume availability of the PCCWST, the cask washdown pit, or the cask loading pit for spent fuel pool makeup, the spent fuel pool makeup water sources specification does not satisfy any of the 10 CFR 50.36(c)(2)(ii) criteria. This LCO is included as a result of an NRC letter summarizing the results of a telephone conference (Reference 2).

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Enclosure to NL-23-0193 Evaluation of the Proposed Change 2.3 Reason for the Proposed Change The proposed change is desired to provide flexibility in outage planning and preventative maintenance activities by allowing consideration of alternate makeup water source strategies (e.g., allowance to close the fuel transfer canal gate in order to perform preventative maintenance on the fuel transfer canal fuel assembly upender when other spent fuel pool makeup water sources provide sufficient makeup to address decay heat levels). These types of changes are outside the scope of the LAR and will be controlled in accordance with 10 CFR 50.59. This will also eliminate an unnecessary burden on SNC and the NRC associated with future revisions to the TS by establishing consistency with the requirements of 10 CFR 50.36(c)(2)(ii).

2.4 Description of the Proposed Change The proposed amendment relocates TS 3.7.9, Spent Fuel Pool Makeup Water Sources, to the VEGP Technical Requirements Manual (TRM) as UFSAR Standard Content, which is controlled in accordance with 10 CFR 50.59. The corresponding TS Bases will also be relocated.

The change to the TS involves UFSAR changes to (plant-specific DCD) Tier 2 information in UFSAR Subsection 9.1.3.4.3 which references the location of the requirement which controls the spent fuel pool makeup water sources.

3.0 TECHNICAL EVALUATION

The proposed change relocates TS 3.7.9 to the TRM.

In order to elaborate on the TS Bases statement that the TS does not satisfy the 10 CFR 50.36(c)(2)(ii) criteria, each criterion is evaluated below:

Criterion 1. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is not installed instrumentation that is used to detect, and indicated in the control room, a significant abnormal degradation of the reactor coolant pressure boundary. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 1.

Criterion 2. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is not a process variable, design feature, or operating restriction that is an initial condition of a design basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 2.

Criterion 3. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product boundary. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 3.

Criterion 4. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is found to be a non-significant risk contributor core damage frequency and offsite releases. The availability of spent E-2

Enclosure to NL-23-0193 Evaluation of the Proposed Change fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool does not contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are found to be important to public health and safety. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 4.

Regarding the appropriate change control process, SNC commits to relocate the Spent Fuel Pool Makeup Water Sources when irradiated fuel assemblies are stored in the spent fuel pool Specification to the VEGP Technical Requirements Manual (TRM) as UFSAR Standard Content, which is controlled in accordance with 10 CFR 50.59 (See Attachment 2). By choosing to relocate this information as UFSAR Standard Content, 10 CFR 52.98(c)(2) applies to future changes.

Conforming changes are proposed to Tier 2 information which references that the availability of the spent fuel pool makeup sources is controlled by the TS. Instead, consistent with the commitment above, the Tier 2 information is proposed to reference the location of the availability controls in the TRM.

It is confirmed that the 10 CFR 50.36(c)(2)(ii) criteria do not apply and that the appropriate change control process applies.

To be complete, SNC also reviewed the rationale in the TS Bases for originally including this requirement in the TS. During NRC review of the AP600 design certification, Westinghouse and NRC held a teleconference on August 28, 1997 (as documented in a September 11, 1997, memo

[ADAMS Accession Number ML20198H542]). The NRC requested that Westinghouse []

determine what technical specification were needed for the PCCS water tank and cask washdown pit to assure that water will be available to supply spent fuel pool makeup. As discussed in NUREG-1793, AP1000 Final Safety Evaluation Report, Section 16.2.10, this function does not satisfy any of the criteria in 10 CFR 50.36(c)(2)(ii), but is included in the TS for defense in depth.

Functions included in TS for defense in depth purposes are more similar to the Regulatory Treatment of Non-Safety Systems discussed in the UFSAR Subsection 1.9.5.3.1, which included the establishment of availability controls in Section 16.3 as formatted into the TRM. Therefore, it is appropriate to relocate this TS to the TRM.

In addition to these requirements relocating to the TRM, shutdown tasks (including the availability of spent fuel pool makeup water sources) are managed using guidance in NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, which has been included in the assessment and management of increases in risk under 10 CFR 50.65(a)(4) for ensuring decay heat removal capability and inventory control (see UFSAR Section 19.7). Thus, shutdown defense-in-depth functions are addressed by the TRM requirement.

4.0 REGULATORY EVALUATION

4.1 Applicable Regulatory Requirements/Criteria 10 CFR 50.36(c)(2)(ii) requires that a Limiting Condition for Operation (LCO) be established in Technical Specifications (TS) for each item meeting one or more of four criteria. LCO 3.7.9 does not meet the criteria for inclusion; therefore, it is relocated from the TS.

1. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is not installed instrumentation that is used to detect, an indicated in the control room, a significant abnormal degradation of the reactor coolant E-3

Enclosure to NL-23-0193 Evaluation of the Proposed Change pressure boundary. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 1.

2. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is not a process variable, design feature, or operating restriction that is an initial condition of a design basis accident (DBA) or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 2.

3. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is not a structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a DBA or transient that either assumes the failure of or presents a challenge to the integrity of a fission product boundary. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 3.

4. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool is found to be a non-significant risk contributor core damage frequency and offsite releases. The availability of spent fuel pool makeup water sources when irradiated fuel assemblies are stored in the spent fuel pool does not contain constraints of prime importance in limiting the likelihood or severity of the accident sequences that are found to be important to public health and safety. The Spent Fuel Pool Makeup Water Sources Specification does not satisfy criterion 4.

Since the 10 CFR 50.36(c)(2)(ii) criteria have not been met, the Spent Fuel Pool Makeup Water Sources Specification when irradiated fuel assemblies are stored in the spent fuel pool may be relocated out of the TS. SNC commits to relocate the Spent Fuel Pool Makeup Water Sources when irradiated fuel assemblies are stored in the spent fuel pool Specification to a document that is controlled in accordance with 10 CFR 50.59.

General Design Criteria (GDC) 61, Fuel Storage and Handling and Radioactivity Control, requires, in part, that fuel storage and handling systems shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety, (2) with suitable shielding for radiation protection, (3) with appropriate containment, confinement and filtering systems, (4) with a residual heat removal capability having reliability and testability that reflect the importance to safety of decay heat and other residual heat removal, and (5) to prevent significant reduction in fuel storage coolant inventory under accident conditions. The relocation of the LCO does not affect compliance with this GDC. The spent fuel pool is designed so that a water level is maintained above the spent fuel assemblies for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> following a loss of the spent fuel pool cooling system, without ac power. Connections to the spent fuel pool are provided at an elevation that prevents inadvertent draining of the water in the pool to an unacceptable level.

GDC 63, Monitoring Fuel and Waste Storage, requires that appropriate systems shall be provided in the fuel storage and radioactive waste systems and associated handling areas (1) to detect conditions that may result in the loss of residual heat removal capability and excessive radiation levels and (2) to initiate appropriate safety actions. The relocation of the LCO does not affect compliance with this GDC. Instrumentation is provided to monitor spent fuel storage pool temperature and water level. Indication and alarms are provided in the main control room.

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Enclosure to NL-23-0193 Evaluation of the Proposed Change 4.2 Precedent While SNC Vogtle 3&4 NRC Amendment No. 13 (ADAMS Accession Number ML13239A287),

Changes R1 and R2, are very similar in technical evaluation process to this change (and other changes like this performed during the adoption of improved standard technical specifications at other plants), no precedent is directly applicable.

4.3 No Significant Hazards Consideration Determination Analysis The proposed amendment relocates TS 3.7.9, Spent Fuel Pool Makeup Water Sources, to the VEGP Technical Requirements Manual (TRM) as UFSAR Standard Content, which is controlled in accordance with 10 CFR 50.59.

SNC has evaluated whether a significant hazards consideration is involved with the proposed amendment 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 change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change relocates an LCO for structures, systems, and components that do not meet the criteria of 10 CFR 50.36(c)(2)(ii) for inclusion in TS. The affected structures, systems, and components are not assumed to be initiators of analyzed events and are not assumed to mitigate accident or transient events. The requirements and Surveillances for these affected structures, systems, and components are proposed to be relocated from the TS to a licensee controlled document that is controlled by the provisions of 10 CFR 50.59. The proposed changes only reduce the level of regulatory control on these requirements. The level of regulatory control has no impact on the probability or consequences of an accident previously evaluated.

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

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

Response: No.

The proposed change does not involve a physical alteration of the plant (no new or different type of equipment will be installed) or change in the methods governing normal plant operation. The proposed change will not impose or eliminate any requirements, and adequate control of existing requirements will be maintained.

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

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Enclosure to NL-23-0193 Evaluation of the Proposed Change 4.3.3 Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The proposed change will not reduce a margin of safety because it has no significant effect on any safety analyses assumptions, as indicated by the fact that the requirements do not meet the 10 CFR 50.36 criteria for retention. In addition, the relocated requirements are moved without change, and any future changes to these requirements will be evaluated per 10 CFR 50.59.

NRC prior review and approval of changes to these relocated requirements, in accordance with 10 CFR 50.92, will no longer be required. There is no margin of safety attributed to NRC prior review and approval. However, the proposed change is consistent with 10 CFR 50.36, which allows revising the TS to relocate these requirements and Surveillances to a licensee controlled document.

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

Based on the above, SNC concludes that the proposed amendment does not involved 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.

4.4 Conclusion In conclusion, 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 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.

5.0 ENVIRONMENTAL CONSIDERATION

S SNC has determined that the proposed amendment would change a requirement with respect to the 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, SNC has evaluated the proposed amendment and has determined that the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed amendment is not required.

6.0 REFERENCES

1. Safety Evaluation by the Office of New Reactors Related to Amendment No. 13 to Combined License Nos. NFP-91 and NFP-92, Vogtle Electric Generating Plant, Units 3 and 4, dated September 9, 2013. [ADAMS Accession Number ML13239A287]

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Enclosure to NL-23-0193 Evaluation of the Proposed Change

2. NRC letter, William C. Huffman to Westinghouse Electric Corporation, Summary of Telephone Conference with Westinghouse to Discuss Proposed Design Changes to the AP600 Main Control Room Habitability System, dated September 11, 1997. [ADAMS Accession Number ML20198H542]

3. Final Safety Evaluation Report Related to Certification of the AP1000 Standard Design (NUREG-1793), Chapter 16, dated September 2004.

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Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)

Attachment 1 Proposed VEGP Units 3 and 4 Licensing Basis Markups to NL-23-0193 Proposed VEGP Units 3 and 4 Licensing Basis Markups Technical Specifications TABLE OF CONTENTS Page 3.5 PASSIVE CORE COOLING SYSTEM (PXS) 3.5.1 Accumulators ............ ... ....... ........... ........................ ... .. .. ............ .............. .... 3.5.1 -1 3.52 Core Makeup Tanks {CMTs) - Operating ............................................... 3.5.2 - 1 3.5.3 Core Makeup Tanks {CMTs) - Shutdown, RCS lntact... .. .......... .... ............. 3 .5.3 - 1 3.5.4 Passive Residual Heat Removal Heat Exchanger (PRHR HX) -

Operating ... .... ........ .......... ......... .... .......... ............................ .................. 3.5.4 - 1 3.5.5 Passive Residual Heat Removal Heat Exchanger (PRHR HX) -

Shutdown, Reactor Coolant System (RCS) lntact... ............................. 3.5.5 - 1 3.5.6 In-containment Refueling Water Storage Tank (IRWST) -

Operating ........................................ ...................................................... 3.5.6 - 1 3.5.7 In-containment Refueling Water Storage Tank (IRWST)-

Shutdown, MODE S....................................... ....................... .......... ...... 3 .5.7 - 1 3.5.8 In-containment Refueling Water Storage Tank (IRWST) -

Shutdown, MODE 6 ........... ................................................. ............ .... .. 3.S.8 - 1 3.6 CONTAJNMENT SYSTEMS 3.6.1 Containment ....... .... .................................................... ................................ 3.6.1 - 1 3.6.2 Containment Air Locks ............. ........ ... ...... .. .................. ................... ........... 3.6.2 - 1 3.6.3 Containment lsolalion Valves ............ ................... .. ................... .. .......... ..... 3 .6.3 - 1 3.6.4 Containment Pressure ..................................... ................. ....... ................... 3.6.4 - 1 3.6.5 Containment Air Temperature .... .............. ................... .. .. ...... ... .. ................ .3.6.5 - 1 3.6.6 Passive Containment Cooling System (PCS) ............ ................................. 3.6.6 - 1 3.6.7 Containment Penetralions ... ... ............... ............... ......... .. ........ ... .. ......... ... .. 3.6.7 - 1 3.6.8 pH Adjus-tment ................... ......................................................................... 3.6.8 -1 3.6.9 Vacuum Relief VaJves .................................. ................ ............................... 3.6.9-1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves (MSSVs) ...... .. .................... ............. ................. 3.7.1 - 1 3.72 Main Steam line Flow Path lsolation Vatves .................. ............................ 3.7.2 - 1 3.7.3 Main Feedwater lsolatioo Valves (MflVs) and Main Feedwater Control Valves (MFCVs) ........ ........ ..... ... ......................................... .. .... 3.7.3 - 1 3.7.4 Secondary Specific Activrty ... .. ............ .. ... .................. ................................. 3.7.4 - 1 3.7.5 Spent Fuel Pool Water level ....... ....... ........ .... ........ ................. .. .. ....... ... .... 3.7.5 - 1 3.7.6 Main Control Room Habitability System (YES) .......................... .. .......... .... 3.7.6 -1 3.7.7 Startup Feedwater Isolation and Control Valves ........ .. ............................... 3.7.7 - 1 3.7.8 Main Steam line Leakage ........ .. .................. .............. .................... ......... ... 3.7.8 - 1 3.7.9 £i,eftt Fttel Peel Meketip 'Nater SeYrces ............. ...... ... ........ ........... ...... ..... 3.7.9 - 1 3.7.10 Steam GeoeratOf (SG) Isolation Valves .................... .. ........................ ... ... 3.7.10-1 3.7.11 3.7.12 3.7.13

~

1 Spent Fuel Pool Boron Concentration ..... ........ ............ .. ........................... 3.7.11 -1 Spent Fuel Pool Storage ....... ....... .......................... ........... .. ... ..... ..... .... 3.7.12 - 1 t Spent Fuel Pool Cooling System (SFS) coo.,;nmen11sc1a0onva1ve, .................. ........ ....... ..... .. ............. n1, . 1 VEGP Units 3 and 4 iii AIR&RGmeAt NG. 15Q (URil J)

-Affieflemertt Ne. 149 (Uflil 4)

A1-1 to NL-23-0193 Proposed VEGP Units 3 and 4 Licensing Basis Markups Technical Specifications Spent Fwel P901 Makewp 'Miler S9'm,ee 3.7.9 1\-

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3.7 PLANTSYSTEMS 3.7.9 Spelu FYEIII PQQI Makewp Watet: So9b1FG88

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J.7.Q 2 A mendmeAI No. 1Je {Unit 3)

Afflefldftleflt Ne. 125 fURit 4)

A1-3 to NL-23-0193 Proposed VEGP Units 3 and 4 Licensing Basis Markups Technical Specifications Spent fwel P891 Makwp !Nater !iiOOFG88 1/4.-7-:9-SURltElbbANGE Fffl:OYENCY 1~ ~ ' lh8 sp@Rt fwel PQQI ~akeup i891&QQR veluee IR acOOfdanGe wiltl PC!ii ~b 11008, Ka Pb \!045 1 PCS Pb 11051 , Sf& tl:ie IA&BQ<iG8 Pl 'lG42, SFS-PL '/045, SFS-PL \.'949, SFS-fll ~~P,egmm VOii, aAd S FS Pl VD66 are OPERAHU: iR aGc:QiQaAGe WRA lh8 IR&en*iG8 Tes&ing Pmgi:alll.

V6GP Unim J 3AG 4 3.7.Q 3 t>mendmSRI t>l8. 12fi (Unit J)

Afflell8ffieftt Ne. 125 ~UHit 4 )

A1-4 to NL-23-0193 Proposed VEGP Units 3 and 4 Licensing Basis Markups UFSAR (plant-specific DCD) Subsection 9.1.3.4.3, Abnormal Conditions is revised in part as follows:

[] The amount of makeup required to provide the 7 day capability depends on the decay heat level of the fuel in the spent fuel pool and is provided as follows:

x When the calculated decay heat level in the spent fuel pool is less than or equal to 4.0 MWt, only the safety-related makeup from the fuel transfer canal is needed to achieve spent fuel pool cooling for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

x When the calculated decay heat level in the spent fuel pool is greater than 4.0 MWt and less than or equal to 5.0 MWt, safety related makeup from the fuel transfer canal and cask washdown pit is sufficient to achieve spent fuel pool cooling for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. A minimum level of 13.75 feet in the cask washdown pit is provided for this purpose.

Availability of the makeup source is controlled by technical specifications technical requirements manual.

x When the calculated decay heat level in the spent fuel pool is greater than 5.0 MWt and less than or equal to 7.0 MWt, safety-related makeup from the fuel transfer canal, cask washdown pit and cask loading pit is sufficient to achieve spent fuel pool cooling for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. A minimum level of 13.75 feet in the cask washdown pit and 43.9 feet in the cask loading pit is provided for this purpose. Availability of the makeup sources is controlled by technical specifications technical requirements manual.

x When calculated decay heat level in the spent fuel pool is greater than 7.0 MWt makeup from the passive containment cooling water storage tank or passive containment cooling ancillary water storage tank, or combination of the two tanks, is sufficient to achieve spent fuel pool cooling for at least 7 days.

x When the decay heat level in the reactor is less than or equal to 7.0 MWt, the passive containment cooling water storage tank is not needed for containment cooling and this water can be used for makeup to the spent fuel pool. This tank provides safety related makeup for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Between 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> and 7 days the tank continues to provide makeup water as required until it is empty. If the passive containment cooling water storage tank empties in less than 7 days, non-safety makeup water can be provided from the passive containment cooling ancillary water storage tank.

x When the decay heat level in the reactor is greater than 7.0 MWt, the water in the passive containment cooling water storage tank is reserved for containment cooling.

Safety related spent fuel pool cooling is provided for at least 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> from the pool itself and makeup water from the cask washdown pit and cask loading pit. After 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, non-safety related makeup can be provided from the passive containment cooling ancillary water storage tank.

x Minimum volume in the passive containment cooling water storage tank for spent fuel pool makeup is 756,700 gallons. Availability of this makeup source for the first 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> is controlled by technical specifications technical requirements manual. Minimum volume in the passive containment ancillary water storage tank for spent fuel pool makeup is 201,600 gallons. []

A1-5

Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)

Attachment 2 Regulatory Commitment to NL-23-0193 Regulatory Commitment The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions. They are provided for information purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENTs DUE DATE / EVENT SNC commits to relocate the Spent Fuel Pool Makeup Water Sources Within 90 days of when irradiated fuel assemblies are stored in the spent fuel pool issuance of this Specification to the VEGP Technical Requirements Manual (TRM) as Amendment UFSAR Standard Content, which is controlled in accordance with 10 CFR 50.59.

A2-1

Southern Nuclear Operating Company Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment:

Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)

Attachment 3 Proposed VEGP Units 3 and 4 Technical Specifications Changes (Clean Pages) to NL-23-0193 Proposed VEGP Units 3 and 4 Technical Specifications Changes (Clean Pages)

Technical Specifications TABLE OF CONTENTS Page 3.5 PASSIVE CORE COOLING SYSTEM (PXS) 3.5.1 Accumulators ............................................ ........... .......... ............................. 3.5.1 - 1 3.5.2 Core Makeup Tanks (CMTs)- Operating ............................. ........ .............. 3.5.2 - 1 3.5.3 Core Makeup Tanks (CMTs) - Shutdown, RCS tntact... ... ......... ................. 3.5.3 - 1 3.5.4 Passive Residual Heat Removal Heat Exchanger (PRHR HX) -

Operating ............. ......... ................................................. ....................... 3.5.4 - 1 3.5.5 Passive Residual Heat Removal Heat Exchanger {PRHR HX) -

Shutdown, Reactor Coolant System {RCS) lntact .... ............................ 3.5.5 - 1 3.5.6 In-containment Refueling Water Storage Tank (tRWST ) -

Operating ............ ..........................................*... .. .............. .................... 3.5.6 - 1 3.5.7 In-containment Refuerrng Water Storage Tank (lRWST ) -

Shutdown, MOOE 5 ........ .............................................. ........................ 3.5.7 - 1 3.5.8 In-containment Refueling Water Storage Tank (IRWST } -

Shutdown, MOOE 6 ................................................................. ............. 3.5.8 - 1 3.6 CONTAJNMENTSYSTEMS 3.6.1 Containment ........... ...................................................... .............................. 3.6.1 - 1 3.6.2 Containment Air Lod<s ........................... ... .. ............................................... 3.6.2 - 1 3 .6.3 Containment Isolation Valves .... ... ........................................ ...................... 3.6.3 - 1 3.6.4 Containment Pressure .......................... ... ................................................... 3 .6.4 -1 3.6.5 Containment Air Temperature .... .................................. ............................... 3.6.5 - 1 3.6.6 Passive Containment Cooling System (PCS) ............................................. 3.6 .6 - 1 3.6.7 Containment Peoetrations ......... ............................................ ......... ............ 3.6.7 -1 3.6.8 pH Adjustment ..... ...................... ............................................. .. ................. . 3 .6 .8 - 1 3.6.9 Vacuum Relief VaJ-ves ............................................... .. .............. .................. 3.6 .9 - 1 3.7 PLANT SYSTEMS 3.7.1 Main Steam Safety Valves {MSSVs) ............... ..... ................ ...................... 3.7.1 -1 3.7.2 Main Steam Line Flow Path Isolation Valves .............................................. 3 .7 .2 - 1 3.7.3 Main Feedwater Isolation Valves {MFIVs) and Main Feedwater Control Valves (MFC\/s) ....................................................... ............... 3.7 .3 - 1 3.7.4 Secondary Specific Activity ........... .......... .................................. .................. 3.7.4- 1 3.7.5 Spent Fuel Poo Water Level **********************************************************************3 .7.5 - 1 3.7.6 Main Control Room Habitability System (\/ES) ..........................................3 .7.6 - 1 3.7.7 Startup Feedwa.ter Isolation and Control Valves .... .. .................................. 3.7.7 -1 3.7.8 Main Steam Line Leakage **** ***** ** *********** ******** *********** ***************************-****3.7.8 -1 3.7.9 Not Used ...................................................................... .............. ................ 3 .7.9 - 1 3.7.10 Steam Generator {SG) Isolation Valves ........ ......................... .................. 3.7.10 - 1 3.7.11 Spent FueJ Poo Boron Concentration ........................................ .............. 3.7.11 -1 3 .7.1 2 Spent Fuel Poo Storage****** ******** ************ **** ************** ********** ******************* 3.7.12 - 1 3.7.13 Spent Fuel Poo Cooling System (SFS)

Containment Jsolation Valves ... ................. ......................................... 3.7.13 - 1 VEGP Units 3 and 4 iii Amendment No.X:XX (Unit 3)

Amendment No.XXX (Unit 4)

A3-1 to NL-23-0193 Proposed VEGP Units 3 and 4 Technical Specifications Changes (Clean Pages)

Technical Specifications Not Used 3.7.9 3.7 PlANT SYSTEMS 3.7.9 Not Used VEGP Units 3 and 4 3.7.9 - 1 Amendment No. _ (Unit 3)

Amendment No. _ (Unit 4)

A3-2