ML18159A443
| ML18159A443 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/12/2018 |
| From: | Manny Comar NRC/NRO/DNRL/LB4 |
| To: | Whitley B Southern Nuclear Operating Co |
| comar m/415-3863 | |
| Shared Package | |
| ML18159A437 | List: |
| References | |
| EPID L- 2018-LLA-0018, LAR 18-004 | |
| Download: ML18159A443 (8) | |
Text
SAFETY EVALUATION BY THE OFFICE OF NEW REACTORS RELATED TO AMENDMENT NOS. 133 AND 132 TO THE COMBINED LICENSE NOS. NPF-91 AND NPF-92 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026
1.0 INTRODUCTION
By letter dated January 31, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18031B131), as supplemented by letter dated May 2, 2018 (ADAMS Accession No. ML18122A132), Southern Nuclear Operating Company (SNC) requested that the U.S. Nuclear Regulatory Commission (NRC) amend the combined licenses (COL) for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, COL Numbers NPF-91 and NPF-92, respectively. The License Amendment Request (LAR)18-004 requested changes to COL Appendix A, Technical Specifications (TS) related to pressurizer safety valve (PSV) operability.
The requested amendment proposes changes to COL Appendix A. Two groups of changes are proposed. In the first group of changes the requested amendment proposes changes to TS 3.4.6, PSV, Applicability to require the PSVs to be operable when TS 3.4.14, Low Temperature Overpressure Protection (LTOP), is not required to be operable. Conforming changes to the TS 3.4.6 Actions are also proposed. In the second group of changes the requested amendment proposes moving TS Limiting Condition for Operation (LCO) Notes stating No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures, from TS 3.4.4, Reactor Coolant System (RCS) Loops, 3.4.8, Minimum RCS Flow, and TS 3.4.14 to TS 3.4.3 RCS Pressure / Temperature (P/T) Limits.
The supplement dated May 2, 2018, provided additional information that clarified the application, did not expand the scope of the application as originally noticed and did not change the NRC staffs original proposed no significant hazard consideration determination as published in the Federal Register on March 13, 2018 (83 FR 10922).
2.0 REGULATORY EVALUATION
The NRC staff considered the following regulatory requirements in reviewing SNCs proposed license amendment request (LAR).
Title 10 of the Code of Federal Regulations (10 CFR) 52.98(f) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL. This activity involves changes to COL Appendix A, TS. Therefore, this activity requires an amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this LAR.
10 CFR 52, Appendix D, Section VIII.C.6 states that after issuance of a license, Change to the plant-specific TS will be treated as license amendments under 10 CFR 50.90. 10 CFR 50.90 addresses the application for amendments of licenses, construction permits, and early site permits. The proposed LAR requires changes in the TS and therefore a LAR is required to be submitted for NRC approval.
10 CFR 50.36, TS impose limits, operating conditions, and other requirements upon reactor facility operation for the public health and safety. The TS are derived from the analyses and evaluations in the safety analysis report. In general, TS must contain: (1) safety limits and limiting safety system settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls 10 CFR 50, Appendix A, General Design Criteria for Nuclear Power Plants General Design Criterion (GDC) 14 - Reactor coolant pressure boundary, the reactor coolant pressure boundary shall be designed, fabricated, erected, and tested so as to have an extremely low probability of abnormal leakage, of rapidly propagating failure, and of gross rupture.
10 CFR 50, Appendix A, GDC 30 - Quality of reactor coolant pressure boundary, components which are part of the reactor coolant pressure boundary (RCPB) shall be designed, fabricated, erected, and tested to the highest quality standards practical. Means shall be provided for detecting, and to the extent practical, identifying the location of the source of reactor coolant leakage.
3.0 TECHNICAL EVALUATION
3.1 TECHNICAL EVALUATION
OF REQUESTED CHANGES The proposed changes to COL Appendix A, TS are related to PSV operability in two general ways. Specifically, the requested amendment proposed the following.
The first set of changes are to establish consistency related to the applicability of TS that address PSV operability. A revision is proposed to TS 3.4.6 to require the PSVs to be operable when TS 3.4.14 is not required to be operable. The PSV applicability is proposed to be Modes 1, 2, and 3, and Mode 4 when all four cold leg temperatures are > 275°F. A conforming change to the TS 3.4.6 Actions is also proposed. In addition, conforming changes are made to: TS 3.3.8, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, Table 3.3.8-1 (including an editorial change); TS 3.3.9, ESFAS Manual Initiation, Table 3.3.9-1; TS 3.3.15, ESFAS Actuation Logic - Operating, Surveillance Requirement (SR) Note; TS 3.4.4 LCO Note 1 deleted; TS 3.4.5, Pressurizer, Applicability and Actions are revised; TS 3.4.8 LCO Note 2 deleted; TS 3.4.14 LCO Note 1 deleted; and, TS 3.4.16, Reactor Vessel Head Vent, Applicability and Actions are revised.
The second set of changes move TS LCO Notes stating No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each SG is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25 percent of RCP speed from TS 3.4.4, 3.4.8, and 3.4.14, to TS 3.4.3 to be consistent and concise in stating TS requirements.
3.
1.1 TECHNICAL EVALUATION
OF THE FIRST SET OF REQUESTED CHANGES In LAR 18-004, SNC requested changes to TS 3.4.6 Applicability to require the PSVs to be operable when TS 3.4.14 does not require PSVs to be operable. PSVs provide overpressure protection of the RCS during power operation is provided by the PSVs, in conjunction with the action of the reactor protection system. This combination is compliant with the overpressure protection requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel Code, Section III. However, with any RCS cold leg 275°F, LTOP is provided by relief valves in the suction line of the normal residual heat removal system (RNS). During Modes 1, 2, and 3, and Mode 4 when the RNS is isolated or when RCS temperature is 275°F, the PSVs provide overpressure protection, as required by TS 3.4.6. TS 3.4.14 LCO is required in Mode 4 when any cold leg temperature is 275°F, Mode 5, and Mode 6 when the reactor vessel head is on.
In a request for additional information (RAI) provided to SNC on April 2, 2018, the NRC staff requested that SNC indicate whether any changes in the performance requirements or operating conditions are necessary for the PSVs or any other valves for the implementation of LAR 18-004. On May 2, 2018, SNC responded to the RAI by submitting a supplement to LAR 18-004 (ADAMS Accession No. ML18122A132). In the LAR 18-004 supplement, SNC stated that there are no changes necessary to the performance requirements or operating conditions for the PSVs or any other valves for the implementation of LAR 18-004. SNC noted that LAR-18-004 proposes changes to TS 3.4.6 Applicability for Mode 4 from MODE 4 with RNS isolated or RCS temperature 275°F. to MODE 4 with all four cold leg temperatures > 275°F. SNC indicated and the staff confirmed that the proposed change will align the Mode 4 applicability of TS 3.4.6 with TS 3.4.14. Although these changes impose operational restrictions different from those previously defined, SNC specified that the PSVs and other valves, including the LTOP valves, will continue to operate within the requirements of the design specifications and meet the performance requirements specified in the system specifications and TS with no necessary modifications to the valves.
As part of the COL application review for VEGP Units 3 and 4, the NRC staff accepted the performance requirements and conditions for the qualification of the PSVs, as incorporated by reference for the AP1000 certified design, in accordance with ASME Standard QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants. In NUREG-2124, Final Safety Evaluation Report Related to the Combined Licenses for Vogtle Electric Generating Plant, Units 3 and 4, the staff found ASME Standard QME-1-2007 to be acceptable based on its endorsement in NRC Regulatory Guide 1.100 (Revision 3), Seismic Qualification of Electrical and Active Mechanical Equipment and Functional Qualification of Active Mechanical Equipment for Nuclear Power Plants.
The specific TS changes proposed in LAR 18-004 to impose comprehensive, consistent and concise requirements for over-pressure protection for all Modes , specifically a revision to TS 3.4.6 to require the PSVs to be operable when TS 3.4.14 does not require PSVs to be operable, and conforming changes to the following: TS 3.4.6 Actions; TS 3.3.8; Table 3.3.8-1; Table 3.3.9-1; TS 3.3.15 SR Note; TS 3.4.4 LCO Note 1; TS 3.4.5 Applicability and Actions; TS 3.4.8 LCO Note 2; TS 3.4.14 LCO Note 1; and TS 3.4.16 Applicability and Actions, are found acceptable by the NRC staff because the affected valves will continue to operate within the requirements of the design specifications and meet the performance requirements specified in the system specifications and TS.
3.
1.2 TECHNICAL EVALUATION
OF THE SECOND SET OF REQUESTED CHANGES In LAR 18-004, SNC states and the staff confirms that the LCOs in TS 3.4.4, 3.4.8, and 3.4.14 each contain a Note that puts a restriction on RCP starts based on RCS cold leg temperature and secondary side water temperature. The Note reads:
No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each steam generator (SG) is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25% of RCP speed.
SNC states that, as described in the TS 3.4.4 Bases, the purpose of this restriction is to prevent a low temperature overpressure event due to a thermal transient when an RCP is started. The limitation helps to ensure that the RNS pressure is below both the piping design pressure and the acceptable RNS relief valve inlet pressure.
The staff finds that in order to simplify the TS, remove redundancy, and enforce the Note restriction in the intended plant conditions, the Note regarding RCP start restrictions is proposed to be moved to the TS 3.4.3 LCO. The applicability of this TS is At all times, which means that the relocated Note will maintain the intended restrictions on RCP start as stated in the Notes.
This removes redundancy in the TS. Furthermore, the current TS 3.4.4, 3.4.8, and 3.4.14 Actions do not have appropriate compensatory measures should an RCP be started outside the stated limitations. The TS 3.4.3 Actions with the proposed change would require restoration of the limitation, and an evaluation to determine that the RCS is acceptable for continued operation. The staff finds that the proposed change to remove the Note from the LCOs for TS 3.4.4, 3.4.8, and 3.4.14 and add the Note to the TS 3.4.3 LCO is a more restrictive change. The staff finds that the same LCO restrictions continue to apply for RCP starts, however, they are proposed to apply in a more complete range of applicability.
Therefore, the specific TS changes proposed in LAR 18-004 to impose comprehensive, consistent and concise requirements for RCP starting, specifically a relocation of TS LCO Notes stating No RCP shall be started with any RCS cold leg temperature 350°F unless the secondary side water temperature of each SG is 50°F above each of the RCS cold leg temperatures and the RCP is started at 25 percent of RCP speed from TS 3.4.4, 3.4.8, and 3.4.14, to TS 3.4.3 to be consistent and concise in stating TS requirements, are is found acceptable by the staff. In addition the staff finds that the TS changes meet the requirements of 10 CFR 50.36.
As discussed in the evaluation above, the staff finds the changes proposed by SNC are consistent with regulatory requirements and are acceptable. In addition, the proposed TS Bases changes are consistent with the TS changes. The staff finds the proposed changes in LAR 18-004 for the PSV operability to continue to satisfy GDC 14, GDC 30, and 10 CFR 50.36 because the performance requirements and operating conditions of the PSVs remain consistent with the VEGP Units 3 and 4 COLs and the certified AP1000 design.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations in 10 CFR 50.91(b) (4), the Georgia State official was notified of the proposed issuance of the amendment on May 25, 2018. The State official had no comment.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20, Standards for Protection Against Radiation. The NRC staff has determined that the amendment involves no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendment involves no significant hazards consideration, and there has been no public comment on such finding (dated March 13, 2018 (83 FR 10922)). Accordingly, the amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
6.0 CONCLUSION
Based on the technical evaluation presented in Section 3.0 above, the staff has concluded that:
(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the 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, the staff finds the changes proposed in this LAR are acceptable.
7.0 REFERENCES
- 1. Vogtle Electric Generating Plant Units 3 and 4 - Request for License Amendment:
Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004), dated January 31, 2018. (ADAMS Accession No. ML18031B131).
- 2. Vogtle Electric Generating Plant Units 3 and 4 - Supplement to Request for License Amendment: Technical Specification Applicability Changes to Support Pressurizer Safety Valve Operability (LAR-18-004S1), dated May 2, 2018. (ADAMS Accession No. ML18122A132).
- 3. Combined License NPF-91 for Vogtle Electric Generating Plant Unit 3, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A106).
- 4. Combined License NPF-92 for Vogtle Electric Generating Plant Unit 4, Southern Nuclear Operating Company (ADAMS Accession No. ML14100A135).
- 5. and Active Mechanical Equipment and Functional Qualification of Active NRC Regulatory Guide 1.100 (Revision 3), Seismic Qualification of Electrical Mechanical Equipment for Nuclear Power Plants. (ADAMS Accession No. ML091320468).
- 6. American Society of Mechanical Engineers Standard QME-1-2007, Qualification of Active Mechanical Equipment Used in Nuclear Power Plants