ND-18-1403, Request for License Amendment and Exemption: Editorial and Consistency Changes (LAR-18-027)

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Request for License Amendment and Exemption: Editorial and Consistency Changes (LAR-18-027)
ML18324A823
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 11/20/2018
From: Aughtman A
Southern Nuclear Operating Co
To:
Document Control Desk, Office of New Reactors
References
ND-18-1403
Download: ML18324A823 (39)
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{{#Wiki_filter:A. G. Aughtman Southern Nuclear Manager Operating Company, Inc. Licensing 3535 Colonnade Parkway Birmingham, AL 35243 Tel 205.992.7006 November 20, 2018 Docket Nos.: 52-025 ND-18-1403 52-026 10 CFR 50.90 10 CFR 52.63 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 and Exemption: Editorial and Consistency Changes (LAR-18-027) 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 Tier 2 information in the Updated Final Safety Analysis Report (UFSAR) (which includes the plant-specific DCD Tier 2 information) and involves related changes to plant-specific Tier 1 information, with corresponding changes to the associated COL Appendix C information. The requested amendment also proposes changes to the COL Appendix A Technical Specifications. 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. The requested amendment proposes changes to UFSAR Tier 2 information, COL Appendix C (and plant-specific Tier 1), and COL Appendix A (Technical Specifications) that are editorial in nature to promote consistency within the licensing basis. provides the detailed description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed changes in the License Amendment Request (LAR). provides the background and supporting basis for the requested exemption. identifies the requested changes and provides markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents. provides the conforming changes to the Technical Specifications Bases for information only. This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security-related information.

U.S. Nuclear Regulatory Commission ND-18-1403 Page 2 of 4 SNC requests NRC staff approval of the requested amendment and exemption by May 20, 2019 to support closure of the associated VEGP Units 3 and 4 Inspections, Tests, Analyses and Acceptance Criteria (ITAAC). Approval by this date will allow sufficient time to implement the licensing basis changes prior to the associated IT AAC activity. SNC expects to implement this proposed amendment within 30 days of approval of the requested changes. 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. Should you have any questions, please contact Mr. Ryan Henderson at (205) 992-6426. I declare under penalty of perjury that the foregoing is true and correct. Executed on the 201h of November 2018. Respectfully submitted, Amy G. Aughtman Manager, Licensing Southern Nuclear Operating Company

Enclosures:

1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4-Request for License Amendment: Editorial and Consistency Changes (LAR-18-027)
2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Exemption Request:

Editorial and Consistency Changes (LAR-18-027} 3} Vogtle Electric Generating Plant (VEGP) Units 3 and 4-Proposed Changes to Licensing Basis Documents (LAR-18-027)

4) Vogtle Electric Generating Plant (VEGP) Units 3 and 4-Conforming Changes to the Technical Specifications Bases (For Information Only)

(LAR-18-027)

U.S. Nuclear Regulatory Commission ND-18-1403 Page 3 of 4 cc: 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. Yox Mr. C. T. Defnall Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. E. Riffle Ms. K. Roberts Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures) Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker 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

U.S. Nuclear Regulatory Commission ND-18-1403 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. L. Oriani (w/o enclosures) Mr. C. Churchman (w/o enclosures) Mr. M. Corletti Mr. M. L. Clyde Ms. L. Iller Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc. Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc. Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-18-1403 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) (This Enclosure consists of 15 pages, including this cover page)

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 2 of 15 Table of Contents

1.

SUMMARY

DESCRIPTION

2.

DETAILED DESCRIPTION and TECHNICAL EVALUATION

3.

TECHNICAL EVALUATION (Incorporated into Section 2, above)

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.

REFRENCES

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 3 of 15 Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC, or the 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 to depart from Tier 2 information in the Updated Final Safety Analysis Report (UFSAR) (which includes the plant-specific DCD Tier 2 information) and involves changes related to plant-specific Tier 1 information, with corresponding changes to the associated COL Appendix C information. The requested amendment also proposes changes to the COL Appendix A Technical Specifications. The requested amendment proposes changes to UFSAR information, COL Appendix C and associated information in plant-specific Tier 1, and COL Appendix A Technical Specifications that are editorial in nature to promote consistency within the licensing basis. This enclosure requests approval of the license amendment necessary to implement the UFSAR, COL Appendix C, and COL Appendix A changes. Enclosure 2 requests the exemption necessary to implement the involved changes to the plant-specific Tier 1 information.

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION Design descriptions in the Updated Final Safety Analysis Report (UFSAR) are derived from plant design documents. 10 CFR 52, Appendix D, Section II.D states that Tier 1 design information is derived from Tier 2 information. However, certain specific occurrences have been identified in which COL Appendix C (and associated plant-specific Tier 1) information is not consistent with its associated UFSAR (plant-specific DCD) information. Instances of inconsistency have also been identified in the Technical Specifications. The editorial and consistency changes described below are being made to enhance reader understanding of the information already included in the licensing basis.
1. Grounding and Lightning Protection System (EGS) Acronym COL Appendix C (and associated plant-specific Tier 1) Section 1.4 provides the list of acronyms and abbreviations. For EGS, it defines the acronym as Grounding and Lightening Protection System. However, this is inconsistent with COL Appendix C Section 2.6.6 and the UFSAR which defines EGS as the Grounding and Lightning Protection System. Therefore, it has been determined that Lightening was a typographical error and it is proposed to be changed to Lightning to promote a consistent spelling of the acronym within the licensing basis.
2. COL Appendix C Figure 2.2.1-1 Label COL Appendix C Figure 2.2.1-1 shows the Containment System (CNS) piping and instrument diagram. The figure represents the functional diagram of the CNS and is not meant to be indicative of the scale, location, dimensions, shape, or spatial relationships of as-built structures, systems, and components. During implementation of Amendment No. 125 for Vogtle Unit 3 and No. 124 for Vogtle Unit 4 [ADAMS Accession Number ML18106A626], the label for the figure was inadvertently left off. Therefore, it is proposed to add the label back to the figure which states, Figure 2.2.1-1 Containment System. No other changes are proposed to the figure. No change to plant-specific Tier 1 is necessary.

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 4 of 15

3. COL Appendix C Figure 2.3.7-1 Legibility COL Appendix C Figure 2.3.7-1 shows the Spent Fuel Pool Cooling System (SFS) piping and instrument diagram. The figure represents the functional diagram of the SFS and is not meant to be indicative of the scale, location, dimensions, shape, or spatial relationships of as-built structures, systems, and components. The figure is not currently legible in the Vogtle Unit 3 or Unit 4 COL Appendix C. Therefore, it is proposed to replace the figure with a legible version in order to facilitate closure of related inspections, tests, analyses and acceptance criteria (ITAAC). No other changes are proposed to the figure.

The legible portions of the figure were compared with the corresponding plant-specific Tier 1 figure and the plant-specific DCD figure to confirm that they depicted the same information. No change to plant-specific Tier 1 is necessary.

4. Design Commitment for Table 2.3.9-3 Item 4.b COL Appendix C (and associated plant-specific Tier 1) Table 2.3.9-3 Item 4.b states, The components identified in Table 2.3.9-2 perform the listed function after receiving manual a signal from DAS [Diverse Actuation System]. This sentence structure is confusing as written and inconsistent with the language in Item 4.b in Subsection 2.3.9 Design Description. In order to make the language consistent within the licensing basis and ensure the sentence is understandable, Item 4.b in Table 2.3.9-3 is proposed to state, The components identified in Table 2.3.9-2 perform the listed function after receiving a manual signal from DAS.
5. Equipment Number in Table 2.3.11-2 Item 3.a COL Appendix C (and associated plant-specific Tier 1)Table 2.3.11-2 Item 3.a) shows the equipment numbers for the Gaseous Radwaste System (WGS) Activated Carbon Delay Beds as WGS-MV02A and WGS-MV02B. COL Appendix C Table 2.3.11-1 (and Note 1),

Table 2.3.11-3, and Figure 2.3.11-1 show the equipment numbers correctly as WGS-MV-02A and WGS-MV-02B. Therefore, it is proposed to correct the equipment numbers to provide consistency within the licensing basis. A corresponding change is required to UFSAR (plant-specific DCD) Tier 2 information in Table 9.3.3-2, Item 30, and is involved with the proposed Tier 1 change. This Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) for Vogtle Unit 3 and Unit 4 are already closed (ADAMS Accession Number ML14322A395 and ML15211A138, respectively, and published in the Federal Register [83 FR 34890] on July 23, 2018), but this editorial change has no material impact to the ITAAC Closure Notification as previously submitted. Resubmittal and republishing in the Federal Register is not required. The editorial change is provided for consistency within the licensing basis.

6. Design Commitment for Section 2.5.2 Item 14 COL Appendix C (and associated plant-specific Tier 1) Design Description Item 14 and plant-specific Tier 1 Table 2.5.2-8 Item 14 states, The Component Interface Module CIM) is developed using a planned design process which provides for specific design documentation and reviews. It is standard practice to have open and closed parentheses for an acronym following a proper noun. It is also consistent with COL Appendix C

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 5 of 15 Table 2.5.2-8 Item 14 to add an open parenthesis for the acronym. Therefore, it is proposed that an open parenthesis be added for the acronym. The ITAAC for Vogtle Unit 3 and Unit 4 are already closed (ADAMS Accession Number ML17143A239 and ML17143A244, respectively, and published in the Federal Register [82 FR 55658] on November 22, 2017), but this editorial change has no material impact to the ITAAC Closure Notification as previously submitted. Resubmittal and republishing in the Federal Register is not required.

7. Figure 2.6.1-1 (Sheet 1 of 4) Label Editorial Correction COL Appendix C Figure 2.6.1-1 shows the main ac power system (ECS) one-line drawing.

The figure represents the functional diagram of the ECS and is not meant to be indicative of the scale, location, dimensions, shape, or spatial relationships of as-built structures, systems, and components. The label for Sheet 1 of the Figure states, Main ac Power Syste but should state Main ac Power System. The change is considered editorial in nature to improve readability of the licensing basis to facilitate closure of related ITAAC. No change to plant-specific Tier 1 is necessary.

8. Design Description/Commitment in Section 2.6.3 COL Appendix C (and associated plant-specific Tier 1) Section 2.6.3 Design Description (and Table 2.6.3-3 Design Commitment) Item 4.b) states, The IDS [Class 1E dc and Uninterruptible Power Supply System] provides electrical isolation between the non-Class 1E ac power system and the non-Class 1E lighting in the MCR [Main Control Room]. This language is unclear in that a possible reading of this sentence could suggest that the electrical isolation is between the non-Class 1E ac power system and the non-Class 1E lighting in the MCR. However, the purpose of this section of COL Appendix C is to provide inspections, tests, and analyses of the IDS. The non-Class 1E ac power system and non-Class 1E lighting in the MCR are not part of the IDS. The intended meaning of this sentence is that electrical isolation is provided between the IDS and the non-Class 1E ac power system and that electrical isolation is provided between the IDS and the non-Class 1E lighting in the MCR. The described electrical isolation prevents faults from propagating from the non-Class 1E lighting and non-Class 1E power system into the Class 1E power system. This described configuration is supported, in part, by UFSAR Subsection 8.3.2.1.1 which describes the electrical isolation provided by the battery chargers, by UFSAR Subsection 9.5.3.2 which describes the electrical isolation provided by two series fuses for the MCR lighting, and by UFSAR Subsection 9.4.1.1.1 which describes the electrical isolation provided by two series fuses between the regulating transformers and the ancillary fan circuits.

Therefore, it is proposed to change the Design Description and Commitment to state, The IDS provides electrical isolation between itself and the non-Class 1E ac power system and the non-Class 1E lighting in the MCR. This language makes the intended meaning clearer for the purposes of implementing the ITAAC. Uncompleted ITAAC Notification (ADAMS Accession Number ML17332A068) re-submittal will not be required since the methodology of closure is unaffected by this change.

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 6 of 15

9. Design Commitment for Table 2.6.6-1 The Design Commitment for Table 2.6.6-1 states, in part, The EGS provides an electrical grounding system for: [] (2) electrical system grounding of the neutral points of the main generator, main step-up transformers, auxiliary transformers, load center transformers, auxiliary and onsite standby diesel generators []. However, the Design Description for COL Appendix C (and associated plant-specific Tier 1) Section 2.6.6 states, in part, The EGS provides an electrical grounding system for: [] (2) electrical system grounding of the neutral points of the main generator, main step-up transformers, auxiliary transformers, load center transformers, and onsite standby diesel generators [].

UFSAR Subsection 8.3.1.1.7 contains the same information as described in the Design Description for COL Appendix C Section 2.6.6. Additionally, there are no components named auxiliary diesel generators for VEGP 3&4. The list of components in this section is not meant to be wholistic of all equipment connected to EGS. EGS continues to provide electrical grounding during normal and off-normal conditions. Therefore, it is proposed to delete auxiliary from the Design Commitment in Table 2.6.6-1 to make it consistent with the Design Description and UFSAR.

10. Control Function of Ancillary Fans in Table 2.7.1-3 COL Appendix C (and associated plant-specific Tier 1) Table 2.7.1-4 Item 12 (consolidated in COL Index Number 700 / ITAAC Number 2.7.01.14) requires that controls exist in the MCR to cause the components identified in Table 2.7.1-3 to perform the listed function. The MCR Ancillary Fans (VBS-MA-10A / VBS-MA-10B), the Division B Room Ancillary Fan (VBS-MA-11), and the Division C Room Ancillary Fan (VBS-MA-12) listed control function is to Run; however, there are no controls in the MCR which cause these components to Run.

As described in UFSAR (plant-specific DCD) Subsection 9.4.1.2.3, the power supply to the ancillary fans is from the respective division B or C regulating transformers which receive power from the ancillary diesel generators. UFSAR Subsection 9.4.1.1 states that the ancillary fan circuits are disconnected from the supply with manual normally-open switches. These switches are local to the fans in the rooms in which they are needed, so not all switches are located in the MCR. Therefore, it is not possible to complete the ITAAC as written for these components. Additionally, the control function of the rest of the components in COL Appendix C Table 2.7.1-3 is to Start, so it appears that it was always intended that the method of confirming the proper installation and operation of this equipment was meant to be different. It is proposed that the Control Function for VBS-MA-10A, VBS-MA-10B, VBS-MA-11, and VBS-MA-12 be left blank (denoted by a dash) to demonstrate that there is no control in the MCR which causes the components to operate. The components will continue to be verified to have been installed and operate correctly in other ITAAC (including the functional arrangement, location, and that they start and run). Additionally, the fans will be required to pass Surveillances in the Technical Requirements Manual and be determined to be functional. The function of the ancillary fans for the nuclear island nonradioactive ventilation system (VBS) to provide post-72-hour ventilation to the MCR and

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 7 of 15 instrumentation and control rooms is not affected by this change to the Control Function and is consistent with the design of the plant.

11. Fire Area 1220 AF 02 Location in Auxiliary Building in Table 3.3-3 Fire Area 1220 AF 02 is shown in COL Appendix C (and associated plant-specific Tier 1)

Table 3.3-3 as being located in the Auxiliary Building Non-Radiologically Controlled area. However, as shown in UFSAR Subsection 9A.3.1.3.1.4, this fire area includes Room No. 12244 and is serviced by the radiologically controlled ventilation system. UFSAR Table 9A-4 shows Fire Area 1220 AF 02 as being part of the Radiologically Controlled Area. UFSAR Table 3D.5-1 shows Room No. 12244 as being part of Zone 7 - Auxiliary Building - Radiological - Accessible. Therefore, it is proposed to change the table to show Fire Area 1220 AF 02 as part of the Auxiliary Building Radiologically Controlled area. There is no adverse impact to the equipment qualification, separation, or independence of equipment in the subject fire area or adjacent fire areas due to this change. The change is consistent with information in other portions of the licensing basis. Uncompleted ITAAC Notification (ADAMS Accession Numbers ML18177A122, ML18177A099, ML18100A030, and ML18177A057) re-submittal will not be required since the methodology of closure is unaffected by this change.

12. Technical Specification 3.4.12 CONDITION D Consistency Change Technical Specification 3.4.12, ADS - Shutdown, RCS Intact, requires that a prescribed number of Automatic Depressurization System (ADS) flow paths be OPERABLE depending on how long the reactor has been subcritical. LAR-17-027 (approved as Amendment No. 118 for Vogtle Unit 3 and Amendment No. 117 for Vogtle Unit 4) [ADAMS Accession Number ML18075A094], in part, changed the ADS valve availability to accommodate RCS vacuum refill. As described in LAR-17-027, CONDITION D ensures all possible combinations of conditions are addressed under the Limiting Condition for Operation (LCO). One of the conditions is Three or more flow paths in ADS stage 1, 2, and 3 inoperable. The change to this condition, as explained in LAR-17-027, was to address the intent of former CONDITION C. The former CONDITION C referred to the number of required ADS flow paths and the omission of the word required was unintentional in the LAR-17-027 markup. The condition is proposed to be rewritten as Three or more required flow paths in ADS stage 1, 2, and 3 inoperable.

As discussed in the Writers Guide for Plant-Specific Improved Technical Specifications, TSTF-GG-05-01, subsection 4.1.3 paragraph b, required is specifically used to denote reference to equipment which is required by the LCO for the specific existing APPLICABILITY. In cases where the LCO only requires some of all possible components be used to satisfy the LCO requirement, then the clarification of required is used. In the case of the context of the change approved in Amendment Nos. 118 and 117, it is apparent that the intent of the change was to refer to the flow paths required under the LCO and not any three flow paths. As discussed in Amendment Nos. 118 and 117, the safe shutdown analysis continues to demonstrate the plant complies with its licensing performance criteria to cool the RCS to 420°F within 36 hours.

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 8 of 15

13. Technical Specification 3.7.1 REQUIRED ACTION B.1 Editorial Change Technical Specification 3.7.1, Main Steam Safety Valves (MSSVs), requires that six MSSVs per steam generator be OPERABLE. CONDITION B states, One or both steam generators with one or more MSSVs inoperable for closing and REQUIRED ACTION B.1 states, Restore MSSV to OERABLE status. However, the word OPERABLE is misspelled. Therefore, this editorial oversight is proposed to be corrected by changing OERABLE to OPERABLE in REQUIRED ACTION B.1.

General Discussion of Changes The proposed changes are consistency and editorial changes. These changes are proposed to maintain consistency between UFSAR and COL Appendix C design descriptions, tables, and figures, and to propose editorial clarifications. The changes proposed to COL Appendix A Technical Specifications are editorial or for clarification purposes. No structure, system, or component (SSC) 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. The COL Appendix C information is the design information and functions which are subject to verification by the COL Appendix C ITAAC closure process. The proposed changes neither affect the ability to meet design criteria or functions, nor involve a decrease in the safety provided by the associated systems. COL Appendix C information and ITAAC continue to adequately validate their corresponding UFSAR design commitments. The proposed changes do not affect an SSC, function, or feature used for the prevention or mitigation of accidents or their safety / design analyses. The changes do not affect any SSC accident initiator or initiating sequence of events, or involve any safety-related SSC 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. 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 do not adversely impact the emergency plan or the physical security plan implementation, because there are no changes to physical access to credited equipment inside the Nuclear Island (including containment or the auxiliary building) and no adverse impact to plant personnels ability to respond to any plant operations or security event.

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 9 of 15 The proposed changes do not affect the containment, control, channeling, monitoring, processing, or releasing of radioactive and non-radioactive materials. No effluent release path is involved. The types and quantities of expected effluents are not changed. Therefore, radioactive or non-radioactive material effluents are not affected. Plant radiation zones (as described in UFSAR Section 12.3) control 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 are not changed. Licensing Basis Change Descriptions: COL Appendix C (and associated plant-specific Tier 1) Changes Section 1.4 revises Grounding and Lightening Protection System to Grounding and Lightning Protection System. Table 2.3.9-3 Item 4.b sentence is restructured from manual a signal to a manual signal. Table 2.3.11-2 Item 3.a equipment numbers are revised from WGS-MV02A and WGS-MV02B to WGS-MV-02A and WGS-MV-02B. Section 2.5.2 Design Description Item 14 is revised to include an open parenthesis for the acronym for Component Interface Module, (CIM). Section 2.6.3 Design Description Item 4.b) and Table 2.6.3-3 Item 4.b) Design Commitment are revised from The IDS provides electrical isolation between the non-Class 1E ac power system and the non-Class 1E lighting in the MCR to The IDS provides electrical isolation between itself and the non-Class 1E ac power system and the non-Class 1E lighting in the MCR. Table 2.6.6-1 Item 1 Design Commitment is changed from auxiliary and onsite standby diesel generators to and onsite standby diesel generators. Table 2.7.1-3 Control Function for the MCR Ancillary Fans, Division B Room Ancillary Fan, and Division C Room Ancillary Fan are changed from Run to - which denotes no Control Function. Table 3.3-3 location for Fire Area 1220 AF 02 is changed from the Auxiliary Building Non-Radiologically Controlled to the Auxiliary Building Radiologically Controlled. Plant-Specific Tier 1 Change Table 2.5.2-8 Item 14 is revised to include an open parenthesis for the acronym for Component Interface Module, (CIM). COL Appendix C Changes Figure 2.2.1-1 label is added to say, Figure 2.2.1-1 Containment System.

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 10 of 15 Figure 2.3.7-1 is replaced with a legible version of the figure. Figure 2.6.1-1 label is revised from Main ac Power Syste to Main ac Power System. UFSAR Change Table 9.3.3-2 Item 30 is changed from WGS delay bed outlets MV02A, B (waste gas holdup) to WGS delay bed outlets MV-02A, B (waste gas holdup). COL Appendix A Changes LCO 3.4.12 Condition D is changed in part from Three or more flow paths in ADS stage 1, 2, and 3 inoperable to Three or more required flow paths in ADS stage 1, 2, and 3 inoperable. LCO 3.7.1 Required Action B.1 is changed from Restore MSSV to OERABLE status to Restore MSSV to OPERABLE status.

3. TECHNICAL EVALUATION (Incorporated into Section 2, above)
4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR 52.98(f) requires NRC approval for any modification to, addition to, or deletion from the terms and conditions of a COL, including any modification to, addition to, or deletion from the inspections, tests, analyses, or related acceptance criteria contained in the license. The proposed changes involve a departure from COL Appendix C Inspections, Tests, Analyses and Acceptance Criteria (ITAAC) information. Therefore, this activity requires an amendment to the COL. Accordingly, NRC approval is required prior to making the plant-specific changes in this license amendment request.

10 CFR 52, Appendix D, Section VIII.B.5.a allows an applicant or licensee who references this appendix to depart from Tier 2 information, without prior NRC approval, unless the proposed departure involves a change to or departure from Tier 1 information, Tier 2* information, or the Technical Specifications, or requires a license amendment under paragraphs B.5.b or B.5.c of the section. The proposed change involves a change to COL Appendix C (and associated plant-specific Tier 1) ITAAC information. Therefore, NRC approval is required prior to making the change to Tier 2 information. 10 CFR 52, Appendix D, Section VIII.C.6 requires that changes to plant-specific Technical Specifications (TS) be treated as license amendments under 10 CFR 50.90. The proposed changes involve a change to COL Appendix A (plant-specific TS). Therefore, a license amendment is requested under 10 CFR 50.90. 10 CFR Part 50, Appendix A General Design Criterion (GDC) 3, Fire protection, requires, in part, that structures, system, and components important to safety be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. The proposed changes to COL

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 11 of 15 Appendix C (and associated plant-specific Tier 1) information assures the location of the fire areas are correctly shown. Therefore, the proposed changes comply with the requirements of GDC 3. 10 CFR Part 50, Appendix A GDC 4, Environmental and dynamic effects design bases, requires, in part, that structures, systems, and components 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. These structures, systems, and components shall be appropriately protected against dynamic effects, including the effects of missiles, pipe whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit. The proposed changes to COL Appendix C (and associated plant-specific Tier 1) information assures the equipment in affected systems is protected from environmental and dynamic effects, if required. Therefore, the proposed changes comply with the requirements of GDC 4. 10 CFR Part 50, Appendix A GDC 13, Instrumentation and control, requires that instrumentation be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. The proposed changes to COL Appendix C (and associated plant-specific Tier 1) information assures the continued ability to maintain plant safety. Therefore, the proposed changes comply with the requirements of GDC 13. 10 CFR Part 50, Appendix A GDC 17, Electric power systems, requires, in part, that onsite electric power supplies, including the batteries, and the onsite electric distribution system, have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure. The proposed changes to COL Appendix C (and associated plant-specific Tier 1) information assures that power is available from the Class 1E dc and Uninterruptible Power Supply System to monitor and actuate the safety-related passive systems. Therefore, the proposed changes comply with the requirements of GDC 17. 10 CFR Part 50, Appendix A GDC 19, Control room, includes a requirement that 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, and that equipment, including the necessary instrumentation, at appropriate locations outside the control room be provided with a design capability for prompt hot shutdown of the reactor. The proposed changes to COL Appendix C (and associated plant-specific Tier 1) information do not affect the ability of the control room operators to monitor plant status to maintain the plant in a safe condition and to promptly shutdown the reactor. Therefore, the proposed changes comply with the requirements of GDC 19. 10 CFR Part 50, Appendix A GDC 34, Residual heat removal, requires the plant design to include a system to remove residual heat from the reactor core so specified

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 12 of 15 acceptable fuel design limits and the design conditions of the reactor coolant pressure boundary are not exceeded. With the proposed change to COL Appendix A Technical Specifications, the safe shutdown analysis continues to demonstrate the plant complies with its licensing performance criteria to cool the RCS to 420°F within 36 hours. Therefore, the proposed change complies with the requirements of GDC 34. 10 CFR Part 50, Appendix A GDC 60, Control of releases of radioactive materials to the environment, requires that the nuclear power unit design include means to control suitably the release of radioactive materials in gaseous and liquid effluents and to handle radioactive solid wastes produced during normal reactor operation, including anticipated operational occurrences. The proposed changes to COL Appendix C (and associated plant-specific Tier 1) information assures that radioactive waste management systems are designed to minimize the potential for an inadvertent release of radioactivity from the facility and to provide confidence that the discharge of radioactive wastes is maintained below regulatory limits. Therefore, the proposed changes comply with the requirements of GDC 60. 4.2 Precedent No precedent is identified. 4.3 Significant Hazards Consideration Determination The requested amendment proposes to depart from Tier 2 information in the Updated Final Safety Analysis Report (UFSAR) (which includes the plant-specific DCD Tier 2 information) and involves changes related to plant-specific Tier 1 information, with corresponding changes to the associated COL Appendix C information. The requested amendment also proposes changes to the COL Appendix A Technical Specifications. An evaluation to determine whether 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

No. The proposed consistency and editorial changes to Tier 2 information in the UFSAR, COL Appendix C (and associated plant-specific Tier 1) information, and COL Appendix A Technical Specifications do not involve a technical change (e.g., there is no design parameter or requirement, calculation, analysis, function or qualification change). No structure, system, or component (SSC) design or function would be affected. No design or safety analysis would be affected. The proposed changes do not affect any accident initiating event or component failure, thus the probabilities of the accidents previously evaluated are not affected. No function used to mitigate a radioactive material release and no radioactive material release source term is involved, thus the radiological releases in the accident analyses are not affected.

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 13 of 15 Therefore, the proposed 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 consistency and editorial changes to Tier 2 information in the UFSAR, COL Appendix C (and associated plant-specific Tier 1) information, and COL Appendix A Technical Specifications do not change the design of safety-related SSCs. The proposed changes do not affect plant electrical systems, and does not affect the design function, support, design, or operation of mechanical and fluid systems. The proposed changes do not result in a new failure mechanism or introduce any new accident precursors. No design function described in the UFSAR is affected by the proposed changes. Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated. 4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response

No. The proposed consistency and editorial changes to Tier 2 information in the UFSAR, COL Appendix C (and associated plant-specific Tier 1) information, and COL Appendix A Technical Specifications do not involve any change to the design as described in the COL. There would be no change to an existing design basis, design function, regulatory criterion, or analysis. No safety analysis or design basis acceptance limit/criterion is involved. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety. 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 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. ENVIRONMENTAL CONSIDERATIONS The requested amendment proposes to depart from Tier 2 information in the Updated Final Safety Analysis Report (UFSAR) (which includes the plant-specific DCD Tier 2 information) and involves changes related to plant-specific Tier 1 information, with corresponding changes to the associated COL Appendix C information. The requested amendment also proposes changes to the COL Appendix A Technical Specifications. No structure, system or component

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 14 of 15 (SSC), design function or analysis as described in the UFSAR would be affected by these non-technical and editorial changes. (i) There is no significant hazards consideration. As documented in Section 4.3, Significant Hazards Consideration Determination, of this license amendment request, an evaluation was completed to determine whether 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 determined 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 form any accident previously evaluated; and (3) the proposed amendment 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 in the requested amendment identify editorial and consistency changes which do not affect an aspect of the AP1000 design. The proposed changes are unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents) or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation. Therefore, it is concluded that the proposed amendment does not involve a significant change in the types or significant increase in the amounts of any effluents that may be released offsite. (iii) There is no significant increase in individual or cumulative occupational radiation exposure. The proposed changes in the requested amendment identify editorial and consistency changes which do not affect any aspect of the AP1000 design. The proposed changes in the requested amendment do not affect or alter any walls, floors, or other structures that provide shielding. Plant radiation zones and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure. Therefore, the proposed amendment does not involve a significant increase in individual or cumulative occupational radiation exposure. Based on the above review of the proposed amendment, it has been determined that anticipated construction and operational effects of the proposed amendment do 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 individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in

ND-18-1403 Request for License Amendment: Editorial and Consistency Changes (LAR-18-027) Page 15 of 15 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment and proposed exemption.

6. REFRENCES None.

Southern Nuclear Operating Company ND-18-1403 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Exemption Request: Editorial and Consistency Changes (LAR-18-027) (This Enclosure consists of 7 pages, including this cover page)

ND-18-1403 Exemption Request: Editorial and Consistency Changes (LAR-18-027) Page 2 of 7 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 AP1000 Design, Scope and Contents, to allow a plant-specific departure from elements of the certification information in Tier 1 of the plant-specific AP1000 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. A plant-specific departure and exemption is being requested to make editorial changes to promote consistency in Tier 1 information. 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 following proposed consistency and editorial changes to the system-based design descriptions, as described below. Section 1.4 revises Grounding and Lightening Protection System to Grounding and Lightning Protection System. Table 2.3.9-3 Item 4.b sentence is restructured from manual a signal to a manual signal. Table 2.3.11-2 Item 3.a equipment numbers are revised from WGS-MV02A and WGS-MV02B to WGS-MV-02A and WGS-MV-02B. Section 2.5.2 Design Description Item 14 and Table 2.5.2-8 Item 14 are revised to include an open parenthesis for the acronym for Component Interface Module, (CIM). Section 2.6.3 Design Description Item 4.b) and Table 2.6.3-3 Item 4.b) Design Commitment are revised from The IDS provides electrical isolation between the non-Class 1E ac power system and the non-Class 1E lighting in the MCR to The IDS provides electrical isolation between itself and the non-Class 1E ac power system and the non-Class 1E lighting in the MCR. Table 2.6.6-1 Item 1 Design Commitment is changed from auxiliary and onsite standby diesel generators to and onsite standby diesel generators. Table 2.7.1-3 Control Function for the MCR Ancillary Fans, Division B Room Ancillary Fan, and Division C Room Ancillary Fan are changed from Run to - which denotes no Control Function. Table 3.3-3 location for Fire Area 1220 AF 02 is changed from the Auxiliary Building Non-Radiologically Controlled to the Auxiliary Building Radiologically Controlled. 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.

ND-18-1403 Exemption Request: Editorial and Consistency Changes (LAR-18-027) Page 3 of 7

2.0 Background

The Licensee is the holder of Combined License Nos. NPF-91 and NPF-92, which authorize construction and operation of two Westinghouse Electric Company AP1000 nuclear plants, named Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively. Inconsistencies were identified that necessitate editorial and consistency changes to plant-specific Tier 1 information. Editorial changes are made to enhance reader understanding and consistency changes are made to provide consistency within the Updated Final Safety Analysis Report (UFSAR) and plant-specific Tier 1. 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 generic Design Control Document (DCD) Tier 1 material in regard to the AP1000 by correcting various editorial and consistency changes between Tier 1 and Tier 2 in Tier 1 text, tables, and figures. The proposed exemption would allow a change to the plant-specific Tier 1 ITAAC information consistent with existing plant-specific DCD Tier 2 information. The proposed changes to the description information 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 structures, systems, and components (SSCs) nor involve a significant decrease in the level of safety provided by the structures, systems, or components. Because the proposed editorial and consistency changes are consistent with plant-specific DCD Tier 2 information and the underlying plant design, the changes do not physically affect an SSC. The proposed changes to information in plant-specific DCD Tier 1 continue to provide the detail necessary to implement the corresponding ITAAC. Further, application of the current generic 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 would not serve the underlying purpose of the rule due to the apparent editorial inconsistencies with the existing design information provided in Tier 2 of the plant-specific DCD. 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 AP1000 nuclear power plants. Since SNC has identified editorial and consistency changes to the Tier 1 information 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

ND-18-1403 Exemption Request: Editorial and Consistency Changes (LAR-18-027) Page 4 of 7 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 to allow editorial and consistency changes to the description of the components 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 Commissions regulations. Accordingly, this requested exemption is authorized by law, as required by 10 CFR 50.12(a)(1)

2. This exemption will not present an undue risk to the health and safety of the public.

The proposed exemption from the requirements of 10 CFR 52, Appendix D, Section III.B would allow changes to elements of the Tier 1 DCD to depart from the AP1000 certified (Tier 1) design information. The plant-specific Tier 1 will continue to reflect the approved licensing basis for VEGP Units 3 and 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 Tier 1 ITAAC will continue to serve its required purpose. Because the changes will not alter the operation of any plant equipment or systems 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 editorial and consistency 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 exemption from the requirements of 10 CFR 52, Appendix D, Section III.B would make editorial and consistency changes, as presented in plant-specific Tier 1 information, thereby departing from the AP1000 certified design information. The proposed exemption will enable performance of the ITAAC associated with these

ND-18-1403 Exemption Request: Editorial and Consistency Changes (LAR-18-027) Page 5 of 7 changed elements, by reflecting the revised design information in the text, tables, and figures that are referenced in these ITAAC. The exemption does not alter or impede the design, function, or operation of any plant structures, systems, or components (SSCs) associated with the facilitys physical or cyber security, and therefore does not affect any plant equipment that is necessary to maintain a safe and secure plant status. The proposed exemption has no impact on plant security or safeguards. 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. 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 AP1000 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 3 and 4 COLs reference the AP1000 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 AP1000 design certification, and to require compliance with the design certification information in Appendix D. The proposed editorial and consistency 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 AP1000 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 and the understanding that these changes resolve editorial inconsistencies within the licensing basis, it is likely that other AP1000 licensees will request this exemption. However, if this is not the case, the special circumstances continue to outweigh any decrease in safety from the reduction in standardization because the design functions of the systems

ND-18-1403 Exemption Request: Editorial and Consistency Changes (LAR-18-027) Page 6 of 7 associated with this request will continue to be maintained. The proposed editorial and consistency changes are departures from information in the plant-specific AP1000 DCD. This exemption request and the associated mark-ups demonstrate that there is a minimal change from the plant-specific AP1000 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 requested exemption revises the plant-specific DCD Tier 1 information by making editorial and consistency changes in various systems. The editorial and consistency changes do not affect any safety-related equipment or function, and the design functions of the associated systems continue to be met. Because these functions continue to be met, there is no reduction in the level of safety. Therefore, the requested exemption does not involve a design change that would 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 Exemptions None. 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 criteria for categorial 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 be prepared in connection with the proposed exemption. 8.0 Conclusion The proposed editorial and consistency changes to DCD Tier 1 are necessary to revise information in design descriptions in plant-specific Tier 1 information. The exemption request meets the requirements of 10 CFR52.63, 10 CFR 52.7, 10 CFR 50.12, 10 CFR 51.22, and 10 CFR 52 Appendix D. Specifically, the exemption request meets the

ND-18-1403 Exemption Request: Editorial and Consistency Changes (LAR-18-027) Page 7 of 7 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.

Southern Nuclear Operating Company ND-18-1403 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Proposed Changes to Licensing Basis Documents (LAR-18-027) Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * ) (This Enclosure consists of 11 pages, including this cover page)

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 2 of 11 Revise COL Appendix C Section 1.4 and corresponding Plant-Specific Tier 1 Section 1.4, as shown below. 1.4 List of Acronyms and Abbreviations EGS Grounding and Lightening Lightning Protection System

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 3 of 11 Add the label to COL Appendix C Figure 2.2.1-1, as shown below. Figure 2.2.1-1 Containment System

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 4 of 11 Replace COL Appendix C Figure 2.3.7-1, as shown below [replacing for legibility only]. Figure 2.3.7-1 Spent Fuel Pool Cooling System RNS PUMPS SFS-PL-V066 i r--------------, I I I PCSWAW! I STa!AGE TAA1< I I L--, - - - ------ - -J I I I ...J G;1 SFS~-~Oc---- 1---; r---L------ 1---.----L---------c~--~ -- --- -~- - - ------ - - - --- - ~ Sf5-Pl-V042: 1 '------'-----ji><:J"SFS-PL-V045 I 1 ~040~--------------===l-----~~,--,~.=~~::::::::} ___________________________ i 1 r - -, ( \\ SFSOEMINEAALIZERA I 1 r- -f 1----{ ~ - -, WlS ] L - ~Fs-MV~-" ] CCS SFSFLTERA ] f ~ I i SFSPUMPA I --:-----------v-v--- r 1 RffUE~~CAV!TY {.___!._ _____ _ L _____ __ _ SFS-Pl-V032 1 ~-- - ---- - ~ 1 ,...-, SfSOEMINERALIZERB SFS-MP-0 1 A 1 ] 1 ] i~~ 1 1 .,i r---, ( ) SF5-MV~19 ~ ] ] r---i 1----{ ~-., t-------- L--- ---{9<:}--{ }----{>\\::::}' ------------------'--t><J----1-- *xs I L_J I

1 SFS-A.-V035 T

SFS-PL-V034 SFS-PL-V039 IRWST l ~~=8 ! ti I ~-----r-1--_L

____ j I

I 1 SFSPUMP8 I I SF~P-018 I !MMECOOEr:lllaAMI l i ~~f L----- - --- - -- - - ------------- - - - - - - - ----- - ------ - - -- - - ------------------ - - { 9<:}----{ } ----f.... -....}---- ---J SFS-Pl.V038 T I SFS-PL-V037

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 5 of 11 Revise COL Appendix C Table 2.3.9-3 and corresponding Plant-Specific Tier 1 Table 2.3.9-3, as shown below. Table 2.3.9-3 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 428 2.3.09.04b 4.b) The components identified in Table 2.3.9-2 perform the listed function after receiving a manual a signal from DAS. Revise COL Appendix C Table 2.3.11-2 and corresponding Plant-Specific Tier 1 Table 2.3.11-2, as shown below. Table 2.3.11-2 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 453 2.3.11.03a 3.a) The WGS provides the nonsafety-related function of processing radioactive gases prior to discharge. Inspection will be performed to verify the contained volume of each of the activated carbon delay beds, WGS-MV-02A and WGS-MV-02B. A report exists and concludes that the contained volume in each of the activated carbon delay beds, WGS-MV-02A and WGS-MV-02B, is at least 80 ft3.

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 6 of 11 Revise COL Appendix C Section 2.5.2 and corresponding Plant-Specific Tier 1 Section 2.5.2 Design Description, as shown below. 2.5.2 Protection and Safety Monitoring System Design Description

14. The Component Interface Module (CIM) is developed using a planned design process which provide for specific design documentation and reviews.

Revise Plant-Specific Tier 1 Table 2.5.2-8, as shown below. Table 2.5.2-8 Inspections, Tests, Analyses, and Acceptance Criteria Design Commitment Inspections, Tests, Analyses Acceptance Criteria

14. The Component Interface Module (CIM) is developed using a planned design process which provides for specific design documentation and reviews.

{Design Acceptance Criteria}

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 7 of 11 Revise COL Appendix C Figure 2.6.1-1 label, as shown below. Figure 2.6.1-1 (Sheet 1 of 4) Main ac Power System Revise COL Appendix C Section 2.6.3 and Table 2.6.3-3 and corresponding Plant-Specific Tier 1 Section 2.6.3 and Table 2.6.3-3, as shown below. Design Description

4. The IDS provides the following safety-related functions:

a) * *

  • b) The IDS provides electrical isolation between itself and the non-Class 1E ac power system and the non-Class 1E lighting in the MCR.

Table 2.6.3-3 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 602 2.6.03.04b 4.b) The IDS provides electrical isolation between itself and the non-Class 1E ac power system and the non-Class 1E lighting in the MCR.

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 8 of 11 Revise COL Appendix C Table 2.6.6-1 and corresponding Plant-Specific Tier 1 Table 2.6.6-1, as shown below. Table 2.6.6-1 Inspections, Tests, Analyses, and Acceptance Criteria No. ITAAC No. Design Commitment Inspections, Tests, Analyses Acceptance Criteria 637 2.6.06.01.i

1. The EGS provides an electrical grounding system for: * * * (2) electrical system grounding of the neutral points of the main generator, main step-up transformers, auxiliary transformers, load center transformers, auxiliary and onsite standby diesel generators;

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 9 of 11 Revise COL Appendix C Table 2.7.1-3 and corresponding Plant-Specific Tier 1 Table 2.7.1-3, as shown below. Table 2.7.1-3 Equipment Tag No. Display Control Function MCR Ancillary Fans VBS-MA-10A VBS-MA-10B No Run - Division B Room Ancillary Fan VBS-MA-11 No Run - Division C Room Ancillary Fan VBS-MA-12 No Run - Revise COL Appendix C Table 3.3-3 and corresponding Plant-Specific Tier 1 Table 3.3-3, as shown below. Table 3.3-3 Class 1E Divisions in Nuclear Island Fire Areas Fire Area Number Class 1E Divisions A C B D Auxiliary Building Radiologically Controlled 1220 AF 02 Yes Auxiliary Building Non-Radiologically Controlled 1220 AF 02 Yes Note 1: Dash (-) indicates not applicable. Note 2: * *

  • ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027)

Page 10 of 11 Revise UFSAR Table 9.3.3-2, Item 30, as shown below. Sample Point Name Available Number of Points Type of Sample(a) Process Measurement Gaseous Sample

30. WGS delay bed outlets MV-02A, B (waste gas holdup) 2 Grab Moisture, noble gases, iodine, particulates, tritium

ND-18-1403 Proposed Changes to Licensing Basis Documents (LAR-18-027) Page 11 of 11 Revise COL Appendix A (Technical Specifications) 3.4.12, as shown below ACTIONS (continued) CONDITION REQUIRED ACTION COMPLETION TIME D. * *

  • Three or more required flow paths in ADS stage 1, 2, and 3 inoperable.

D.1 Initiate action to open the RCS pressure boundary. Immediately Revise COL Appendix A (Technical Specifications) 3.7.1, as shown below. ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME B. One or both steam generators with one or more MSSVs inoperable for closing. B.1 Restore MSSV to OPERABLE status. 72 hours

Southern Nuclear Operating Company ND-18-1403 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Conforming Changes to the Technical Specifications Bases (For Information Only) (LAR-18-027) Insertions Denoted by Blue Underline and Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * ) (This Enclosure consists of 2 pages, including this cover page)

ND-18-1403 Conforming Changes to the Technical Specifications Bases (For Information Only) (LAR-18-027) Page 2 of 2 Revise Technical Specifications Bases B 3.4.12 ACTIONS as follows: ACTIONS D.1 If the Required Actions and associated Completion Times of Condition A, B, or C are not met, Condition A and Condition B are entered concurrently, three or more required flow paths in ADS stage 1, 2, or 3 are inoperable, or LCO 3.4.12 is not met for reasons other than Condition A, B, or C, the plant must be placed in a MODE in which this LCO does not apply. Action must be initiated, immediately, to open the RCS pressure boundary.}}

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