ML25232A194

Issuance of Amendment Nos. 208 and 206 to Revise Technical Specification Table 3.3.8-1, Engineered Safeguards Actuation System Instrumentation

ML25232A194
Person / Time
Site:	Vogtle
Issue date:	09/10/2025
From:	Turner Z NRC/NRR/DORL/LPL2-1
To:	Coleman J Southern Nuclear Operating Co
References
EPID L-2024-LLA-0146
Download: ML25232A194 (18)

Text

September 10, 2025 Ms. Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Company, Inc.

3535 Colonnade Parkway, Bin N-274-EC Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 - ISSUANCE OF AMENDMENT NOS. 208 AND 206 TO REVISE TECHNICAL SPECIFICATION TABLE 3.3.8-1, ENGINEERED SAFEGUARDS ACTUATION SYSTEM INSTRUMENTATION (EPID L-2024-LLA-0146)

Dear Ms. Coleman:

The U.S. Nuclear Regulatory Commission (NRC, the Commission) has issued the enclosed Amendment No. 208 to Combined License No. NPF-91 and Amendment No. 206 to Combined License NPF-92 for the Vogtle Electric Generating Plant, Units 3 and 4, respectively. The amendments are in response to your application dated November 1, 2024.

The amendments revise the licenses and Technical Specification Table 3.3.8-1, Engineered Safeguards Actuation System Instrumentation, by removing the Mode 2 applicability for the Source Range Neutron Flux Doubling instrumentation (Function 17) and its associated footnote.

Additionally, the amendments correct an administrative typo in Table 3.3.8-1, Function 22.

A copy of the related Safety Evaluation, which includes the NRC staffs evaluation of the amendment, is enclosed. The notice of issuance of the amendment documents included in this letter will be published in the Federal Register.

If you have questions, please contact me at 301-415-2258 or Zachary.Turner@nrc.gov.

Sincerely,

/RA/

Zachary M. Turner, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 52-025 and 52-026

Enclosures:

1. Amendment No. 208 to Vogtle, Unit 3, COL

2. Amendment No. 206 to Vogtle, Unit 4, COL

3. Safety Evaluation cc: Listserv 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, UNIT 3 DOCKET NO.52-025 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 208 License No. NPF-91

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Southern Nuclear Operating Company (SNC),

dated November 1, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commission's regulations set forth in 10 CFR Chapter I; B.

The facility will be constructed and will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations, and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment. Paragraph 2.D(8) of facility Combined License No. NPF-91 is hereby amended to read as follows:

(8) Incorporation The Technical Specifications, Environmental Protection Plan, in Appendices A and B, respectively of this license, as revised through Amendment No. 208, are hereby incorporated into this license.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION:

Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Page 4 of the facility Combined License and affected pages of Appendix A of the facility Combined License Date of Issuance: September 10, 2025 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.09.10 13:09:06 -04'00'

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, UNIT 4 DOCKET NO.52-026 AMENDMENT TO FACILITY COMBINED LICENSE Amendment No. 206 License No. NPF-92

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment by Southern Nuclear Operating Company (SNC),

dated November 1, 2025, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act) and the Commissions regulations set forth in 10 CFR Chapter I; B.

The facility will be constructed and will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations; D.

The issuance of this amendment will not be inimical to the common defense and security or the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations, and all applicable requirements have been satisfied.

2.

Accordingly, the license is amended by changes to Appendix A, Technical Specifications, of the facility Combined License as indicated in the attachment to this license amendment. Paragraph 2.D(8) of facility Combined License No. NPF-92 is hereby amended to read as follows:

(8) Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 206, are hereby incorporated into this license.

3.

This license amendment is effective as of the date of its issuance and shall be implemented within 90 days of the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION:

Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Page 4 of the facility Combined License and affected pages of Appendix C of the facility Combined License Date of Issuance: September 10, 2025 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2025.09.10 13:09:48 -04'00'

ATTACHMENT TO LICENSE AMENDMENT NOS. 208 AND 206 TO FACILITY COMBINED LICENSE NOS. NPF-91 AND NPF-92 DOCKET NOS.52-025 AND 52-026 Replace the following pages of the Facility Combined License Nos. NPF-91 and NPF-92 with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Facility Combined License No. NPF-91 REMOVE INSERT 4

4 Facility Combined License No. NPF-92 REMOVE INSERT 4

4 Appendix C to facility Combined License Nos. NPF-91 and NPF-92 REMOVE INSERT 3.3.8-8 3.3.8-8

4 Amendment No. 208 D.

The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:

(1)

Changes during Construction - Removed by Amendment No.202 (2)

Pre-operational Testing - Removed by Amendment Nos.192 and 202 (3)

Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos.192 and 202 (4)

Initial Criticality and Low-Power Testing - Removed by Amendment No. 202 (5)

Power Ascension Testing - Removed by Amendment No. 202 (6)

Maximum Power Level SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.

(7)

Reporting Requirements - Removed by Amendment No. 202 (8)

Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 208, are hereby incorporated into this license.

(9)

Technical Specifications - Removed by Amendment No. 202 (10)

Operational Program Implementation - Removed by Amendment No. 202 (11)

Operational Program Implementation Schedule - Removed by Amendment No. 202 (12)

Site-and Unit-specific Conditions - Removed by Amendment No. 202

[Blank Pages 5 through 14 removed by Amendment No. 202.]

4 Amendment No. 206 D.

The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:

(1)

Changes during Construction - Removed by Amendment No. 199 (2)

Pre-operational Testing - Removed by Amendment Nos. 194 and 199 (3)

Nuclear Fuel Loading and Pre-critical Testing - Removed by Amendment Nos. 194 and 199 (4)

Initial Criticality and Low-Power Testing - Removed by Amendment No. 199 (5)

Power Ascension Testing - Removed by Amendment No. 199 (6)

Maximum Power Level SNC is authorized to operate the facility at steady state reactor core power levels not to exceed 3400 MW thermal (100-percent thermal power), as described in the UFSAR, in accordance with the conditions specified herein.

(7)

Reporting Requirements - Removed by Amendment No. 199 (8)

Incorporation The Technical Specifications and Environmental Protection Plan in Appendices A and B, respectively, of this license, as revised through Amendment No. 206, are hereby incorporated into this license.

(9)

Technical Specifications - Removed by Amendment No. 199 (10)

Operational Program Implementation - Removed by Amendment No. 199 (11)

Operational Program Implementation Schedule - Removed by Amendment No. 199 (12)

Site-and Unit-specific Conditions - Removed by Amendment No. 199

[Blank Pages 5 through 14 removed by Amendment No. 199.]

Technical Specifications ESFAS Instrumentation 3.3.8 Table 3.3.8-1 (page 2 of 3)

Engineered Safeguards Actuation System Instrumentation FUNCTION 14.

RCS Wide Range Pressure - Low 15.

Core Makeup Tank (CMT) Level - Low 3 16.

CMT Level - Low 6 17.

Source Range Neutron Flux Doubling 18.

IRWST Lower Narrow Range Level - Low 3 19.

Reactor Coolant Pump Bearing Water Temperature - High 2 20.

SG Narrow Range Water Level - Low 2 21.

SG Wide Range Water Level - Low 2

22.

SG Narrow Range Water Level - High 23.

SG Narrow Range Water Level - High 3 APPLICABLE MODES OR OTHER SPECIFIED CONDITIONS 1,2,3,4 5

5(9) 1,2,3,4(b) 4ldl,5lh) 1,2,3,4ib) 4ld\\5lh) 3Iil,4Ul 5Ul 1,2,3,4(b) 4Idl,5 5(9) 1,2,3,4 1,2,3,4ib) 1,2,3,4(b) 1,2,3,4 1,2 3,4 REQUIRED CHANNELS 4

4 4

4 per tank 4 per OPERABLE tank 4 per tank 4 per OPERABLE tank 4

4 4

4 4

4 per RCP 4 per SG 4 per SG 4 per SG 4 per SG 4 per SG (b) With the RCS not being cooled by the Normal Residual Heat Removal System (RNS).

(d) With the RCS being cooled by the RNS.

(g) With upper internals in place.

(h) With RCS not VENTED.

(i)

With unborated water source flow paths not isolated except during intentional approach to criticality.

U) With unborated water source flow paths not isolated.

CONDITIONS H

K L

F J

F J

F M

N 0

F F

D VEGP Units 3 and 4 3.3.8 - 8 Amendment No. 208 (Unit 3)

Amendment No. 206 (Unit 4)

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 208 AND 206 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 November 1, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24306A131), Southern Nuclear Operating Company (SNC, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend the licenses for Vogtle Electric Generating Plant (Vogtle, VEGP), Units 3 and 4, Combined License (COL)

Numbers NPF-91 and NPF-92, respectively. Specifically, SNC submitted a license amendment request (LAR) to remove the Mode 2 applicability for the Source Range Neutron Flux Doubling instrumentation as required by Technical Specification (TS) 3.3.8, Engineered Safety Feature Actuation System (ESFAS) Instrumentation, Table 3.3.8-1, Function 17, Source Range Neutron Flux Doubling and administratively adds a missing dash in the name of Function 22, SG [Steam Generator] Narrow Range Water Level - High.

2.0 REGULATORY EVALUATION

2.1 System Description and Operation In Section 2.1 of the Enclosure to its LAR, the licensee described the system design and operation, in part, as:

As discussed in Updated Final Safety Analysis Report (UFSAR)

Subsection 7.3.1.2.14, Boron Dilution Block, an excessive increasing rate of source range neutron flux doubling signal accomplishes a block of the boron dilution by closing the chemical and volume control system (CVS) makeup isolation valves and closing the makeup pump suction valves to the demineralized water storage tanks. This signal also provides a non-safety trip of the makeup pumps. These actions terminate the supply of potentially unborated water to the reactor coolant system as quickly as possible.

In the event of a loss of ac power sources (identified as low input voltage in UFSAR Subsection 15.4.6.2.5) or a reactor trip (as indicated by the P-4 interlock), the block of boron dilution is accomplished by closing the makeup pump suction valves to the demineralized water storage tanks and aligning the boric acid tank to the suction of the makeup pumps. This permits makeup as needed from a borated source that will not reduce the available shutdown margin in the reactor core.

The licensee further describes conditions when the source range neutron flux doubling signal is currently manually and automatically blocked and reinstated depending upon plant conditions and interlocks.

2.2 Description of Proposed Changes Current TS 3.3.8, Table 3.3.8-1, Function 17 is required to be operable in Modes 2 and 3 with the unborated water source flow paths not isolated except when critical or during intentional approach to criticality, and in Modes 4 and 5 with the unborated water source flows paths not isolated.

In the LAR, the licensee proposed the following TS changes:

Modify TS Table 3.3.8-1 to remove Mode 2 applicability from Function 17, Source Range Neutron Flux Doubling Modify TS Table 3.3.8-1 Footnote (i), to remove except when critical or Modify TS Table 3.3.8-1 to correct an administrative typo in Function 22, by inserting a dash - between Level and High Proposed Changes to Technical Specification Bases Consistent with Title 10 of the Code of Federal Regulations (10 CFR), paragraph 50.36(a)(1),

the licensee submitted corresponding changes to the TS Bases that provide the reasons for the proposed TS changes. The regulation at 10 CFR 50.36(a)(1) states that [a] summary statement of the bases or reasons for such specifications, other than those covering administrative controls, shall also be included in the application, but shall not become part of the technical specifications. The licensee shall make changes to the Vogtle TS Bases in accordance with TS 5.5.6, Technical Specifications (TS) Bases Control Program. As such, the NRC reviewed the TS Bases markup for information and consistency but does not approve proposed changes that are part of this LAR.

2.3 Reason for the Proposed Changes In Section 2.3 of the Enclosure to its LAR, the licensee stated, in part, that:

For VEGP Unit 3 and Unit 4, the Source Range Neutron Flux Doubling instrumentation is not credited for accident mitigation in Mode 2 (see UFSAR Subsection 15.4.6.2.5) nor does it meet any of the other criteria of 10 CFR 50.36 for inclusion in the Technical Specifications. Furthermore, the Source Range Neutron Flux Doubling is blocked in accordance with operating procedures prior to entering Mode 2 on startup and not reenergized until exiting Mode 2 during a shutdown. Additionally, Function 22, Steam Generator Narrow Range Water Level High is missing a dash before the High designation.

2.4 Regulations In accordance with paragraph C.6. of Section VIII of the Code of Federal Regulations (10 CFR)

Processes for Changes and Departures of Appendix D to Part 52 Design Certification Rule for the AP1000 Design, changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90. Pursuant to 10 CFR 50.90, whenever a COL holder desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired and following, as far as applicable, the form prescribed for original applications.

Per 10 CFR 52.79(a)(30), the application for a COL shall include proposed TSs prepared in accordance with the requirements of 10 CFR 50.36. The regulation at 10 CFR 50.36(c)(2) requires that TSs includes LCO. Per 10 CFR 50.36(c)(2)(i), LCO are the lowest functional capability or performance levels of equipment required for safe operation of the facility. The regulation also requires that when an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met.

The regulations in 10 CFR Part 50, Appendix A, General Design Criteria [GDC] for Nuclear Power Plants, establishes the minimum requirements for the principal design criteria for water-cooled nuclear power plants. The principal design criteria establish the necessary design, fabrication, construction, testing, and performance requirements for structures, systems, and components important to safety. The NRC staff determined that the following GDC are relevant to the review:

GDC 13, Instrumentation and control, requires that, Instrumentation shall be provided to monitor variables and systems over their anticipated ranges for normal operation, for anticipated operational occurrences, and for accident conditions as appropriate to assure adequate safety, including those variables and systems that can affect the fission process, the integrity of the reactor core, the reactor coolant pressure boundary, and the containment and its associated systems. Appropriate controls shall be provided to maintain these variables and systems within prescribed operating ranges.

GDC 20, Protection system functions, requires that, The protection system shall be designed (1) to initiate automatically the operation of appropriate systems including the reactivity control systems, to assure that specified acceptable fuel design limits are not exceeded as a result of anticipated operational occurrences and (2) to sense accident conditions and to initiate the operation of systems and components important to safety.

3.0 TECHNICAL EVALUATION

3.1 Evaluation of Proposed Changes 3.2.1 TS Table 3.3.8-1, Engineered Safety Feature Actuation System Instrumentation, Remove Mode 2 Applicability from Function 17 and revise Footnote (i)

The licensee proposed to modify TS Table 3.3.8-1, Function 17, by removing the Mode 2 applicability and by revising Footnote (i) as follows:

Function:

17. Source Range Neutron Flux Doubling Applicable Modes or Other Specified Conditions:

2(i), 3(i), 4(j)

Footnote:

(i) With unborated water source flow paths not isolated except when critical or except during intentional approach to criticality Evaluation of TS Table 3.3.8-1, Function 17, Changes The NRC staff reviewed and evaluated independently the proposed changes by reviewing the technical evaluations provided in the licensees submittal against the assumptions and analysis in the UFSAR and associated regulatory requirements for TS. The potential impact evaluated within this Safety Evaluation is related to inadvertent boron dilution of the reactor coolant system (RCS) while in Mode 2, in the absence of the Source Range Neutron Flux Doubling function, which provides a signal to block the supply of unborated water.

As described in Section 7.3.1.2.14, Boron Dilution Block, of the Vogtle UFSAR (ML23165A215), signals to block boron dilution are generated by any of the following conditions:

1. Excessive increasing rate of source range flux doubling signal

2. Loss of ac power sources (low Class 1E battery charger input voltage)

3. Reactor trip (interlock P-4)

The proposed change affects Item 1 and its applicability in Mode 2. Currently, as stated in the submittal, the TS Table 3.3.8-1, Function 17, is required to be operable in Modes 2 through 5.

Table 3.3.8-1, which lists this requirement, also provides an exception to this requirement in Modes 2 and 3 with Footnote (i) which states [w]ith unborated water source flow paths not isolated except when critical or except during intentional approach to criticality. The licensees proposed change removes the requirement for the operability of the source range neutron flux doubling function in Mode 2.

The NRC staff confirmed through their review of the Vogtle UFSAR that this proposed change will not affect the other two signals which block dilution, loss of ac power sources or reactor trip.

The licensees submittal discusses the UFSAR Subsection 7.3.1.2.14, which states, in part, that:

In the event of an excessive increasing rate of source range flux doubling signal, the block of boron dilution is accomplished by closing the chemical and volume control system makeup isolation valves and closing the makeup pump suction valves to the demineralized water storage tanks. This signal also provides a non-safety trip of the makeup pumps. These actions terminate the supply of potentially unborated water to the reactor coolant system as quickly as possible.

Further Section 2.3 of the Enclosure to its LAR, the licensee states, in part, that:

For VEGP Unit 3 and Unit 4, the Source Range Neutron Flux Doubling instrumentation is not credited for accident mitigation in Mode 2 (see UFSAR Subsection 15.4.6.2.5) nor does it meet any of the other criteria of 10 CFR 50.36 for inclusion in the Technical Specifications. Furthermore, the Source Range Neutron Flux Doubling is blocked in accordance with operating procedures prior to entering Mode 2 on startup and not reenergized until Mode 2 during a shutdown.

The Vogtle UFSAR Subsection 15.4.6.1, Identification of Causes and Accident Description, discusses the chemical and volume control system (CVCS) malfunctions that result in a decrease in the boron concentration in the reactor coolant, stating, in part, that:

An inadvertent boron dilution is caused by the failure of the demineralized water transfer and storage system or chemical and volume control system, either by controller, operator or mechanical failure. The chemical and volume control system and demineralized water transfer and storage system are designed to limit, even under various postulated failure modes, the potential rate of dilution to values that, with indication by alarms and instrumentation, allowing sufficient time for automatic or operator response to terminate the dilution.

The Vogtle UFSAR further states that the CVCS, as designed, does not run continuously, but instead is operated once per day to make up for reactor coolant leakage. A makeup pump is started when the volume control system is placed into dilute mode. The status of the RCS makeup is available to the operator by various indications and alarms.

In Section 3.0 of its submittal and UFSAR Subsection 15.4.6.2.5, Dilution During Startup (Mode 2), the licensee describes the effects of a dilution during startup, when rod control is in manual and operators take manual action to change power levels (includes Mode 2).

This mode of operation is a transitory operational mode in which the operator intentionally dilutes and withdraws control rods to take the plant critical. During this mode, the plant is in manual control. For a normal approach to criticality, the operator manually withdraws control rods and dilutes the reactor coolant with unborated water at controlled rates until criticality is achieved. Once critical, the power escalation is slow enough to allow the operator to manually block the source range reactor trip after receiving the P-6 permissive signal from the intermediate range detectors (nominally at 105 cps [counts per second] ). Too fast a power escalation (due to an unknown dilution) would result in reaching P-6 unexpectedly, leaving insufficient time to manually block the source range reactor trip. Failure to perform this manual action results in a reactor trip and immediate shutdown of the reactor.

The NRC staff reviewed the licensees submittal and the Vogtle plant design, including the UFSAR, and confirmed that the Source Range Neutron Flux Doubling function remains blocked when transitioning from Mode 2 to Mode 1, and this has no impact on the safe operation of the reactor in Mode 1. Further when the operators intentionally drive the plant to approach criticality, the function can be blocked by the operator upon the occurrence of the P-6 permissive. When transitioning down in modes approaching shutdown (from Mode 2 to Modes 3, 4, 5), the function remains required as specified in TS Table 3.3.8-1, and the current LAR does not propose any changes to this applicability or to operating procedures, including the practice of blocking the doubling function in Mode 2 during startup after receiving the required permissive and reenergizing it when exiting Mode 2 (the function remains required in Mode 3, 4 and 5 with no changes). The NRC staffs independent review of the Vogtle TS and UFSAR confirms that no changes are being requested to other reactor trips that mitigate a boron dilution event in Mode 2, which remain required per TS 3.3.1, Reactor Trip System (RTS) Instrumentation, TS 3.3.2, Reactor Trip System (RTS) Source Range Instrumentation, and TS 3.3.3, Reactor Trip System (RTS) Intermediate Range Instrumentation, above the P-6 interlock. Therefore, the approval of the request to remove the requirement for the Source Range Neutron Flux Doubling function operability in Mode 2, including the revision of Table 3.3.1-8 Footnote (i), will not adversely affect the plants safe operation and is, therefore, acceptable.

3.2.2 Evaluation of Editorial Revision in TS Table 3.3.8-1, Function 22 The licensee proposed the following editorial revision of TS Table 3.3.8-1, Function 22:

Function:

22. SG Narrow Range Water Level - High Evaluation of Proposed, Function 22, Editorial Change The NRC staff reviewed the proposed change to TS 3.3.8, Table 3.3.8-1, Function 22, to add a missing dash between Level and High. The NRC staff concludes that this change is administrative in nature and does not affect the technical information or requirements of the TS.

3.2 Technical Conclusion The NRC staff reviewed the licensees proposed changes and concludes that the proposed deletion of Mode 2 applicability for the Source Range Neutron Flux Doubling function operability as required by TS 3.3.8, Table 3.3.8-1, is acceptable because there is no impact on the following:

1. System or operators ability to prevent a boron dilution event during startup or shutdown in Mode 2

2. Analyzed cases in Chapter 15 of the plant UFSAR as applicable to Mode 2

3. Other trips that are required in Mode 2 as described in TS 3.3.1, 3.3.2, and 3.3.3

4. Operating procedures, instrumentation and hardware logic

5. TS 3.3.8, Table 3.3.8-1 exception to operability requirement of the source range neutron doubling function in Mode 2 when critical or intentional approach to criticality The NRC staff finds the proposed addition of a missing dash in the title of Function 22 acceptable because it is administrative in nature and does not impact the technical information or requirements of the TS.

Based on the technical evaluations, the NRC staff conclusions regarding the applicable regulatory requirements given in Section 2.0 above are as follows:

1. The requirements of 10 CFR 50.36 would still be met because the proposed TS change continues to assure the necessary quality of systems and components are maintained and that the facility operation will be within safety limits, and the limiting conditions for operation will be met.

2. GDC 13 would continue to be met because the proposed change will not negatively impact the instrumentation and control used to monitor variables and systems that can affect the fission process.

3. GDC 20 would continue to be met because the proposed change will not adversely affect the design or automatic operation of the reactor protection system such that acceptable fuel design limits are not exceeded.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on August 19, 2025. On August 28, 2025, the State official confirmed that the State of Georgia had no comments.

5.0 ENVIRONMENTAL CONSIDERATION

The amendment changes a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. 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 amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on December 23, 2024 (89 FR 104568, 104572). 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 amendment.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, 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 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.

Principal Contributors: G. Vasudevamurthy, NRR J. Ambrosini, NRR Date: September 10, 2025

ML25232A194 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/STSB/BC NRR/DSS/SCPB/BC NAME ZTurner KZelenock SMehta MValentin DATE 08/19/2025 08/25/2025 08/25/2025 09/02/2025 OFFICE NRR/DSS/SNSB/BC NRR/DEX/EICB/BC NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME NDiFrancesco FSacko MMarkley ZTurner DATE 09/02/2025 08/26/2025 09/10/2025 09/10/2025