virgil c. summer nuclear station (vcsns) units 2 and 3 ...nnd-17-0288 10 cfr 50.90 10 cfr 52.63 u.s....

SCE&G New Nuclear Deployment ● P. O. Box 88 ● MC 846 ● Jenkinsville, South Carolina 29065 ● www.sceg.com

April Rice

Manager New Nuclear Licensing

May 25, 2017

NND-17-0288 10 CFR 50.90 10 CFR 52.63

U.S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, DC 20555-0001 Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3 Docket Numbers 52-027 and 52-028 Combined License Numbers NPF-93 and NPF-94 Subject: Request for License Amendment and Exemption: Fire Protection System (FPS)

Piping That Must Remain Functional Following a Safe Shutdown Earthquake (SSE) (LAR 17-15)

Reference: 1. Southern Nuclear Operating Company, Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment and Exemption: Fire Protection System (FPS) Piping That Must Remain Functional Following a Safe Shutdown Earthquake (SSE) (LAR-17-013), dated May 5, 2017 (ND-17-0788)

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, South Carolina Electric & Gas Company (SCE&G), acting on behalf of itself and the South Carolina Public Service Authority (Santee Cooper), requests an amendment to the combined licenses (COLs) for Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3 (License Numbers NPF-93 and NPF-94, respectively). The requested amendment proposes changes to the VCSNS Units 2 and 3 COL Appendix C (and corresponding plant-specific Design Control Document (DCD) Tier 1) information. Pursuant to the provisions of 10 CFR 52.63(b)(1), an exemption from elements of the design as certified in the 10 CFR Part 52, Appendix D, design certification rule is also requested for the plant-specific Tier 1 material departures. The requested amendment proposes changes to more clearly define the boundaries and seismic requirements for the portion of the fire protection system (FPS) piping that is required to remain functional following a safe shutdown earthquake (SSE); i.e., the “seismic standpipe system.” The proposed changes also include the removal of SSE requirements from pipe lines that do not need to remain functional following an SSE (specifically, the FPS piping that is part of the non-seismic FPS containment spray system and the FPS open tray system). Enclosure 1 provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination), and environmental considerations for the proposed changes in the License Amendment Request (LAR). Enclosure 2 provides the background and supporting basis for the requested exemption. Enclosure 3 provides the proposed changes to the VCSNS 2&3 licensing basis documents.

U. S. Nuclear Regulatory Commission NND-17-0288 of 3

This LAR is technically consistent with that submitted by Southern Nuclear Operating Company (SNC) in Reference 1.

SCE&G requests NRC staff approval of this license amendment request and the associated exemption by December 22, 2017, to support closure of ITAAC associated with FPS piping . SCE&G expects to implement this proposed amendment (through incorporation into the licensing basis documents; e.g. , the UFSAR) within 30 days of approval of the requested changes. SNC has indicated the requested approval date for the Vogtle Electric Generating Plant (VEGP) Units 3 and 4 license amendment request for this topic is November 6, 2017.

In accordance with 10 CFR 50.91, SCE&G is notifying the State of South Carolina of this LAR by transmitting a copy of this letter and enclosures to the designated State Official.

This letter contains no regulatory commitments.

Should you have any questions, please contact Nick Kellenberger by telephone at (803) 941 -9834, or by email at [email protected].

I declare under penalty of perjury that the foregoing is true and correct.

BB/ARR/bb

Executed on this as--l'day of M d Sincerely,

cy:J~ April Rice Manager

I 2017.

New Nuclear Licensing

Enclosures: 1) Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3 - Request for License Amendment: FPS Piping That Must Remain Functional Following an SSE (LAR 17-15)

2) Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3 - Exemption Request: FPS Piping That Must Remain Functional Following an SSE (LAR 17-15)

3) Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3 - Proposed Changes to Licensing Basis Documents (LAR 17-15)

U. S. Nuclear Regulatory Commission NND-17-0288 of 3 cc: Billy Gleaves Ruth Reyes Chandu Patel Paul Kallan Tom Fredette Tomy Nazario Cathy Haney Jim Reece Stephen A. Byrne Jeffrey B. Archie Ronald A. Jones Alvis J. Bynum Kathryn M. Sutton April Rice Nick Kellenberger Matt Kunkle Mory Diane Bryan Barwick Dean Kersey Cynthia Lanier Lisa Spears Frederick Willis Neil Haggerty

Pat Young Zach Harper Brian McIntyre Brian Bedford Carl Churchman Joseph Cole Chuck Baucom Lisa Alberghini Curt Castell Susan E. Jenkins William M. Cherry Rhonda O’Banion [email protected] vcsummer2&[email protected] [email protected] [email protected]

South Carolina Electric & Gas Company

NND-17-0288

Enclosure 1

Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3

Request for License Amendment:

FPS Piping That Must Remain Functional Following an SSE

(LAR 17-15)

(Enclosure 1 consists of 22 pages, including this cover page)

NND-17-0288 Enclosure 1 Request for License Amendment: FPS Piping That Must Remain Functional Following an SSE (LAR 17-15)

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Table of Contents

1. Summary Description

2. Detailed Description

3. Technical Evaluation

4. Regulatory Evaluation

4.1. Applicable Regulatory Requirements/Criteria

4.2. Precedent

4.3. Significant Hazards Consideration Determination

4.4. Conclusions

5. Environmental Considerations

6. References


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Pursuant to 10 CFR 50.90, South Carolina Electric & Gas Company (SCE&G), acting on behalf of itself and the South Carolina Public Service Authority (Santee Cooper), hereby requests an amendment to Combined License (COL) Nos. NPF-93 and NPF-94 for Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3, respectively. 1. Summary Description

The requested amendment revises COL Appendix C, Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC), and corresponding plant-specific Tier 1 ITAAC with concurrent revisions to the Updated Final Safety Analysis Report (UFSAR) to define the boundaries and seismic requirements for the portion of the fire protection system (FPS) piping that is required to remain functional following a safe shutdown earthquake (SSE); i.e., the “seismic standpipe system.” The proposed changes include the removal of SSE requirements from pipe lines that do not need to remain functional following an SSE due to the change from piping Class F to Class G. Specifically, the FPS piping that is part of the non-seismic FPS containment spray system and the FPS open tray system are removed from the seismic standpipe system. The requested amendment requires changes to the UFSAR in the form of departures from the plant-specific Design Control Document (DCD) Tier 2 information (as detailed in Section 2), and involves changes to related plant-specific DCD Tier 1 information, with corresponding changes to the associated COL Appendix C information. This enclosure requests approval of the license amendment necessary to implement the Tier 2 and COL Appendix C changes. Another enclosure requests the exemption necessary to implement the involved changes to the plant-specific DCD Tier 1 information.

2. Detailed Description

The fire protection system (FPS) is a nonsafety-related, non-seismic system consisting of subsystems for fire detection and alarm, fire water supply, and automatic and manual fire suppression. The primary objective of these subsystems is to minimize the consequences should a fire occur. The design of the FPS meets the applicable requirements of the National Fire Protection Association (NFPA) standard, NFPA 804, “Standard for Fire Protection for Advanced Light Water Reactor Electric Generating Plants,” 2001 Edition; NUREG-0800 Standard Review Plan (SRP), Section 9.5.1, “Fire Protection Program,” Revision 5; and Branch Technical Position (BTP) CMEB 9.5-1, “Guidelines for Fire Protection for Nuclear Power Plants.” One specific FPS subsystem that is fed into containment is the FPS open-nozzle suppression system, which is the sprinkler system used to spray nonsafety-related open cable trays. The FPS open-nozzle suppression system supports compliance with UFSAR and BTP CMEB 9.5-1 requirements to avoid fire propagation from nonsafety-related cables routed in open cable trays to safety-related cables during a fire event. There is no credit taken for the FPS cable tray system to operate following a seismic event as there are no requirements to consider a fire event concurrent with the occurrence of any plant accident or other natural phenomena, including a seismic event. As a severe accident management function, the FPS feeds the nonsafety-related, non-seismically qualified FPS containment spray system as described in UFSAR Subsection


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6.5.2. The FPS containment spray system provides an additional means of removing airborne particulates after a severe accident. Note that the primary means of removal of airborne activity is by natural processes that do not depend on sprays, such as sedimentation, diffusiophoresis, and thermophoresis. Because it is a nonsafety-related, severe accident management feature of the AP1000 plant, the FPS containment spray system is not credited in any accident analysis as described in UFSAR Subsection 15.6.5. The FPS also performs a single safety-related function of containment isolation during design basis accidents for the fire protection water supply line that penetrates containment. The containment isolation valve and the portion of piping that maintain the integrity of the containment pressure boundary are designed to seismic Category I and AP1000 equipment Class B (Safety Class 2) criteria in accordance with Regulatory Guide 1.29. Primary containment isolation piping and valves are designed in accordance with General Design Criterion (GDC) 56 of 10 CFR Part 50, Appendix A. Despite being a nonsafety-related, non-seismic system, in accordance with BTP CMEB 9.5-1, special seismic design requirements are applied to portions of the FPS manual fire suppression standpipe system that are located in areas containing equipment required for safe shutdown following a safe shutdown earthquake (SSE). The FPS piping is not required to remain functional following an SSE, except to provide water to the seismic standpipe system and hose stations for manual firefighting in areas containing safe shutdown equipment. Tier 1 Table 2.3.4-4 provides a list of FPS pipe lines that remain functional following an SSE. During design finalization of the FPS, it was identified that changes are needed to add or remove several FPS pipe lines identified in Tier 1 Table 2.3.4-4. As additional changes are likely as the detailed FPS design follows the plant systems and structures design, a change is proposed to replace Tier 1 Table 2.3.4-4 in its entirety with a new Tier 1 Figure 2.3.4-2, which, instead of listing individual pipe lines, depicts boundaries (i.e., valves) for FPS piping that must remain functional following an SSE. The Tier 1 Figure 2.3.4-2 boundary includes existing interface piping, with the same piping Class RCF as the FPS seismic standpipe, from the Passive Containment Cooling Water Storage Tank (PCCWST), which is the normal source of water supply. The FPS containment spray lines (FPS-L701 through FPS-L709) and fire pipe lines FPS-L181 and FPS-L183 serving fire hose stations F125A and F134A, respectively, are not required to remain functional following an SSE, and are not within the boundaries on proposed Tier 1 Figure 2.3.4-2. Fire pipe lines FPS-L144 and FPS-L154 are omitted from Figure 2.3.4-2 due to the consolidation of two fire hose stations (F127A/B) into a single hose station (F127) fed by pipe line FPS-L143, as a result of the elimination of the lower annulus room/corridor (room 12243). Pipe reducers are removed from fire pipe lines FPS-L095 and FPS-L123. These fire pipe lines are then consolidated into fire pipe lines FPS-L131 and FPS-L130, respectively. Fire protection lines FPS-L090A/B, FPS-L091A/B/C and FPS-L092A/B/C are removed from Tier 1 Table 2.3.4-4, because these lines are downstream of valves FPS-V133A, B and C, which is discussed in the Note in new Tier 1 Figure 2.3.4-2. The remaining pipe lines required to be functional following an SSE support the seismic source water supply to the seismic functional fire hose valves. These pipe lines are either depicted or addressed by the Note in the proposed Tier 1 Figure 2.3.4-2, rather than listing them individually in the current Tier 1 Table 2.3.4-4. The nonsafety-related FPS containment spray system includes pipe lines FPS-L701 through FPS-L709, which are currently listed in COL Appendix C (and plant-specific Tier 1),


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Table 2.3.4-4, “FPS Piping Which Must Remain Functional Following a Safe Shutdown Earthquake.” This amendment request proposes removal of the requirement to maintain functionality of the nonsafety-related FPS containment spray system pipe lines (FPS-L701 through FPS-L709) following a seismic event consistent with the piping class for these lines. Fire hose stations F125A and F134A are currently fed from the Area 4 seismic standpipe via FPS pipe lines FPS-L181 and FPS-L183, as depicted on UFSAR Figure 9.5.1-1, Sheet 3. The Area 4 seismic standpipe system is designed to remain functional following an SSE. These hose stations are located in fire area 1200 AF 01 in fire zones 1225 AF 12261 (room 12261) and 1234 AF 12351 (room 12351), respectively, and are not credited for serving areas containing equipment required for safe shutdown following an SSE. Therefore, a change is proposed to feed these hose stations from a non-seismic standpipe in Area 5, and change the piping class for the pipe lines to these hose stations to nonseismic Equipment Class G piping. This amendment request proposes removal of the requirement to maintain functionality of the nonsafety-related FPS fire hose station lines (FPS-L181 and FPS-L183) by removing these two FPS pipe lines from Tier 1 Table 2.3.4-4; i.e., omitting them from new Tier 1 Figure 2.3.4-2, because they are no longer required to be functional following an SSE. The FPS seismic standpipe subsystem is normally aligned to the Passive Containment Cooling Water Storage Tank (PCCWST) as the primary source of water. The seismic standpipe subsystem can also be supplied from the FPS fire main by opening the normally closed cross-connect valve (FPS-V101) with the plant fire main. The PCCWST supply water to the FPS seismic standpipe system is at a lower pressure than the FPS fire main. As such, the use of the existing pressure regulating valves does not allow for an effective hose stream when using the PCS supply to the seismic standpipe subsystem. In order to produce an effective hose stream, it is necessary to add non-pressure regulating (manual) hose valves. Non-pressure regulating hose valves are proposed to be added to the existing FPS seismic standpipe hose stations as shown on UFSAR Figure 9.5.1-1, Sheet 3. A change is proposed to add 28 new non-pressure regulating (manual) hose valves to FPS lines L112, L113, L114, L115, L118, L119, L120, L141, L142, L143, L145, L146, L147, L148, L149, L150, L155, L156, L182, L184, L188, L189, L191, L192, L193, L194, L195 and L199, currently identified in Tier 1 Table 2.3.4-4, by further dividing these lines into A/B connections to accommodate the 28 new non-pressure regulating hose valves. All of these A/B connection lines are within the boundary of the new Tier 1 Figure 2.3.4-2. Like the FPS containment spray system, the functional capability requirement following an SSE of the FPS open-nozzle suppression system is not required by any regulatory code requirements (i.e., BTP 9.5.1 or NFPA 804) because it is not a part of the seismic standpipe system. Since the FPS open-nozzle suppression system components could be considered to be a part of the manual “suppression system components” as noted in UFSAR Table 3.2-3, this could be misinterpreted to mean that the FPS open-nozzle suppression system components are required to function after an SSE. It is therefore proposed that UFSAR Table 3.2-3 be changed by clarifying that the FPS open-nozzle suppression system components are not required to remain functional during an SSE. Additionally, it is proposed that UFSAR Table 3.2-3, “AP1000 Classification of Mechanical and Fluid Systems, Components, and Equipment,” be revised to replace the general description of “suppression system components” with the more specific description of “fire hose connections.”


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With regard to FPS piping in the non-1E equipment room, a change to UFSAR Table 3.2-3 is also proposed to reflect this differentiation by replacing “components” with the more specific “piping” in the description column, and identify that only the non-radiologically controlled area of the auxiliary building standpipes that need to be functional following SSE require the same seismic analysis for seismic Category I, using the same seismic methods and allowable limits for the faulted load combination that contains the SSE loads as ASME Section III Class 3 piping. The FPS standpipes in the radiological area of the auxiliary building standpipes are Class G piping and do not require seismic analysis. Whereas the FPS piping in the non-1E penetration room piping requires seismic analysis, the other FPS components do not. This change is consistent with current Tier 1 Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, which require inspection and analysis of FPS piping only, rather than FPS components. Other specific ITAAC in Table 2.3.4-2 address containment isolation valves, fire hose stations, etc. UFSAR Table 9.5.1-1 also requires revision. Table 9.5.1-1, Item 19 states that a single active failure or crack in a fire suppression system moderate energy line should not impair the primary and backup fire suppression capabilities. The remark applicable to Item 19 states:

“The fire suppression systems located inside the containment are qualified to seismic Category I criteria…”

A change is proposed to clarify the Item 19 remark by revising UFSAR Table 9.5.1-1 to indicate that the seismic portions of the FPS inside containment (i.e., the “seismic standpipe system”) are analyzed to remain functional following an SSE. The safety-related containment isolation piping/valves are fully qualified as seismic Category I. Consistent with BTP CMEB 9.5-1, which applies special seismic design requirements to portions of the manual fire suppression standpipe system located in areas containing equipment required for safe shutdown following a safe shutdown earthquake, it is proposed that UFSAR Table 9.5.1-1 be revised to replace the statement that “fire suppression systems” in containment are qualified to seismic Category I criteria with the statement that “piping serving the standpipe and fire hose connections” in containment are analyzed to remain functional following a safe shutdown earthquake, and that the containment isolation piping is qualified to seismic Category I criteria. There are currently three FPS open-nozzle cable tray systems configured in a three-branch manifold, located in the North side of room 11400 on the steel platform (SPL) SPL18 between the containment vessel wall and the safety-related barrier. During the cable tray design finalization, and in order to maintain, inspect, and test the FPS open nozzle cable tray system in accordance with requirements delineated in UFSAR Appendix 9A, the three-branch containment cable tray spray system manifold must be divided into five branches. The two new groups will require two new branches, each branch with an additional valve. The addition of the new isolation valves V133D and V133E are reflected in the proposed Tier 1 Figure 2.3.4-2. The spray system design allows for the water supply to feed adjacent systems concurrently. The five systems will consist of one larger system of approximately 145 nozzles and 4 smaller systems of approximately 70 nozzles each. The new system arrangement allows for the one larger system to flow concurrently with the adjacent smaller system, or concurrent flow of three of the smaller systems that could actuate at once in a worst case scenario. The revised nozzle distribution among those


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reconfigured systems allows for available FPS water supply to be adequately dispersed for all cable tray fire scenarios for the protected cable trays with sufficient flow rate. Licensing Basis Change Descriptions The following licensing basis changes are proposed.

COL Appendix C (and plant-specific Tier 1) 1. Subsection 2.3.4: Revise design description item 2 to refer to information shown in

Tier 1 Figure 2.3.4-2, in lieu of Tier 1 Table 2.3.4-4.

2. Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii: Revise Design Commitment 2 and ITAAC 2.3.04.02.i (and plant-specific Tier 1 Table 2.3.4-2, item 2.i) to refer to piping shown on Tier 1 Figure 2.3.4-2 in lieu of Tier 1 Table 2.3.4-4.

3. Table 2.3.4-4: Replace this table in its entirety with a note indicating this table is not used.

4. Figure 2.3.4-2: Add a new figure titled, Boundaries of Fire Protection System Piping That Must Remain Functional Following a Safe Shutdown Earthquake, depicting a simplified piping schematic of the applicable FPS piping and boundary valves to the manual fire hose station connections. The Tier 1 Figure 2.3.4-2 boundary includes existing interface piping, with the same piping Class RCF as the FPS seismic standpipe, from the Passive Containment Cooling Water Storage Tank (PCCWST), which is the normal source of water supply. With the exception of omitting the FPS containment spray lines (FPS-L701 through FPS-L709), fire hose station lines FPS-L181 and FPS-L183, fire piping FPS-L144, FPS-L154, FPS-L095 and FPS-L123, and FPS-L090A/B, FPS-L091A/B/C and FPS-L092A/B/C, the pipe lines in Tier 1 Table 2.3.4-4 that must remain functional following a safe shutdown earthquake will be included in new Tier 1 Figure 2.3.4-2. Additionally, the new simplified piping schematic shows the addition of two new isolation piping/valves for FPS open-nozzle cable tray suppression systems valve manifolds, and a note that states that piping is designed to remain functional following a safe shutdown earthquake for the piping that is routed to the fire hose stations. The piping includes all Class F fire protection system piping that serves the fire hose valves in containment and the non-radiologically controlled area of the auxiliary building. The piping supplying the containment fire hose valves that must remain functional following an SSE also includes the ASME Class 2 containment isolation piping between FPS-V050 and FPS-V052, as shown on the figure, which are seismic Category I. The pipe lines required to remain functional also includes all Class F piping serving the sprinklers located downstream of valve FPS-V301, which are not shown on Figure 2.3.4-2, that supply the non-1E penetration room sprinklers.

UFSAR (Tier 2) 1. Table 3.2-3: Revise the entry for Containment standpipe and suppression system

components by: (1) clarifying the Tag Number column by replacing “suppression system components” with “fire hose connections”; (2) revising the Description column


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for the spelling of “Reactor”; (3) adding “cable tray suppression” to the exceptions to the provided description of the FPS seismic standpipe.

2. Table 3.2-3: Specify that the entry for Various “components” is actually FPS “piping” in the Description column, and clarify that this only applies to the non-radiologically controlled area of the auxiliary building in the Description column.

3. Table 9.5.1-1: Revise the text in the Remarks column for Item 19 to clarify that the piping serving the standpipe and fire hose connections located inside the containment rather than the fire protection system inside the containment are analyzed to remain functional following an SSE, and that the containment isolation piping is qualified to seismic Category I.

4. Figure 9.5.1-1: Remove fire hose stations F125A and F134A that are fed water through fire pipe lines FPS-L181 and FPS-L183, respectively, from the non-radiologically controlled area of the auxiliary building seismic standpipe. These pipe lines serving these fire hose stations have been re-routed to supply water to the radiologically controlled part of the auxiliary building using a standpipe designated for the radiologically controlled area. Correct the piping classification change for valve FPS-V116 to the outlet of the valve. Add 28 non-pressure regulating (manual) hose valves adjacent to the FPS pressure regulating hose valves. The new non-pressure regulating FPS valves are numbered as VXXXA; the existing pressure regulating FPS valves are renumbered as VXXXB:

V112 (112A/112B), V113 (113A/113B), V114 (114A/114B), V115 (115A,115B), V118 (118A/118B), V119 (119A/119B), V120 (120A/120B), V141 (141A/141B), V142 (142A/142B), V143 (143A/143B), V145 (145A/145B), V146 (146A/146B), V147 (147A/147B), V148 (148A/148B), V149 (149A/149B), V150 (150A/150B), V182 (182A/182B), V191 (191A/191B), V192 (192A/192B), V193 (193A/193B), V194 (194A/194B), V195 (195A/195B), V155 (155A/155B), V156 (156A/156B), V184 (184A/184B), V188 (188A/188B), V189 (189A/189B), V199 (199A/199B)

3. Technical Evaluation

As stated in UFSAR Subsection 9.5.1.1.1:

“The fire protection system is classified as a nonsafety-related, non-seismic system. Special seismic design requirements are applied to portions of the standpipe system located in areas containing equipment required for safe shutdown following a safe shutdown earthquake, as described in Subsection 9.5.1.2.1.5. In addition, the containment isolation valves and associated piping for the fire protection system are safety-related (Safety Class 2) and seismic Category I. The fire protection system is not required to remain functional following a plant accident or the most severe natural phenomena, except as indicated below for a safe shutdown earthquake.

The fire protection system is designed to perform the following functions: • Detect and locate fires and provide operator indication of the location


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• Provide the capability to extinguish fires in any plant area, to protect site personnel, limit fire damage, and enhance safe shutdown capabilities

• Supply fire suppression water at a flow rate and pressure sufficient to satisfy the demand of any automatic sprinkler system plus 500 gpm for fire hoses, for a minimum of 2 hours

• Maintain 100 percent of fire pump design capacity, assuming failure of the largest fire

pump or the loss of offsite power

• Following a safe shutdown earthquake, provide water to hose stations for manual firefighting in areas containing safe shutdown equipment

• Satisfy the requirements of the passive containment cooling system as an alternate

source of water to wet the containment dome or to refill the passive containment cooling water storage tank after a loss-of-coolant accident, if the fire protection system is available

• Provide an alternate supply of cooling water to the normal residual heat removal system heat exchanger after a loss of normal component cooling water system function.

• Provide nonsafety-related containment spray capability for severe accident management.”

As noted above, with the exception of the manual fire suppression “seismic standpipe system” addressed in the fifth bullet, the FPS is not required to remain functional following an SSE except to provide water to these hose stations for manual firefighting. The technical evaluation for the proposed changes addresses these functional descriptions, with additional justification provided as necessary: 1. The following changes are proposed to COL Appendix C (and plant-specific Tier 1)

ITAAC: a. Replace Tier 1 Table 2.3.4-4 in its entirety with Tier 1 Figure 2.3.4-2:

In order to clarify FPS seismic classification and design criteria, it is proposed to replace Tier 1 Table 2.3.4-4 in its entirety with Tier 1 Figure 2.3.4-2, which, instead of listing individual pipe lines, shows the system boundaries (i.e., valves) for FPS piping that must remain functional following an SSE. This change clarifies the description of the boundaries of the FPS piping that must remain functional following an SSE, and consistently applies seismic classification and design criteria to provide assurance that future changes to FPS branch lines and associated components do not adversely affect the seismic design criteria applicable to “hose stations for manual firefighting in areas containing safe shutdown equipment.” The Tier 1 Figure 2.3.4-2 boundary includes existing interface piping, with the same piping Class RCF as the FPS seismic standpipe, from the PCCWST, which is the normal source of water supply. The original purpose of Tier 1 Table 2.3.4-4 was to identify FPS piping that must remain functional following an SSE. This new figure continues to accomplish


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this purpose; therefore, this change has no adverse impact on the ability to accomplish a design function or the ability to perform the associated ITAAC.

b. Remove the SSE functional requirements for FPS containment spray: As discussed in UFSAR Subsection 6.5.2, the AP1000 plant design includes a nonsafety-related, non-seismically qualified FPS containment spray system. As a severe accident management function, the FPS containment spray system provides an additional means of removing airborne particulates after a severe accident, with the primary means of removal of airborne activity by natural processes that do not depend on sprays, such as sedimentation, diffusiophoresis, and thermophoresis (see UFSAR Subsection 6.5.2). The FPS containment spray system is a nonsafety-related, non-seismic, severe accident management feature; therefore, the FPS containment spray system is not credited in any accident analysis. The FPS containment spray system consists of pipe lines FPS-L701 through FPS-L709, all of which are class JCE piping. JCE piping is nonsafety-related (Class E). Therefore, these lines need to be excluded from the seismic standpipe, as the appropriate piping class for inclusion in Tier 1 Table 2.3.4-4 is RCF (seismic standpipe piping, nonsafety-related piping subject to special seismic analysis to remain functional following an SSE, Class F), or JCB (seismic Category I safety-related piping), which is true of the remainder of the pipe lines currently shown in Tier 1 Table 2.3.4-4. UFSAR Table 3.2-3, under the “Containment standpipe and suppression system components” line (proposed to be “Containment standpipe and fire hose connections”) confirms the Class F classification. Because the FPS containment spray system does not provide “water to hose stations for manual firefighting in areas containing safe shutdown equipment” per UFSAR Subsection 9.5.1.1.1, and is not credited for any accident analysis per UFSAR Subsection 6.5.2, it is determined that this change has no adverse impact on the ability to accomplish a design function.

c. Remove the SSE functional requirements for fire hose station lines FPS-L181 and FPS-L183: As shown on UFSAR Figure 9.5.1-1, the current water source for fire hose stations FPS-PY-F125A and FPS-PY-F134A is the seismically analyzed standpipe that serves the non-radiologically controlled side of the auxiliary building. The seismic standpipe in this area is dedicated to feeding fire suppression equipment that protects safety-related equipment required for safe shutdown. However, fire hose stations F125A and F134A, which are fed water through fire pipe lines FPS-L181 and FPS-L183, respectively, and are currently identified in plant-specific Tier 1 Table 2.3.4-4, are not credited to serve safety-related equipment required for safe shutdown. Therefore, the pipe lines serving these fire hose stations have been re-routed to supply water to the radiologically controlled part of the auxiliary building using a standpipe designated for the radiologically controlled area. Because FPS fire hose stations F125A and F134A do not provide “water to hose stations for manual firefighting in areas containing safe shutdown equipment” per UFSAR Subsection 9.5.1.1.1, and are not credited for any accident analysis per


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UFSAR Subsection 6.5.2, it is determined that this change has no adverse impact on the ability to accomplish a design function.

d. Remove the SSE functional requirements from fire hose station lines FPS-L144, FPS-L154, FPS-L095, and FPS-L123: Fire pipe lines FPS-L144 and FPS-L154 are omitted as a result of the consolidation of two fire hose stations (F127A/B) into a single hose station (F127), which is fed by pipe line FPS-L143, due to the elimination of the lower annulus room/corridor (room 12243). Room 12243 was eliminated from the AP1000 design in DCD Tier 2 prior to issuance of DCD Revision 19. Pipe reducers are removed from fire pipe lines FPS-L095 and FPS-L123, resulting in the consolidation of these fire pipe lines into fire pipe lines FPS-L131 and FPS-L130, respectively. These changes therefore have no adverse impact on the ability to accomplish a design function.

e. Remove the SSE functional requirements from fire lines FPS-L090A/B, FPS-L091A/B/C, and FPS-L092A/B/C: Fire pipe lines FPS-L090A/B, FPS-L091A/B/C and FPS-L092A/B/C are removed from Tier 1 Table 2.3.4-4, because these lines are downstream of valves FPS-V133A, B, and C, as discussed in the Note on new Tier 1 Figure 2.3.4-2. This change therefore has no adverse impact on the ability to accomplish a design function.

f. Include the additional open-nozzle cable tray suppression manifolds: The addition of two open-nozzle cable tray suppression systems is proposed in order to provide balanced spray coverage considering the locations and configurations of the raceways. This proposed change allows the FPS open-nozzle cable tray suppression system to continue to support the UFSAR Subsection 9A.3.1.1.8 requirement for the use of water spray systems to limit smoke and heat generation from fire in the open cable trays in fire zone 1100 AF 11300B. The new five-branch manifold design, including the addition of system isolation valves FPS-V133D and FPS-V133E, will also be relocated to accommodate the additional two branches and to provide adequate space for construction, operations, maintenance, inspections, and testing. While in a different location, the new manifold will still be in the same radiation zone and as such, the manifold valves will be qualified to the same radiation requirements as its previous location. This change therefore has no adverse impact on the ability to accomplish a design function.

2. The proposed modifications to Tier 1 Subsection 2.3.4 address consistency changes, which instead of referencing current Tier 1 Table 2.3.4-4, references the proposed Tier 1 Figure 2.3.4-2. This change has no adverse impact on a design function or the ability to perform the ITAAC because the original intent of ITAAC Table 2.3.4-4 is still met.

3. The proposed modifications to Tier 1 Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, address consistency changes, by referencing proposed Tier 1 Figure 2.3.4-2 instead of referencing current Tier 1 Table 2.3.4-4. This change has no adverse impact on a design function or the ability to perform the ITAAC because the original intent of Table 2.3.4-4 is still met.


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4. Five changes are proposed to UFSAR Table 3.2-3 “AP1000 Classification of Mechanical

and Fluid Systems, Components, and Equipment,” four for clarity and one editorial change: a. In the Tag Number column for Containment standpipe and suppression system

components, replace “suppression system components” with “fire hose connections”: Special seismic design requirements are applied to portions of the nonsafety-related manual fire suppression standpipe system that are located in areas containing equipment required for safe shutdown following an SSE. With the exception of the “seismic standpipe system” that provides water to these fire hose stations for manual firefighting; the FPS is not required to remain functional following an SSE. BTP 9.5.1 and NFPA 804 requirements for seismically functional fire hose and standpipe systems do not extend to the fire suppression spray and sprinkler systems. Standpipe and hose systems are “fixed piping systems with hose valves, hose, and nozzles connected to a reliable water supply to provide effective fire hose streams to specific areas inside the building.” Suppression systems include manual (hydrants, standpipes and extinguishers) and automatic (sprinklers and sprays) fire suppression component and system capabilities. Replacing “suppression system components” with “fire hose connections” is therefore consistent with the functional description of the FPS as stated in UFSAR Subsection 9.5.1.1.1 that states that the FPS will, “following a safe shutdown earthquake, provide water to hose stations for manual firefighting in areas containing safe shutdown equipment.” These hose stations and hose connections, together with the associated standpipes, constitute the seismic standpipe system. Only the piping and fire hose valves that must remain functional for the manual fire hose stations following an SSE require seismic analysis, not all FPS components. This change is consistent with changes made in Tier 1 Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, in which the ITAAC is provided for FPS piping only, not components. There are separate ITAAC entries in Tier 1 for providing manual firefighting capability in areas containing safe shutdown equipment (ITAAC No. 2.3.04.04.ii) and the nonsafety-related containment spray (ITAAC No. 2.3.04.06), and other ITAAC for specific components such as containment isolation piping/valves (ITAAC No. 2.3.04.03). Specific entries are made to UFSAR Table 3.2-3 for components, such as containment isolation valves and penetrations, that are safety-related. There is a separate entry in Table 3.2-3 for the balance of system FPS components not explicitly described in the table that identifies the remainder of the FPS components as Class E, F and G (nonsafety-related). It is determined that this clarification change has no adverse impact on the ability to accomplish a design function.

b. In the Description column, replace “Rector” with “Reactor”: An editorial change is proposed to the table to correct the spelling of “Reactor” (currently “Rector” in the table). This editorial change does not involve a technical modification, and therefore has no adverse impact on the ability to accomplish a design function.


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c. In the Description column for containment standpipe and suppression system components, add “cable tray suppression” to the identified exceptions to signify that the FPS open-nozzle suppression spray system is not bounded by SSE functional requirements: The FPS open-nozzle cable tray suppression system is a sprinkler system used to spray nonsafety-related open cable trays. The FPS open-nozzle suppression system supports UFSAR requirements in avoiding extensive burning of the nonsafety-related cables leading to a fire that propagates outside of its originating fire zone or leading to an adverse impact to both the divisions A/C and B/D safety-related cables located within a fire zone during a fire event. No credit is taken for the FPS cable tray spray fire suppression following a seismic event and water flow to this system would be prevented by closing the manual isolation valves (FPS-V133A/B/C/D/E) to the cable tray spray system branches. FPS cable tray spray system operation following an SSE would be detrimental to the functioning of the FPS seismic standpipe system, as it would divert water flow dedicated for the manual firefighting fire hose stations. Because the FPS open-nozzle cable tray suppression system does not meet the description of providing “water to hose stations for manual firefighting in areas containing safe shutdown equipment” nor has it been credited for any accident analysis, this change has no adverse impact on the ability to accomplish any design function.

d. In the Description column for the “Various” tag numbers, insert “(Non-Radiologically Controlled)” after Auxiliary Building and replace Non-1E equipment room preaction sprinkler system “components” with “piping”: The only portion of the auxiliary building that requires seismic analysis consistent with ASME Section III Class 3 is the Class F piping in the non-radiologically controlled area. The auxiliary building standpipes in the radiologically controlled area of the auxiliary building are Class G and do not require additional seismic analysis. As a result, the Description column is clarified to state that only the FPS Class F piping in the non-radiologically controlled area of the auxiliary building will be seismically analyzed in accordance with the requirements of ASME Section III Class 3. Only the piping/valves, and not other components, that must remain functional for the manual fire hose stations following an SSE requires seismic analysis. Specific entries are made to UFSAR Table 3.2-3 for components such as containment isolation valves and penetrations that are safety-related. There is a separate entry in Table 3.2-3 for the balance of system FPS components not explicitly described in the table that identifies the remainder of the FPS components as Class E, F, and G. This change is consistent with proposed changes to Tier 1 Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii in which the ITAAC is provided for FPS piping only, not components. There are separate ITAAC entries in Tier 1 for providing manual firefighting capability in areas containing safe shutdown equipment (ITAAC No. 2.3.04.04.ii) and the nonsafety-related containment spray (ITAAC No. 2.3.04.06), and other ITAACs for specific components such as containment isolation (ITAAC No. 2.3.04.03).


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Therefore, these changes have no adverse impact on the ability to accomplish a design function, but instead provide clarification that the FPS piping that must remain functional following a safe shutdown earthquake is subject to a seismic analysis consistent with ASME Section III Class 3 systems.

5. Two changes are proposed to UFSAR Table 9.5.1-1: a. Seismic Analysis of FPS Piping/Valves:

UFSAR Table 9.5.1-1, Item 19, states: “The fire suppression systems located inside the containment are qualified to seismic Category I criteria…” This statement requires clarification, because while these seismic portions of the FPS are designed to remain functional following an SSE, they are not fully qualified as seismic Category I. The piping system serving the hose stations in containment is analyzed for safe shutdown and earthquake loading and provided with supports that ensure pressure boundary integrity. The piping for the seismic standpipe system satisfies at a minimum, the requirements of ANSI B31.1, Code for Power Piping, and additionally, the piping seismic analysis is consistent with ASME Section III Class 3 systems identified in UFSAR Table 3.2-3. UFSAR Table 3.2-3, under the “Containment standpipe and suppression system components” entry (proposed to be “Containment standpipe and fire hose connections”) confirms that seismic analysis is consistent with ASME Section III Class 3 systems, and analyzed consistently with seismic Category I piping. Therefore, there is no reduction in functionality or reliability. It is therefore determined that this change has no adverse impact on the ability to accomplish a design function. It is also necessary to clarify that the containment isolation piping in UFSAR Table 9.5.1-1 is qualified to seismic Category I criteria. There is therefore no adverse impact on the ability to accomplish a design function associated with this change.

b. Replace “fire suppression systems” with “piping serving the standpipe and fire hose connections”: The FPS is a nonsafety-related, non-seismic system, in accordance with BTP CMEB 9.5-1, with special seismic design requirements applied to portions of the manual fire suppression standpipe system that are located in areas containing equipment required for safe shutdown following an SSE. With the exception of the “seismic standpipe system,” the FPS is not required to remain functional following an SSE, except to provide water to these hose stations for manual firefighting. BTP CMEB 9.5.1 and NFPA 804 requirements for seismically functional fire hose and standpipe systems do not extend to the fire suppression systems. Replacing “fire suppression systems” with “piping serving the standpipe and fire hose connections” is consistent with the functional description of the FPS as stated in UFSAR Subsection 9.5.1.1.1. This change provides clarification that only the piping serving the containment standpipe and fire hose connections for manual firefighting remain functional following an SSE, not the entire fire suppression system. This change


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therefore does not introduce an adverse impact on the ability to accomplish a design function.

6. Revise Figure 9.5.1-1, Sheet 3 of 3, to include the addition of 28 non-pressure regulating (manual) hose valves: As identified in UFSAR Subsection 9.5.1.2.1.5, the FPS seismic standpipe subsystem is normally aligned with the PCCWST as the primary source of water. The seismic standpipe subsystem can also be supplied from the FPS fire main by opening the normally closed cross-connect valve (FPS-V101) with the plant fire main. The seismic standpipe supply line draws water from a portion of the PCCWST allocated for fire protection. The FPS and PCS supplies have different water supply conditions (flow and pressure) and volumes. When the FPS fire main is aligned to supply water to the seismic standpipe subsystem, the use of pressure regulating hose valves is required to reduce the pressure of the water for firefighting purposes. The proposed change adds non-pressure regulating hose valves and associated piping to the existing FPS seismic standpipe hose stations to allow for an effective hose stream when using the PCS supply to the seismic standpipe system. The new piping and non-pressure regulating hose valve connections meet the existing piping class and seismic analysis as the seismic standpipe. Therefore, this change has no adverse impact on the ability to accomplish any design function.

These proposed changes do not reduce functionality or reliability, nor have an adverse impact on the ability to accomplish a design function. Furthermore, the FPS continues to meet the existing design requirements described in UFSAR Subsection 9.5.1.1.1, as the following aspects of the design remain valid:

1. Containment isolation and integrity is maintained.

2. The flow path to the standpipes and fire hose valves is maintained.

3. The severe accident mitigation capability is maintained.

4. Seismic interaction guidelines are still followed.

Therefore, the proposed changes would not adversely affect any design function, safety-related equipment or function, safety analysis, or radioactive material barrier. The proposed changes resolve inconsistencies in the current licensing basis and do not adversely affect the design functions of the FPS described above. The FPS continues to meet the same regulatory acceptance criteria, codes, and industry standards specified in the UFSAR. The physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the UFSAR are changed due to the addition of two open-nozzle suppression systems to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. However, the function, compliance with BTP CMEB 9.5-1 requirements, and design of the additional open-nozzle suppression systems are the same as the existing cable tray suppression systems; therefore, the physical design and operation of the FPS remains the same. The


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proposed changes comply with the requirements of 10 CFR Part 50 Appendix A, General Design Criteria (GDC) 2 and 3, as stated in the UFSAR. The proposed changes do not require a change to procedures or method of control that adversely affects the performance of the FPS nonsafety-related design functions as described in the UFSAR. The physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the UFSAR has changed due to the addition of two open-nozzle suppression systems with associated system isolation valves to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. However, the function, compliance with BTP CMEB 9.5-1 requirements, and design of the additional open-nozzle suppression systems are the same as the existing cable tray suppression systems; therefore, the method of control and procedures used for the open-nozzle suppression systems for spray coverage is not changed. The proposed changes maintain the design functions of the FPS for any fire suppression following an SSE. An impact review has determined that these proposed changes do not affect or require any change to the AP1000 PRA presented in UFSAR Chapter 19, including the Fire PRA, results and insights (e.g., core damage frequency and large release frequency). The physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the UFSAR are changed due to the addition of two open-nozzle suppression systems with associated system isolation valves to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. However, the additional open-nozzle suppression spray systems for spray coverage employs the same methodology for fire suppression following an SSE as the current cable tray spray suppression systems, and thus, no changes are required to the AP1000 PRA to address the proposed licensing basis changes. There are no new postulated failures of the FPS required in the PRA model. Therefore, there are no changes required to initiating event frequencies and system logic models of the PRA, including the Seismic Margins Analysis. The existing PRA risk significance investment protection determination for the FPS is not affected. There are no radiation zone changes or radiological access control changes required because of these proposed changes. The physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the UFSAR are changed due to the addition of open-nozzle suppression systems with associated system isolation valves to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. However, no changes are required to the radiation protection design features described in UFSAR Section 12.3 as the radiation zones identified and radiological control features remain the same. There are no fire area changes required because of these proposed changes. The physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the UFSAR are changed due to the addition of two open-nozzle suppression systems with associated system isolation valves to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. However, the fire protection analysis described in UFSAR Appendix 9A remains unaffected because the same fire suppression methodology is employed.


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There is no change to the risk-significant designation of SSCs within the Design Reliability Assurance Program (D-RAP) as described in UFSAR Table 17.4-1, as the physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the UFSAR, are not changed due to the addition of two open-nozzle suppression systems with associated system isolation valves to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. However, the FPS is a nonsafety-related system and there are no risk-significant designations of SSCs in the D-RAP. 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 affected. The types and quantities of expected effluents are not changed. Therefore, neither radioactive, nor non-radioactive, material effluents are affected. The proposed changes do not affect plant radiation zones, controls under 10 CFR Part 20, and expected amounts and types of radioactive materials, as the physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the UFSAR are not changed. Therefore, individual and cumulative radiation exposures do not change. The proposed changes do not affect the results of the aircraft impact assessment described in UFSAR Section 19F.4. Summary The proposed changes affect the COL concerning the ITAAC for the FPS piping. The proposed changes revise UFSAR Tables 3.2-3 and 9.5.1-1, and COL Appendix C (and plant-specific Tier 1) Subsection 2.3.4, Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, and Table 2.3.4-4, with corresponding changes to the associated plant-specific DCD Tier 1 information, for inspections of the as-built FPS to clarify those portions of the FPS that are required to be functional following an SSE. The proposed changes clarify information necessary to verify that the FPS is constructed in accordance with the design certification as verified by COL Appendix C (and plant-specific Tier 1) ITAAC. The proposed changes maintain the design functions of the FPS to mitigate any potential fires in areas containing equipment required for safe shutdown following an SSE. Therefore, the FPS nonsafety-related design functions described in the UFSAR are not adversely affected by these proposed changes to Tier 2 UFSAR Tables 3.2-3 and 9.5.1-1, and Figure 9.5.1-1 information, and COL Appendix C (and plant-specific Tier 1) Subsection 2.3.4. The proposed changes do not adversely affect any safety-related equipment or function, design function, radioactive material barrier, or safety analysis.


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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 Combined License (COL). These activities involve a change to COL Appendix C Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) information, with corresponding changes to the associated plant-specific Tier 1 information. Therefore, NRC approval is required prior to making the plant-specific proposed 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 changes for the fire protection system, which include changes to Updated Final Safety Analysis Report (UFSAR) Table 3.2-3, Table 9.5-1, and Figure 9.5.1-1 involve a revision to COL Appendix C (and plant-specific Tier 1) ITAAC Subsection 2.3.4, Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, and Table 2.3.4-4. Therefore, NRC approval is required for the Tier 2 and Tier 1 departures.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 2 requires that structures, systems and components important to safety be designed to withstand the effects of natural phenomena, such as earthquakes. The proposed changes for the FPS, which include changes to UFSAR Tables 3.2-3 and 9.5.1-1, and Figure 9.5.1-1, involves a revision to COL Appendix C (and plant-specific Tier 1) ITAAC Subsection 2.3.4, Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, and Table 2.3.4-4 changes the FPS physical design due to the addition of two open-nozzle suppression systems with associated system isolation valves to provide additional spray coverage to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. However, the additional spray systems are similar design to the existing cable tray suppression systems, and meet the existing FPS seismic design requirements. As described in UFSAR Subsection 9.5.1.1.1., the only function of the FPS following a design basis earthquake is to provide water to hose stations for manual firefighting in areas containing safe shutdown equipment. Therefore, the proposed changes comply with the requirements of GDC 2.

10 CFR Part 50, Appendix A, GDC 3 requires that structures, systems, and components important to safety shall be designed and located to minimize, consistent with other safety requirements, the probability and effect of fires and explosions. Noncombustible and heat resistant materials shall be used wherever practical throughout the unit, particularly in locations such as the containment and control room. Fire detection and fighting systems of appropriate capacity and capability shall be provided and designed to minimize the adverse effects of fires on structures, systems, and components important to safety. Firefighting systems shall be designed to assure that their rupture or inadvertent operation does not significantly impair the safety capability of these structures, systems, and components. The proposed changes for the FPS, which involve a revision to COL Appendix C (plant-specific Tier 1) ITAAC Subsection 2.3.4, Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, and Table 2.3.4-4, maintain the


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physical design capability of the FPS water hose stations for manual firefighting in areas containing safe shutdown equipment following a design basis earthquake as required by this criterion and as described in UFSAR Subsection 9.5.1.1.1. Therefore, the proposed changes comply with the requirements of GDC 3.

4.2 Precedent

No precedent is identified.

4.3 Significant Hazards Consideration Determination The proposed changes affect the Combined License (COL) concerning the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) for the fire protection system (FPS) by clarifying the boundaries for the portion of the FPS required to remain functional following a safe shutdown earthquake (SSE). The requested amendment requires changes to Updated Final Safety Analysis Report (UFSAR) Tables 3.2-3 and 9.5.1-1, and Figure 9.5.1-1, and COL Appendix C (and plant-specific Tier 1) ITAAC Subsection 2.3.4, Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, and Table 2.3.4-4, for inspections of the as-built FPS by clarifying the boundaries of the FPS that must remain functional following an SSE for manual fire suppression capabilities in safe shutdown equipment areas. An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, “Issuance of amendment,” as discussed below: 4.3.1 Does the proposed amendment involve a significant increase in the

probability or consequences of an accident previously evaluated? Response: No The proposed modification changes would clarify the boundaries for the portion of the nonsafety-related fire protection system (FPS) required to remain functional following a safe shutdown earthquake (SSE) for manual firefighting in areas with SSE equipment, and the addition of two new open-nozzle suppression systems with associated system isolation valves to provide adequate spray coverage to accommodate the final cable tray location, configuration and quantity. These changes do not affect any accident initiating event or component failure, thus the probabilities of the accidents previously evaluated are not adversely 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 adversely affected. Therefore, the proposed amendment does not involve an increase in the probability or consequences of an accident previously evaluated. Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.


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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 clarification of the boundaries for the portion of the nonsafety-related FPS required to remain functional following a SSE for manual firefighting in areas with equipment required for safe shutdown following an SSE does not affect the operation of any systems or equipment that may initiate a new or different kind of accident, or alter any SSC such that a new accident initiator or initiating sequence of events is created. The proposed changes affect the physical design and operation of the FPS, including as-installed inspections, testing, and maintenance requirements, as described in the Updated Final Safety Analysis Report (UFSAR) due to the addition of two open-nozzle suppression systems with associated system isolation valves. However, the additional open-nozzle suppression systems with associated system isolation valves are similar in design and function as the existing cable tray suppression systems and raceway covers. Therefore, the operation of the FPS is not affected. These proposed changes do not adversely affect any other SSC design functions or methods of operation in a manner that results in a new failure mode, malfunction, or sequence of events that affect safety-related or nonsafety-related equipment. Therefore, this activity does 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 results in significant fuel cladding failures. Therefore, the requested 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 clarification of the boundaries for the portion of the FPS required to remain functional following a SSE, and the addition of two new open-nozzle suppression systems with associated system isolation valves do not affect any safety or accident analysis as the FPS is a nonsafety-related system. The only function of the FPS following a design basis earthquake is to provide water for hose valves for manual firefighting in safe shutdown equipment areas. The proposed changes continue to meet the existing design basis, design function, regulatory criterion, or analyses. Therefore, the proposed changes satisfy the same design functions in accordance with the codes and standards currently stated in the UFSAR. These changes do not adversely affect any design code, function, design analysis, safety analysis input or result, or design/safety margin. No safety analysis or design basis acceptance limit/criterion is challenged or exceeded by the proposed changes, and no margin of safety is reduced. Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.


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Based on the above, 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.

4.4 Conclusions

Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission’s regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. The above evaluations demonstrate that the requested changes can be accommodated without an increase in the probability or consequences of an accident previously evaluated, without creating the possibility of a new or different kind of accident from any accident previously evaluated, and without a significant reduction in a margin of safety. Having arrived at negative declarations with regard to the criteria of 10 CFR 50.92, this assessment determined that the requested change does not involve a Significant Hazards Consideration.

5. Environmental Considerations

The proposed changes affect the Combined License (COL) concerning the Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) and plant-specific Tier 1 ITAAC for the fire protection system (FPS). The requested amendment requires a change to a revision to COL Appendix C (plant-specific Tier 1) ITAAC Subsection 2.3.4, Table 2.3.4-2, ITAAC Nos. 2.3.04.02.i and 2.3.04.02.ii, and Table 2.3.4-4, for inspections of the as built FPS by clarifying the boundaries of the FPS that must remain functional following an SSE for manual fire suppression capabilities in safe shutdown equipment areas. A review has determined that the requested 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 Part 20, or would change an inspection or surveillance requirement. However, facility construction and operation following implementation of the requested amendment 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. Accordingly, the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that: (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 or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, “Issuance of amendment.” The Significant Hazards Consideration Determination 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 from 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


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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 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 design functions or operational features credited with controlling the release of effluents during plant operation. Therefore, the requested amendment does not involve a significant change in the types or a 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 do not adversely affect walls, floors, or other structures that provide shielding. Plant radiation zones are not affected, and there are no changes to the controls required by 10 CFR Part 20 that preclude a significant increase in occupational radiation exposure. Therefore, the requested 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 impacts 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 the individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

6. References

None


NND-17-0288

Enclosure 2


Exemption Request:

FPS Piping That Must Remain Functional Following an SSE

(LAR 17-15)

(Enclosure 2 consist 7 pages, including this cover page)

NND-17-0288 Enclosure 2 Exemption Request: FPS Piping That Must Remain Functional Following an SSE (LAR 17-15)

Page 2 of 7

1.0 PURPOSE

South Carolina Electric & Gas Company (the Licensee) requests a permanent exemption from the provisions of 10 CFR 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, to allow a departure from elements of the certification information in Tier 1 of the generic 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. The Tier 1 information for which a plant-specific departure and exemption is requested is related to changes to better define the boundaries and seismic requirements for the portion of the fire protection system (FPS) piping that is required to remain functional following a safe shutdown earthquake (SSE); i.e., the “seismic standpipe system”. 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 changes to the system-based design descriptions in plant-specific Tier 1 Table 3.3-6:

• Tier 1 Subsection 2.3.4: o Revise to add refer to information shown in Tier 1 Figure 2.3.4-2, in lieu of

Tier 1 Table 2.3.4-4.

• Tier 1 Table 2.3.4-2 Item 2.i): o Revise Design Commitment (DC), Inspections, Tests, Analyses (ITA) and

Acceptance Criteria (AC) to refer to piping shown on Tier 1 Figure 2.3.4-2 in lieu of Tier 1 Table 2.3.4-4.

• Tier 1 Table 2.3.4-2 Item 2.i): o Revise DC to refer to piping shown on Tier 1 Figure 2.3.4-2 in lieu of Tier 1

Table 2.3.4-4.

• Tier 1 Table 2.3.4-4: o Delete Table 2.3.4-4 in its entirety and replace with a Note stating that the

table is not used.

• Tier 1 Figure 2.3.4-2: o Insert a new Figure 2.3.4-2 depicting boundaries (i.e., valves) for FPS piping

that must remain functional following an SSE. FPS pipe lines that were included in Tier 1 Table 2.3.4-3 and are specifically omitted from Figure 2.3.4-2 are the FPS containment spray system pipe lines (FPS-L701 through FPS-L709), FPS pipe lines that feed fire hose stations F125A and F134A off a non-seismic fire pipe line (FPS-L181 and FPS-L183), fire pipe lines that were eliminated due to the due to the consolidation of fire hose stations when the lower annulus room/corridor was removed from the plant design (FPS-L144 and FPS-L154), two fire pipe lines that were consolidated with two other pipes when pipe reducers were removed from the adjoining fire pipes (FPS-L095 and FPS-L123), and fire pipe lines FPS-L090A/B,


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FPS-L091A/B/C and FPS-L092A/B/C that are downstream of valves FPS-V133A, B, and C, as discussed in the Note on new Tier 1 Figure 2.3.4-2.

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

2.0 BACKGROUND

The Licensee is the holder of Combined License Nos. NPF-93 and NPF-94, which authorize construction and operation of two Westinghouse Electric Company AP1000 nuclear plants, named Virgil C. Summer Nuclear Station (VCSNS) Units 2 and 3, respectively. Plant-specific DCD Tier 1 Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) Subsection 2.3.4, Design Description 2, currently identifies that the FPS piping identified in Tier 1 Table 2.3.4-4 must remain functional following an SSE, referred to as the “seismic standpipe system.” This is verified by inspection and a reconciliation analysis of the pipe lines identified in Table 2.3.4-4. However, to allow more flexibility to add or remove FPS pipe lines from this seismic standpipe system as the plant design evolves, and provide a more clear depiction of the FPS seismic standpipe system, the Table 2.3.4-4 list of pipe line numbers is replaced with a new plant-specific Tier 1 figure, Figure 2.3.4-2, depicting the seismic standpipe system, including the boundaries (i.e., valves) for FPS piping that must remain functional following an SSE. New Tier 1 Figure 2.3.4-2 also includes a note specifying the requirement that piping within the boundary valves on this figure, including all Class RCF and JCB fire protection system piping in containment and the non-radiologically controlled area of the auxiliary building, are designed to remain functional following an SSE. The note on Figure 2.3.4-2 also specifies that piping downstream of boundary valve V301 must remain functional following an SSE.

3.0 TECHNICAL JUSTIFICATION OF ACCEPTABILITY

The requested exemption will allow the Licensee to depart from generic AP1000 DCD Table 2.3.4-4 by replacing this table with plant-specific Tier 1 Figure 2.3.4-2. The original DCD Table 2.3.4-4 identified the specific line numbers in the FPS that must remain functional following an SSE, and the plant-specific Table 2.3.4-2 also identifies the same FPS piping, except with the use of a simplified figure that shows the boundaries (i.e., valves) of the FPS seismic standpipe system and a provides a note that specifies that the FPS piping located within the boundary valves is designed to remain functional following an SSE. The depiction of the seismic standpipe system and associated boundary valves, together with a clarifying note specifying that the piping located within the boundary valves, including the piping downstream of valve V301, and all Class RCF and JCB FPS piping in containment and the non-radiologically controlled area of the auxiliary building, provides assurance that the associated ITAAC in Tier 1 Table 2.3.4-2, ITAAC items 2.i) and 2.ii) will continue to provide the same assurance that the hose stations for manual firefighting in areas containing safe shutdown equipment as that provided by the list of FPS line numbers in Tier 1 Table 2.3.4-4.


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Furthermore, the FPS pipe lines specifically identified as being deleted from current Tier 1 Table 2.3.4-4 (and omitted from new Figure 2.3.4-2) do not supply fire water to hose stations for manual firefighting in areas containing safe shutdown equipment, and accordingly their omission is consistent with the current Tier 1 Subsection 2.3.4 Design Description number 2 requirement that the FPS piping in Tier 1 Table 2.3.4-4 remains functional following an SSE. Detailed technical justification supporting this request for exemption is provided in Section 3 of the associated License Amendment Request in Enclosure 1 of this letter.

4.0 JUSTIFICATION FOR PROPOSED 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 the Licensee has identified 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 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 changes to the description of the acceptable configurations satisfies the criteria for granting specific exemptions, as described below. 1. This exemption is authorized by law

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


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reflect the approved licensing basis for VCSNS Units 2 and 3, 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. The proposed changes will not impact the ability of the components to perform their design functions. There is no change to plant systems or the response of systems to postulated accident conditions. There is no change to the predicted radioactive releases due to postulated accident conditions. The plant response to previously evaluated accidents or external events is not adversely affected, and the change described does not create any new accident precursors. Therefore, no adverse safety impact that would present any additional risk to the health and safety of the public is present. The replacement of the list of pipe lines that must remain functional following an SSE with a figure depicting these pipe lines, including the boundary valves for this seismic standpipe system in the plant-specific Tier 1 DCD will also continue to provide the detail necessary to support the performance of the associated ITAAC.

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

3. The exemption is consistent with the common defense and security

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

4. Special circumstances are present

10 CFR 50.12(a)(2) lists six “special circumstances” for which an exemption may be granted. Pursuant to the regulation, it is necessary for one of these special circumstances to be present in order for the NRC to consider granting an exemption request. The requested exemption meets the special circumstances of 10 CFR 50.12(a)(2)(ii). That subsection defines special circumstances as when “Application of the regulation in the particular circumstances would not serve the underlying purpose of the rule or is not necessary to achieve the underlying purpose of the rule.” The rule under consideration in this request for exemption is 10 CFR Part 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 VCSNS Units 2 and 3 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,


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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 changes provide an alternative means of specifically identifying the FPS piping that is required to remain functional to protect safe shutdown equipment following an SSE, while enabling the Licensee to add or remove FPS piping from this listing as the detailed design of the FPS identifies additional piping to be included or excluded from the seismic standpipe system. The proposed changes do not impact the ability of any structures, systems, or components 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 intent of the scope and contents of the design certified by the NRC in 10 CFR Part 52, Appendix D. Therefore, special circumstances are present, because application of the current plant-specific certified design information in Tier 1 as required by 10 CFR Part 52, Appendix D, Section III.B in the particular circumstances discussed in this request is not necessary to achieve the underlying purpose of the rule.

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

Based on the nature of the changes to the plant-specific Tier 1 information in the proposed areas and the understanding that these changes are not related to system functions, these changes will not have a negative impact. Nevertheless, if other AP1000 licensees do not elect to request this exemption, the special circumstances continue to outweigh any decrease in safety from the reduction in standardization because the key design functions associated with this request will continue to be maintained. This exemption request proposing the replacement of the list of FPS pipe line numbers in plant-specific Tier 1 Table 2.3.4-4 with the simplified plant-specific Figure 2.3.4-2 depicting the FPS piping that must remain functional following an SSE demonstrates that there is a minimal change from the generic 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 does not adversely impact the level of safety because the changes associated with this exemption request will not adversely affect the ability of any systems or equipment to perform their design functions, there are no new failure modes introduced by these changes and the level of safety provided by the current systems and equipment is maintained. It is concluded that the design change associated with this proposed exemption will not result in a significant decrease in the level of safety.


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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 identified.

7.0 ENVIRONMENTAL CONSIDERATION The Licensee requests a departure from elements of the certified information in Tier 1 of the generic AP1000 DCD. The Licensee has determined that the proposed departure would require a permanent exemption from the requirements of 10 CFR 52, Appendix D, Section III.B, Design Certification Rule for the AP1000 Design, Scope and Contents, with respect to installation or use of facility components located within the restricted area, as defined in 10 CFR Part 20, or which changes an inspection or a surveillance requirement; however, the Licensee evaluation of the proposed exemption has determined that the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Based on the above review of the proposed exemption, the Licensee has determined that the proposed activity does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in the individual or cumulative occupational radiation exposure. Accordingly, the proposed exemption meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed exemption is not required. Specific details of the environmental considerations supporting this request for exemption are provided in Section 5 of the associated License Amendment Request provided in Enclosure 1 of this letter.

8.0 CONCLUSION

The proposed changes to Tier 1 information are necessary and the exemption request was confirmed to meet the requirements of 10 CFR 52.63, “Finality of standard design certifications,” 10 CFR 50.12, “Specific exemptions,” and 10 CFR 52 Appendix D, “Design Certification Rule for the AP1000 Design.” Specifically, the exemption request meets the criteria of 10 CFR 50.12(a)(1) in that the request is authorized by law, presents no undue risk to public health and safety, and is consistent with the common defense and security. Furthermore, approval of this request does not result in a significant decrease in the level of safety, presents special circumstances, does not present a significant decrease in safety as a result of a reduction in standardization, and meets the eligibility requirements for categorical exclusion.

9.0 REFERENCES None


NND-17-0288

Enclosure 3


Proposed Changes to the Licensing Basis Documents

(LAR 17-15)

Note: Added text is shown as bold Blue Underline

Deleted text is shown as bold Red Strikethrough

* * * indicates omitted existing text that is not shown

(Enclosure 3 consist of 6 pages, including this cover page)

NND-17-0288 Enclosure 3 Proposed Changes to the Licensing Basis Documents (LAR 17-15)

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COL Appendix C (and plant-specific Tier 1) Subsection 2.3.4, Fire Protection System

Revise Design Description item 2, as shown below:

2. The FPS piping identified in Table 2.3.4-4 shown on Figure 2.3.4-2 remains functional following a safe shutdown earthquake.

COL Appendix C (and plant-specific Tier 1) Table 2.3.4-2, Inspections, Tests, Analyses, and Acceptance Criteria

Revise Table 2.3.4-2, ITAAC 2.3.04.02.i and 2.3.04.02.ii [plant-specific Tier 1 items 2.i) and 2.ii)], as shown below:

Design Commitment Inspections, Tests,

Analyses Acceptance Criteria

2. The FPS piping identified in Table 2.3.4-4 shown on Figure 2.3.4-2 remains functional following a safe shutdown earthquake.

i) Inspection will be performed to verify that the piping identified in Table 2.3.4-4 shown on Figure 2.3.4-2 is located on the Nuclear Island.

i) The piping identified in Table 2.3.4-4 shown on Figure 2.3.4-2 is located on the Nuclear Island.

ii) A reconciliation analysis using the as-designed and as-built piping information will be performed, or an analysis of the as-built piping will be performed.

ii) The as-built piping stress report exists and concludes that the piping remains functional following a safe shutdown earthquake.

COL Appendix C (and plant-specific Tier 1) Table 2.3.4-4, FPS Piping Which Must Remain Functional Following a Safe Shutdown Earthquake

Delete Table 2.3.4-4 and insert the following text in its place:

This Table not used.

COL Appendix C (and plant-specific Tier 1) new Figure 2.3.4-2, Boundaries of Fire Protection System Piping That Must Remain Functional Following a Safe Shutdown Earthquake

Insert new Figure 2.3.4-2 after current Figure 2.3.4-1, as shown on the following page.

Figure 2.3.4-2 x

Boundaries of Fire Protection System Piping That Must Remain Functional Following a Safe Shutdown Earthquake


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Updated Final Safety Analysis Report (UFSAR) Table 3.2-3, AP1000 Classification of Mechanical and Fluid Systems, Components, and Equipment

Revise Table 3.2-3, as shown below:

Tag Number Description AP1000 Class

Seismic Category

Principal Con- struction Code Comments

* * * Fire Protection System (FPS)

* * *

FPS-PL-V702 FPS Containment Penetration Thermal Relief Valve

C I ASME III-3

Containment standpipe and suppression system components fire hose connections

Includes all FPS components Inside Rector Reactor Containment with the exception of those used for containment isolation, cable tray suppression, and containment spray

F NS ANSI B31.3 Seismic Analysis Consistent with ASME Section III Class 3 Systems

Various Auxiliary Building (Non-Radiologically Controlled) Standpipe and Non-1E Equipment Penetration Room Preaction Sprinkler System components piping

F NS ANSI B31.1 Seismic Analysis Consistent with ASME Section III Class 3 Systems

Balance of system components are Class E, F & G

* * *


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UFSAR Table 9.5.1-1 (Sheet 3), AP1000 Fire Protection Program Compliance With BTP CMEB 9.5-1

Revise Table 9.5.1-1, as shown below:

BTP CMEB 9.5-1 Guideline Paragraph Comp(1) Remarks

* * *

Fire Suppression System Design Basis

* * *

19. A single active failure or a crack in a fire suppression system moderate energy line should not impair both the primary and backup fire suppression capabilities.

C.1.c(2) AC Criteria followed except for containment and outlying buildings. The fire suppression systems piping serving the standpipe and fire hose connections located inside the containment are are analyzed to remain functional following a safe shutdown earthquake. The containment isolation piping is qualified to seismic Category I criteria. These attributes reduce , which reduces the potential for a failure of the system. The buildings outside the auxiliary building do not contain safety-related equipment, or present an exposure hazard to structures containing safety-related equipment. Manual fire suppression capability using hose lines connected to the outside hydrants of the yard main can be provided in the event of a failure of the interior fire suppression systems.

* * *

Figure 9.5.1-1 (Sheet 3 of 3) Simplified Fire Protection System

Piping and Instrumentation Diagram (REF FPS 004)


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