NL-15-0812, Operating License Revisions Associated with License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b

Operating License Revisions Associated with License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b

ML15125A446
Person / Time
Site:	Vogtle
Issue date:	05/05/2015
From:	Pierce C Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-15-0812
Download: ML15125A446 (15)

Text

Charles A. Pierce Southern Nuclear Regulatory Affairs Director Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 A

Birmingham, AL 35242 Tel 205.992.7872 Fax 205.992.7601 SOUTHERN COMPANY MAY 0 5 2015 Docket Nos.: 50-424 NL-15-0812 50-425 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant, Units 1 & 2 Operating License Revisions Associated with License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines By letter dated September 13, 2012, Southern Nuclear Operating Company (SNC) submitted a license amendment request for the Vogtle Electric Generating Plant (VEGP) Technical Specifications (TS) to permit the use of Risk Managed Technical Specifications per Nuclear Energy Institute (NEI) Topical Report 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines.

By letters dated May 16, 2013, June 9, 2014 (corrected by letter dated June 25, 2014), and October 14, 2014, the NRC requested additional information related to this license amendment request. SNC responded to those requests by letters dated August 2, 2013, July 17, 2014, and November 11, 2014 (further clarified via letter dated December 12, 2014). On February 19, 2015, a conference call was held between SNC and the NRC staff to discuss implementation items provided in the RAI responses discussed above. SNC responded to this request via NL 0381 dated March 16, 2015.

While confirming the OL pages affected by the aforementioned submittal with the NRC staff, it was identified that the affected Operating License (OL) pages require resubmittal due to the inadvertent omission of the original submittal date in the revised OL text. Enclosure 1 contains the markups to the existing OL pages and Enclosure 2 contains the clean-typed OL pages.

U. S. Nuclear Regulatory Commission NL-15-0812 Page2 This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.

Respectfully submitted, C/{~

C. R. Pierce Regulatory Affairs Director CAP/EGA

References:

1. Southern Nuclear Operating Company letter, NL-12-1344, dated September 13, 2012, License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines'

2. NEI 06-09, Revision 0-A, November, 2006, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS)

Guidelines

3. NRC Letter dated May 16, 2013, Vogtle Electric Generating Plant, Units 1 and 2 (VEGP) Request for Additional Information, (TAG Nos. ME9555 and ME9556)

4. Southern Nuclear Operating Company letter, NL-13-1540, dated August 2, 2013, Vogtle Electric Generating Plant Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS)

Guidelines"

5. NRC Letter dated June 9, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Request for Additional Information (TAG Nos. ME9555 and ME9556)

6. NRC Letter dated June 25, 2014, Vogtle Electric Generating Plant, Units 1 and 2- Corrected- Request for Additional Information, (TAG Nos. ME9555 and ME 9556}

7. Southern Nuclear Operating Company letter, NL-14-1016, dated July 17, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines"

U.S. Nuclear Regulatory Commission NL-15-0812 Page 3

8. NRC Letter dated October 14, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Request for Additional Information (TAG Nos. ME9555 and ME9556)

9. NRC Letter dated April 24, 2013, Vogtle Electric Generating Plant, Units 1 and 2, Issuance of Amendments Regarding Adoption of TSTF-439, "Eliminate Second Completion Times Limiting Time from Discovery of Failure to Meet an LCO" (TAG Nos. ME9470 and ME9471)

10. Southern Nuclear Operating Company letter, NL-14-1703, dated November 11, 2014, Vogtle Electric Generating Plant, Units 1 and 2, Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines"

11. Southern Nuclear Operating Company Letter, NL-14-1974, dated December 12, 2014, Vogtle Electric Generating Plant, Units 1 & 2, Clarification of Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines"

12. Southern Nuclear Operating Company Letter, NL-15-0381, dated March 16, 2015, License Conditions for License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, "Risk Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines"

Enclosures:

1. Operating Licenses Marked Up Pages

2. Operating Licenses Clean Typed Pages cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President- Fleet Operations Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. G. W. Gunn, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2 Mr. G. E. Miller, NRR Project Manager

Vogtle Electric Generating Plant, Units 1 & 2 Operating License Revisions Associated with License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines Enclosure 1 Operating Licenses Marked Up Pages

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (11) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No.!1Hl are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required.

The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 5.

An exemption was previously granted pursuant to 10 CFR 70.24. The exemption was granted with NRC materials license No. SNM-1967, issued August 21 , 1986, and relieved GPC from the requirement of having a criticality alarm system. GPC and Southern Nuclear are hereby exempted from the criticality alarm system provision of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The exemptions in items b and c above are granted pursuant to 10 CFR 50.12. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission.

E. Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 162.

F. GPC shall comply with the antitrust conditions delineated in Appendix C to this license.

Renewed Operating License No. NPF-68 Amendment No.l 173 l

Amendment Additional Condition Implementation Number Date 102 The licensee will implement all applicable crane, load path and Before and height, rigging and load testing guidelines of NUREG-0612 and during ANSI Standard 830.2, as described in the licensee's letters dated reracking September 4, 1997, May 19 and June 12,1998, and evaluated in operations, as the staffs Safety Evaluation dated June 29, 1998 appropriate.

154 Upon implementation of the Amendment adopting TSTF-448, Revision 3, As stated in the the determination of CRE unfiltered air inleakage as required by SR Additional 3.7.10.5, in accordance with TS 5.5.20.c.(i) , and Condition the measurement of CFE pressure as required by Specification 5.5.20.d, shall be considered met. Following implementation:

(a) The first performance of SR 3.7.10.5, in accordance with Specification 5.5.20.c.(i) , shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01 , or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.

(b) The first performance of the periodic assessment of CRE habitability, specification 5.5.20.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01 , or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.

The first performance of the periodic measurement of CRE pressure, specification 5.5.20.d, shall be within 18 months, plus the 138 days allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.

173 Southern Nuclear Operating Company (SNC) is approved to implement As stated in the 10 CFR 50.69 using the processes for categorization of Risk-Informed Additional Safety Class (RISC)-1 , RISC-2, RISC-3, and RISC-4 structures, systems, Condition and components (SSCs) specified in the licensee amendment request submittals dated August 31 , 2012, May 17, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11 , 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval, under 10 CFR 50.90, is required for a change to a categorization process that is outside the bounds specified above (e.g .,

change from a seismic margins approach to a seismic probabilistic risk assessment approach).

\ *unit 1 Operating Vogtle Umt 1 Y~icense Insert D-2 Amendment No 1173 I

successfully demonstrated prior to the time and condition specified below for each:

a) DELETED b) DELETED c) SR 3.8.1 .20 shall be successfully demonstrated at the first regularly scheduled performance after implementation of this license amendment.

(3) Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a Joss of coolant accident.

(4) Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (5) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No . ~ are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required . The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 8.

Renewed Operating License NPF-81 Amendment No.l155l

Amendment Additional Condition Implementation Number Date 155 Southern Nuclear Operating Company (SNC) is approved to implement As stated in the 10 CFR 50.69 using the processes for categorization of Risk-Informed Additional Safety Class (RISC)-1 , RISC-2 , RISC-3 , and RISC-4 structures, systems, Condition and components (SSCs) specified in the licensee amendment request submittals dated August 31 , 2012, May 17, 2013, July 2, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11 , 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval , under 10 CFR 50.90, is required for a change to a categorization process that is outside the bounds specified above (e.g.,

change from a seismic margins approach to a seismic probabilistic risk assessment approach .)

AI

('

'Unit 2 Operating License Insert I Vogtle Unit 2 D-2 b Amendment No. 55 1

Unit 1 Operating License Insert Southern Nuclear Operating Company (SNC) is approved to implement As stated in the the Risk Informed Completion Time Program as specified in the Additional licensee amendment request submittals dated September 13,2012, Condition August 2, 2013, July 17, 2014, November 11, 2014, and December 12, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation Items, of SNC letter NL-15-0381 dated March 16, 2015 prior to the implementation of the Risk Informed Completion Time Program.

Unit 2 Operating License Insert Southern Nuclear Operating Company (SNC) is approved to implement As stated in the the Risk Informed Completion Time Program as specified in the Additional licensee amendment request submittals dated September 13, 2012, Condition August 2, 2013, July 17, 2014, November 11,2014, and December 12, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation Items, of SNC letter NL-15-0381 dated March 16,2015 prior to the implementation of the Risk Informed Completion Time Program.

Vogtle Electric Generating Plant, Units 1 & 2 Operating License Revisions Associated with License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0-A, Risk Informed Technical Specifications Initiative 4b, Risk Managed Technical Specifications (RMTS) Guidelines Enclosure 2 Operating Licenses Clean-Typed Pages

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (11) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. , are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required.

The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 5.

An exemption was previously granted pursuant to 10 CFR 70.24. The exemption was granted with NRC materials license No. SNM-1967, issued August 21, 1986, and relieved GPC from the requirement of having a criticality alarm system. GPC and Southern Nuclear are hereby exempted from the criticality alarm system provision of 10 CFR 70.24 so far as this section applies to the storage of fuel assemblies held under this license.

These exemptions are authorized by law, will not present an undue risk to the public health and safety, and are consistent with the common defense and security. The exemptions in items b and c above are granted pursuant to 10 CFR 50.12. With these exemptions, the facility will operate, to the extent authorized herein, in conformity with the application, as amended, the provisions of the Act, and the rules and regulations of the Commission .

E. Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved physical security, training and qualification, and safeguards contingency plans including amendments made pursuant to provisions of the Miscellaneous Amendments and Search Requirements revisions to 10 CFR 73.55 (51 FR 27817 and 27822) and to the authority of 10 CFR 50.90 and 10 CFR 50.54(p).

The plan, which contains Safeguards Information protected under 10 CFR 73.21, is entitled: "Southern Nuclear Operating Company Security Plan, Training and Qualification Plan, and Safeguards Contingency Plan," with revisions submitted through May 15, 2006.

Southern Nuclear shall fully implement and maintain in effect all provisions of the Commission-approved cyber security plan (CSP), including changes made pursuant to the authority of 10 CFR 50.90 and 10 CFR 50.54(p). The Southern Nuclear CSP was approved by License Amendment No. 162.

F. GPC shall comply with the antitrust conditions delineated in Appendix C to this license.

Renewed Operating License No. NPF-68 Amendment No.

Amendment Additional Condition Implementation Number Date Southern Nuclear Operating Company (SNC) is approved to implement As stated in the Risk Informed Completion Time Program as specified in the the Additional licensee amendment request submittals dated September 13, 2012, Condition August 2, 2013, July 17, 2014, November 11, 2014, and December 12, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation Items, of SNC letter NL-15-0381 dated March 16, 2015 prior to the implementation of the Risk Informed Completion Time Program.

Vogtle Unit 1 D-3 Amendment No.

successfully demonstrated prior to the time and condition specified below for each :

a) DELETED b) DELETED c) SR 3.8.1 .20 shall be successfully demonstrated at the first regularly scheduled performance after implementation of this license amendment.

(3) Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training of response personnel (b) Operations to mitigate fuel damage considering the following :

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

7. Spent fuel pool mitigation measures (c) Actions to minimize release to include consideration of:

1. Water spray scrubbing

2. Dose to onsite responders (5) Additional Conditions The Additional Conditions contained in Appendix D, as revised through Amendment No. , are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Additional Conditions.

D. The facility requires exemptions from certain requirements of 10 CFR Part 50 and 10 CFR Part 70. These include (a) an exemption from the requirements of 10 CFR 70.24 for two criticality monitors around the fuel storage area, and (b) an exemption from the requirements of Paragraph III.D.2(b)(ii) of Appendix J of 10 CFR 50, the testing of containment air locks at times when containment integrity is not required . The special circumstances regarding exemption b are identified in Section 6.2.6 of SSER 8.

Renewed Operating License NPF-81 Amendment No.

Amendment Additional Condition Implementation Number Date 155 Southern Nuclear Operating Company (SNC) is approved to implement As stated in the 10 CFR 50.69 using the processes for categorization of Risk-Informed Additional Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, Condition and components (SSCs) specified in the licensee amendment request submittals dated August 31,2012, May 17,2013, July 2, 2013, September 13, 2013, May 2, 2014, July 22, 2014 and August 11, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.

NRC prior approval, under 10 CFR 50.90, is required for a change to a categorization process that is outside the bounds specified above (e.g.,

change from a seismic margins approach to a seismic probabilistic risk assessment approach.)

Southern Nuclear Operating Company (SNC) is approved to implement As stated in the Risk Informed Completion Time Program as specified in the the Additional licensee amendment request submittals dated September 13, 2012, Condition August 2, 2013, July 17, 2014, November 11, 2014, and December 12, 2014.

The licensee shall implement the items listed in enclosure 1, Implementation Items, of SNC letter NL-15-0381 dated March 16, 2015 prior to the implementation of the Risk Informed Completion Time Program.

Vogtle Unit 2 D-2 Amendment No.