ML20303A042
| ML20303A042 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 11/05/2020 |
| From: | Alina Schiller NRC/NRR/VPOB |
| To: | Omar Lopez-Santiago NRC/NRR/VPOB |
| Alina Schiller Ex 8777 | |
| References | |
| Download: ML20303A042 (10) | |
Text
November 5, 2020 MEMORANDUM TO: Omar Lpez-Santiago, Chief Vogtle Project Office Office of Nuclear Reactor Regulation FROM: Alina Schiller, Project Manager /RA/
Vogtle Project Office Office of Nuclear Reactor Regulation
SUBJECT:
SUMMARY
OF A PUBLIC MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ON OCTOBER 22, 2020 The U.S. Nuclear Regulatory Commission (NRC) staff held a Category 1 public meeting with Southern Nuclear Operating Company (SNC) on October 22, 2020. The purpose of the meeting was to discuss the following topics regarding Vogtle Electric Generating Plant (VEGP), Units 3 and 4: (1) submittal of turbine maintenance and inspection program in accordance with updated final safety analysis report (UFSAR) and (2) regulatory guidance on making emergency plan (EP) staffing changes to the number of system operators (SOs).
The meeting notice can be found in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML20293A154. The meeting notice is also posted on the NRC public website. Enclosures 1 and 2 are the meeting agenda and attendance list for the meeting, respectively. The documents referenced during the discussion can be found under ADAMS Accession Nos. given below:
- Submittal of Turbine Maintenance and ML20192A048 Inspection Program in Accordance with UFSAR
- Regulatory Guidance on Making EP ML20290A806 Staffing Changes to the Number of SOs CONTACT: Alina Schiller, NRR/VPO (301) 415-8177
O. Lpez-Santiago Summary of Meeting:
Submittal of Turbine Maintenance and Inspection Program in Accordance with UFSAR The NRC staff provided background on the license condition requiring SNC to submit a turbine maintenance and inspection program consistent with the activities identified in the UFSAR for VEGP Units 3 and 4. SNC submitted this program on July 10, 2020 (ADAMS Accession No. ML20192A048). The staff reviewed this submittal to confirm the program is consistent with the UFSAR.
The NRC staff provided the following items for SNC to consider:
- Inspection intervals for turbine rotor are not specified for the high pressure and low-pressure rotors (8-year and 10-year interval, respectively). SNC agreed to add the inspection intervals for the turbine rotor inspection to the program description.
- No inspection methods and acceptance criteria are specified in the program description.
NRC staff noted that procedures B-MTS-MMM-001 and B-MTS-MMM-003 specify the inspection methods and acceptance criteria. Therefore, stating that the turbine inspections (visual, magnetic particle, and ultrasonic examinations) would be performed using these procedures, would satisfy this requirement. SNC agreed to add these procedures to a list of references and add the appropriate description of those references, in the turbine rotor inspection portion of the program description.
At the conclusion of the discussion, there was an opportunity for the public to provide comments and ask questions. Glenn Carroll asked about the accuracy of the review status of the Inspections, Tests, Analyses and Acceptance Criteria closure notifications (ICNs) on the NRC website. The NRC staff explained the ICN status report is accurate and current as of the date published on the report which is updated periodically to reflect current performance.
Regulatory Guidance on Making EP Staffing Changes to the Number of SOs SNC provided presentation material (ADAMS Accession No. ML20290A806) on its application of Regulatory Guide (RG) 1.219, Guidance on Making Changes to Emergency Plans for Nuclear Power Reactors, regarding the determination whether proposed changes to SO staffing for VEGP Units 3 and 4 constituted a reduction in effectiveness to SNCs Standard EP Annex for VEGP Units 3 and 4. SNC described the proposed change which will reduce the number of non-licensed operators (SOs) listed in Table 2.2.A of SNCs Standard EP Annex for VEGP Units 3 and 4 from 8 to 6 for dual unit operation. SNC highlighted section 1.8b.(1) of RG 1.219 which states: If the licensees original commitment resulted from a conservative operating philosophy, the licensee may be able to show that the reduction in commitment would not reduce the effectiveness of its emergency plan. SNC also referred to section 4.2c of RG 1.219 and stated that based on the examples listed, the reduction in SO staffing does not rise to the level that could require NRC approval.
The NRC staff emphasized that the purpose of the public meeting was to provide SNC with feedback on whether SNC is looking at the right areas in evaluating whether there is a reduction in effectiveness. However, the staff emphasized that the decision on whether the changes to SNCs Standard EP Annex for VEGP Units 3 and 4 constitute a reduction in effectiveness rests with the licensee and would be subject to review as part of the NRCs regional inspection activities. Further, the staff stated that SNC needs to specifically evaluate if removing the 2
O. Lpez-Santiago number of SOs impacts the ability to perform an emergency function as described in SNCs Standard EP Annex for VEGP Units 3 and 4.
The NRC staff acknowledged that the RG 1.219 sections mentioned in SNCs presentation are applicable; however, there are other sections that are also relevant which need to be considered to support the evaluation and effectiveness decision. The staff provided several examples:
- statement in section 1.8c that clarifies in the case of that particular regulatory decision, conditions may have developed since the original commitments were made, which makes them necessary to maintain the effectiveness
- section 1.9b states it is inappropriate for the licensee to conclude that certain commitments made in the NRC approved EP are no longer required and then compare the EP as modified to SNCs conclusion (i.e., 10 CFR 50.54(q) decision)
- sections 4.a and 4.b SNC agreed to consider the NRC staffs comments.
SNC discussed the impact of this proposed change on a separate SNC license amendment request (LAR), which the staff is currently reviewing (ADAMS Accession No. ML20192A140).
This LAR requests changes to emergency response organization (ERO) staffing and augmentation times for the entire SNC fleet. SNC stated it evaluated the SO staffing change discussed above and any impacts it would or would not have upon the LAR, specifically whether the LAR may require repair and corrective action function from SOs. SNC noted the performance-based procedure analysis performed for this LAR regarding VEGP Units 3 and 4 never employs more than 6 SOs for dual unit operation. SNC concluded that there would be no impact to the fleet LAR, as the SOs being removed do not have any EP function, nor are they relied upon in the LAR.
The NRC staff stated that repair and corrective actions performed by the SOs should be built in SNCs emergency operating procedures. SNC agreed to consider that in their evaluation.
The NRC staff asked about the schedule for the licensee commitment per the Near-Term Task Force (NTTF) 9.3 recommendation for SNC to provide the NRC a multi-unit ERO staffing assessment license commitment prior to VEGP Unit 3 fuel load. SNC mentioned it would finalize and submit the staffing assessment after completing the specific change evaluation (discussed above), and it would communicate the date when the NTTF staffing analysis will be submitted to NRC in the near future.
At the conclusion of the discussion, there was an opportunity for the public to provide comments and ask questions. There were no comments or questions from the public.
Docket Nos.: 52-025 52-026
Enclosures:
As stated cc w/encls: See next page 2
ML20303A042 *via e-mail NRC-001 OFFICE PM: NRR/VPO LA: NRR/VPO PM: NRR/VPO BC: NRR/VPO NAME ASchiller* (c) RButler* CSantos* OLpez-Santiago*
DATE 11/3/20 11/3/20 11/4/20 11/5/20 OFFICE PM: NRR/VPO NAME ASchiller* (s)
DATE 11/5/20 AGENDA FOR PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION (NRC)
Thursday, October 22, 2020 Teleconference 9:00 a.m. - 12:00 p.m.
PURPOSE: To discuss issues associated with the safety review of licensing actions and/or Inspections, Tests, Analyses, and Acceptance Criteria (ITAAC) closures for Southern Nuclear Operating Companys (SNC) Vogtle Electric Generating Plant (VEGP) Units 3 and 4.
OPEN Time Topic Led By 9:00 a.m. Opening Remarks NRC 9:10 a.m. Discussion of Identified Topics NRC/SNC Opportunity for Public Comment NRC/Public Open Portion Concludes CLOSED (If needed) NRC/SNC 12:00 p.m. Adjourn Enclosure 1 2
PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION Thursday, October 22, 2020 Teleconference 9:00 a.m. - 12:00 p.m.
List of Attendees Name Organization Representing the Nuclear Regulatory Commission Omar Lpez-Santiago Mike King Cayetano Santos Alina Schiller NRR/VPO Christopher Welch Billy Gleaves Garry Armstrong Olivier Lareynie John Honcharik NRR/DNRL Michael Norris Raymond Hoffman Don Johnson Joseph Anderson Dan Barss Bruce Musico NSIR/DPR Robert Kahler Charles Murray Kenneth Mott Raymond Gibson Jessie Quichocho Jason Eargle Region II Representing Industry Amy Chamberlain Steven Leighty Stephanie Agee Jim Miller Nick Kellenberger Mark Humphrey Dan Williamson Ernest Bates Southern Nuclear Operating Company Jonathan Hartman Adam Quarles Ricky Collings Jamie Coleman Cheryl Gayheart Wesley Sparkman Eddie Grant Enclosure 2 2
Representing the Public Glenn Carroll Nuclear Watch South Note: All participated via teleconference.
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Vogtle Mailing List (Revised 9/16/2020) cc:
Resident Manager Resident Inspector Oglethorpe Power Corporation Vogtle Plant Units 3 & 4 Alvin W. Vogtle Nuclear Plant 7825 River Road, BIN 63031 7821 River Road Waynesboro, GA 30830 Waynesboro, GA 30830 Mr. Barty Simonton Office of the Attorney General Team Leader 40 Capitol Square, SW Environmental Radiation Program Atlanta, GA 30334 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company 4244 International Parkway, Suite 120 Document Control Coordinator Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 Brian H. Whitley Regulatory Affairs Director Anne F. Appleby Southern Nuclear Operating Company Olgethorpe Power Corporation 3535 Colonnade Parkway, BIN N-226-EC 2100 East Exchange Place Birmingham, AL 35243 Tucker, GA 30084 Mr. Michael J. Yox County Commissioner Site Regulatory Affairs Director Office of the County Commissioner Vogtle Units 3 & 4 Burke County Commission 7825 River Road Waynesboro, GA 30830 BIN 63031 Waynesboro, GA 30830 Mr. Wayne Guilfoyle Commissioner District 8 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334 Page 1 of 3
Vogtle Mailing List Email:
ppsena@southernco.com (Peter Paul Sena III) dlmckinn@southernco.com (D.L. McKinney mdmeier@southernco.com (Michael Meier) gchick@southernco.com (Glen Chick) ststimac@southernco.com (Stephen Stimac) patmarti@southernco.com (Patrick A. Martino) myox@southernco.com (Michael J. Yox) asparton@southernco.com (Anthony S. Parton) kroberts@southernco.com (Kelli A. Roberts) tgpetrak@southernco.com (Tom C. Petrak) ctdefnal@southernco.com (Chris T. Defnall) cemorrow@southernco.com (Calvin E. Morrow) x2rlbeil@southernco.com (Robert L. Beilke) sleighty@southernco.com (Steve Leighty) acchambe@southernco.com (Amy C. Chamberlain) jhaswell@southernco.com (Jeremiah C. Haswell) chandu.patel@nrc.gov (Chandu Patel) george.khouri@nrc.gov (George Khouri) nicholas.karlovich@nrc.gov (Nicholas D. Karlovich andrew.lerch@nrc.gov (Andrew Lerch) christopher.even@nrc.gov (Christopher Even) brian.kemker@nrc.gov (Brian J. Kemker) nicole.coovert@nrc.gov (Nicole C. Coovert) christopher.welch@nrc.gov (Christopher Welch) james.gaslevic@nrc.gov (James Gaslevic) victor.hall@nrc.gov (Victor Hall) garry.armstrong@nrc.gov (Garry Armstrong) michael.webb@nrc.gov (Michael Webb) thomas.fredette@nrc.gov (Thomas Fredette) steven.smith@nrc.gov (Steven Smith) cayetano.santos@nrc.gov (Cayetano Santos) marissa.bailey@nrc.gov (Marissa Bailey) steven.rose@nrc.gov (Steven Rose) bradley.davis@nrc.gov (Bradley Davis) jose.vasquez@nrc.gov (Jose Vasquez) jason.eargle@nrc.gov (Jason Eargle) kenya.carrington@nrc.gov (Kenya Carrington) michael.king2@nrc.gov (Michael King) evan.davidson@nrc.gov (Evan Davidson) theodore.fanelli@nrc.gov (Theodore Fanelli) bob.brinkman@opc.com (Robert B. Brinkman) eric.rasmussen@opc.com (Eric Rasmussen) jfuller@meagpower.org (J. E. Fuller) sjackson@meagpower.org (S.M. Jackson) tbundros@dutil.com (T. Bundros) orianil@westinghouse.com (Dr. L. Oriani)
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Vogtle Mailing List continued durhamdc@westinghouse.com (D. C. Durham) corletmm@westinghouse.com (M.M. Corletti) harperzs@westinghouse.com (Zach Harper) cowardjl@westinghouse.com (J. L. Coward) swkline@bechtel.com (S. W. Kline) lisa.matis@tetratech.com (Lisa Matis) bill.jacobs@gdassociates.com (Dr. Bill Jacobs) sroetger@psc.state.ga.us (S. Roetger) rtrokey@psc.state.ga.us (Robert L. Trokey) kevin.greene@troutmansanders.com (Kevin C. Greene) sblanton@balch.com (Stan Blanton) g2ndrmdc@southernco.com (SNC Document Control)
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