ML22077A543

Summary of Meeting with Southern Nuclear Operating Co

ML22077A543
Person / Time
Site:	Vogtle
Issue date:	04/04/2022
From:	Cayetano Santos NRC/NRR/VPOB
To:
Santos C, 301-415-7270
References
Download: ML22077A543 (4)

Text

April 4, 2022 LICENSEE: SOUTHERN NUCLEAR OPERATING COMPANY FACILITY: VOGTLE ELECTRIC GENERATING PLANT, UNIT 4

SUMMARY

OF MARCH 17, 2022, MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY On March 17, 2022, the U.S. Nuclear Regulatory Commission (NRC) held a virtual public meeting with representatives of Southern Nuclear Operating Company (SNC). The purpose of the meeting was to discuss SNCs authorized request for an alternative to the inservice testing (IST) requirements of the American Society of Mechanical Engineers (ASME) Operation and Maintenance of Nuclear Power Plants, Division 1, OM Code: Section IST (OM Code) associated with establishing the applicable OM Code Edition for the initial IST Program interval (IST-ALT-01). The meeting notice and agenda, dated March 9, 2022, are available in the Agencywide Documents Access and Management System (ADAMS) at Accession No. ML22068A224. A list of attendees is enclosed.

By letters dated October 31, 2019, and February 6, 2020 (ADAMS Accession Nos.

ML19304C432 and ML20037A329, respectively), SNC requested authorization of an alternative pursuant to Title 10 of the Code of Federal Regulations (10 CFR) 50.55a(z)(1) to the requirements for establishing the applicable OM Code Edition for the initial 120-month IST Program interval for Vogtle Electric Generating Plant (VEGP) Unit 4. On March 2, 2020, the NRC authorized the proposed alternative for VEGP Unit 4 for initial fuel load dates prior to November 23, 2022 (emphasis added) (ADAMS Accession No. ML20045D487). This approval allowed SNC to develop IST Programs for VEGP Units 3 and 4 using the same Edition of the ASME OM Code. The VEGP Unit 3 IST Program is based on the 2012 Edition of the ASME OM Code.

Currently, the scheduled initial fuel load date for VEGP Unit 4 is prior to November 23, 2022.

SNC plans to submit a request to remove the initial fuel load date condition (i.e., for initial fuel load dates prior to November 23, 2022) to account for schedule uncertainty in the VEGP Unit 4 construction. SNCs objective is to develop and maintain a consistent IST Program for VEGP Units 3 and 4 that is based on the same Edition of the ASME OM Code. This consistency reduces the effort associated with maintaining separate requirements and minimizes potential errors associated with implementing separate requirements between two nearly identical units.

SNC also noted that NUREG-1482, Revision 3, Guidelines for Inservice Testing at Nuclear Power Plants: Inservice Testing of Pumps and Valves and Inservice Examination and Testing of Dynamic Restraints (Snubbers) at Nuclear Power Plants, states [t]he NRC staff believes that conducting IST programs for multiple unit sites using the same OM Code edition could provide an improvement in program effectiveness.

SNC staff described its justification for removing the initial fuel load date condition. If this condition is not removed, and VEGP Unit 4 initial fuel load occurs after November 23, 2022, the

Unit 4 IST Program would need to be updated to the 2017 Edition of the ASME OM Code. The most significant difference between the 2012 and 2017 Editions is that the 2017 Edition includes Mandatory Appendix IV, for the testing of air-operated valves (AOVs). Testing of AOVs was addressed for VEGP Units 3 and 4 in the combined license application and is documented in Updated Final Safety Analysis Report (UFSAR) Section 3.9.6.4.5, Air-Operated Valves Additional Testing. SNC staff added that the NRC is currently inspecting the implementation of the AOV testing program. SNC staff concluded that updating the VEGP Unit 4 IST Program to the 2017 Edition would involve considerable burden without a corresponding increase in safety.

SNC also noted a burden on NRC resources to review updated programs and procedures if a separate IST Program was developed for VEGP Unit 4.

Below is a summary of the NRC staff comments and the resulting discussions:

The NRC staff noted that the submittal should adequately discuss how the AOV testing program addresses the difference between the 2012 and 2017 Editions of ASME OM Code.

The NRC staff stated that authorization of an open-ended alternative request is not possible so there must be a foreseeable end date to the request. This could be done by linking the initial IST Program interval of Unit 4 to that of Unit 3. SNC will consider this comment.

The NRC staff commented that the request should focus on the initial IST Program interval for Unit 4 because successive IST Program intervals would implement the latest edition of the ASME OM Code incorporated by reference in 10 CFR 50.55a within the specified timeframe. SNC can maintain consistent programs between the two units by updating the Unit 4 IST Program based on the schedule required for Unit 3. Effectively, this would result in updating the Unit 4 Program earlier than required.

In response to a question, SNC staff stated that the request to remove the initial fuel load date condition will be submitted in approximately 10 days with a request that NRC complete its review two months prior to the scheduled initial fuel load date for Unit 4.

Members of the public were not in attendance so there were no comments or questions from the public. The staff did not receive any Public Meeting Feedback forms.

Please direct any inquiries to me at 301-415-7270 or Cayetano.Santos@nrc.gov .

Sincerely, Signed by Santos, Cayetano on 04/04/22 Cayetano Santos Jr., Senior Project Manager Vogtle Project Office Office of Nuclear Reactor Regulation Docket No.52-026

Enclosure:

List of Attendees cc: Listserv

ML22077A543 *via e-mail NRR-106 OFFICE NRR/VPO/PM NRR/VPO/LA NRR/DEX/EMIB/BC NAME CSantos RButler ITseng DATE 3/17/2022 3/21/2022 4/4/2022 OFFICE NRR/VPO/BC NRR/VPO/PM NAME VHall CSantos DATE 4/4/2022 4/4/22 LIST OF ATTENDEES MARCH 17, 2022, MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ALTERNATIVE REQUIREMENTS FOR INSERVICE TEST INTERVAL CODE EDITION Name Organization Cayetano (Tanny) Santos Victor Hall William (Billy) Gleaves James Gaslevic Michael Webb NRC/Office of Nuclear Reactor Regulation Ian Tseng Christopher Welch Phil OBryan Brian Wittick Garry Armstrong NRC/Office of Nuclear Material Safety and Nicholas Hansing Safeguards Denise Hannigan NRC/Office of the Inspector General Amy Chamberlain Eddie Grant Chris Pendleton Southern Nuclear Operating Company Jamie Coleman Kyle Caver Ken Baity None Members of the Public Enclosure