ML22208A133

NRR E-mail Capture - RAI - Hatch, Units 1 and 2, TSTF-208 LAR

ML22208A133
Person / Time
Site:	Hatch
Issue date:	07/26/2022
From:	Dawnmathews Kalathiveettil NRC/NRR/DORL/LPL2-1
To:	Enfinger T, Quarles A Southern Nuclear Operating Co
References
L-2022-LLA-0045
Download: ML22208A133 (4)

Text

From: Kalathiveettil, Dawnmathews Sent: Tuesday, July 26, 2022 3:41 PM To: Enfinger, Timothy Lee; Quarles, Adam Graham Cc: Chamberlain, Amy Christine; Markley, Michael; Lamb, John; Devlin-Gill, Stephanie

Subject:

RAI - Hatch, Units 1 and 2, TSTF-208 LAR (EPID: L-2022-LLA-0045)

Importance: High Tim/Adam, By letter dated March 25, 2022 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML22087A169), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2. The LAR and supplemental information, dated May 17, 2022 (ADAMS Accession No. ML22137A001), proposed a change from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for the allowable time limit to reach Mode 2 in Limiting Condition for Operation (LCO) 3.0.3. In addition, SNC requested an administrative change for deletion of a duplicate TS 3.4.10, on TS Page 3.4-25 of each units TS.

After reviewing the LAR, the NRC staff requests response to the request for additional information (RAI) given below.

On July 6, 2022, the NRC staff provided a draft RAI question to SNC to make sure that the RAI is understandable, the regulatory basis is clear, to ensure there is no proprietary information, and to determine if the information was previously docketed. During the RAI clarification call between the NRC staff and SNC held on July 20, 2022, SNC stated that it can provide its response to the RAI by mid-October. The staff anticipates SNCs response by October 15, 2022.

If you have any questions, you can contact me at 301-415-5905.

Best Regards, Dawnmathews T. Kalathiveettil Project Manager Plant Licensing Branch (LPL 2-1)

DORL - O8 C02 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Office Phone: 301-415-5905 Email: Dawnmathews.Kalathiveettil@nrc.gov REQUEST FOR ADDITIONAL INFORMATION (RAI)

By letter dated March 25, 2022 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML22087A169), Southern Nuclear Operating Company (SNC, the

licensee) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Plant (HNP), Units 1 and 2. The proposed amendments would eliminate the Limiting Condition for Operation (LCO) 3.0.3 requirement to be in Mode 2 within an allowable time limit based on the approved Technical Specifications (TS) Task Force (TSTF) Traveler TSTF-208, Revision 0, Extension of Time to Reach Mode 2 in LCO 3.0.3. The amendment request maintained the LCO 3.0.3 requirement to be in Mode 3 within 13 hours1.50463e-4 days <br />0.00361 hours <br />2.149471e-5 weeks <br />4.9465e-6 months <br />. In addition, SNC requested an administrative change for deletion of a duplicate TS 3.4.10, on TS Page 3.4-25 of each units TS.

By letter dated April 29, 2022 (ADAMS Accession No. ML22111A086), the NRC informed SNC of the need for supplemental information for acceptance of the requested licensing action. By letter dated May 17, 2022 (ADAMS Accession No. ML22137A001), SNC responded with supplemental information. The supplemental information proposed a change from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> for the allowable time limit to reach Mode 2 in LCO 3.0.3.

NRC staff has reviewed the application and the supplemental information. To complete its review, the NRC staff requests additional information as shown below.

RAI-01

The regulations of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.36, Technical specifications, establish the requirements related to the content of the TS. Section 50.36(c)(2) states, in part:

Limiting conditions for operation. (i) Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility.

When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

The requirements of LCO 3.0.3 establish the actions that must be implemented when an LCO is not met and either an associated Required Action and Completion Time is not met and no other Condition applies, or the condition of the unit is not specifically addressed by the associated actions.

NUREG-1433, Revision 5, BWR/4 standard technical specifications, requires actions to be initiated within one hour to place the unit in Mode 2 within 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> when in LCO 3.0.3.

Therefore, the NUREG effectively allows six hours from the start of the shutdown to reach Mode

2. The time limits specified to enter lower MODES of operation permit the shutdown to proceed in a controlled and orderly manner that is well within the specified maximum cooldown rate and within the capabilities of the unit, assuming that only the minimum required equipment is OPERABLE.

TSTF-208, Revision 0 (ADAMS Accession No. ML040570174), determined that older BWRs can take longer than the currently available six hours to reach conditions where the plant can be placed in Mode 2. In addition, a Reviewer's Note is added to LCO 3.0.3 stating that plant specific data must be provided to support the extension of the time to reach Mode 2.

The second and third paragraphs of Section 3.0 of the May 17, 2022, supplement states:

In accordance with TSTF-208, Revision 0, it has been determined that older BWRs can take longer than the currently available six hours to reach conditions where the plant can be

placed in Mode 2. HNP is a BWR/4 with 137 control rods.

At HNP, review of plant data indicates approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> are typically required for an orderly shutdown. An orderly shutdown involves lowering reactor power to ~20% using control rods and reactor recirculation pumps, and then inserting a manual scram from ~20%

power by placing the reactor mode switch in the Shutdown position. While extending the allowed time to reach Mode 2 upon entry into LCO 3.0.3 from 7 hours8.101852e-5 days <br />0.00194 hours <br />1.157407e-5 weeks <br />2.6635e-6 months <br /> to 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> will still result in an aggressive shutdown, it provides additional time for a more orderly shutdown and reduces stress on the operators.

TSTF-208 contains a reviewers note that the licensee must provide the plant specific data to support the extension. This information has not been provided in your initial submittal or supplement. Staff requests the licensee provide the plant specific data and analysis that reached the 10-hour LCO time requested in the LAR submittal. The information should include a summary analysis of the applicable operating procedure(s) and action steps for completing LCO 3.0.3 actions required to exit Mode 1 as well as historical operational data or simulator training data which demonstrate reliable completion in the requested 10-hour LCO time. The analysis should explain how the extended completion time will ensure maintaining the existing transient safety analysis for LCO 3.0.3 Manual SCRAM from 20% power.

Hearing Identifier: NRR_DRMA Email Number: 1728 Mail Envelope Properties (BY5PR09MB56663E4CE97776415105B77297949)

Subject:

RAI - Hatch, Units 1 and 2, TSTF-208 LAR (EPID: L-2022-LLA-0045)

Sent Date: 7/26/2022 3:41:17 PM Received Date: 7/26/2022 3:41:00 PM From: Kalathiveettil, Dawnmathews Created By: Dawnmathews.Kalathiveettil@nrc.gov Recipients:

"Chamberlain, Amy Christine" <ACCHAMBE@southernco.com>

Tracking Status: None "Markley, Michael" <Michael.Markley@nrc.gov>

Tracking Status: None "Lamb, John" <John.Lamb@nrc.gov>

Tracking Status: None "Devlin-Gill, Stephanie" <Stephanie.Devlin-Gill@nrc.gov>

Tracking Status: None "Enfinger, Timothy Lee" <TLENFING@SOUTHERNCO.COM>

Tracking Status: None "Quarles, Adam Graham" <AGQUARLE@southernco.com>

Tracking Status: None Post Office: BY5PR09MB5666.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6624 7/26/2022 3:41:00 PM Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: