ML23011A274

Regulatory Audit in Support of Review of the License Amendment Request to Revise Technical Specification 1.1, Use and Application Definitions, and to Add Technical Specification 5.5.23, Online Monitoring Program

ML23011A274
Person / Time
Site:	Vogtle
Issue date:	01/20/2023
From:	John Lamb Plant Licensing Branch II
To:	Gayheart C Southern Nuclear Operating Co
References
EPID L-2022-LLA-0190
Download: ML23011A274 (1)

Text

January 20, 2023 Ms. Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - REGULAORY AUDIT IN SUPPORT OF REVIEW OF THE LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 1.1, USE AND APPLICATION DEFINITIONS, AND TO ADD TECHNICAL SPECIFICATION 5.5.23, ONLINE MONITORING PROGRAM (EPID L-2022-LLA-0190)

Dear Ms. Gayheart:

By letter dated December 21, 2022 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML22355A588), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Vogtle Electric Generating Plant (Vogtle), Units 1 and 2. The proposed LAR would revise Technical Specification (TS) 1.1, Use and Application Definitions, and add TS 5.5.23, Online Monitoring Program.

SNC proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed LAR is based on the U.S. Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Corporation (AMS) topical report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (ML21235A493).

The NRC staff has identified the need for a regulatory audit to examine the SNCs non-docketed information with the intent to gain understanding, to verify information, or to identify information that will require docketing to support the basis of the licensing or regulatory decision.

The NRC staff will conduct the audit virtually via Teams using a licensee-established electronic portal available to NRC staff from approximately February 1, through May 31, 2023, with formal audit meetings to be scheduled during this period as needed. The NRC staff reserves the right to extend the audit, if necessary. The detailed audit plan is enclosed with this letter.

C. Gayheart If you have any questions, please contact me at (301) 415-3100 or by e-mail at John.Lamb@nrc.gov.

Sincerely,

/RA/

John G. Lamb, Senior Project Manager Plant Licensing Branch II-2 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosure:

Audit Plan cc: Listserv

REGULATORY AUDIT PLAN BY THE OFFICE OF NUCLEAR REACTOR REGULATION TO SUPPORT THE REVIEW OF THE LICENSE AMENDMENT REQUEST TO REVISE TS 1.1 and ADD TS 5.5.23 SOUTHERN NUCLEAR OPERATING COMPANY VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425

1.0 BACKGROUND

By letter dated December 21, 2022 (Agencywide Documents and Access Management System (ADAMS) Accession No. ML22355A588), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Vogtle Electric Generating Plant (Vogtle), Units 1 and 2. The proposed LAR would revise Technical Specification (TS) 1.1, Use and Application Definitions, and add TS 5.5.23, Online Monitoring Program.

The licensee, SNC proposes to use online monitoring (OLM) methodology as the technical basis to switch from time-based surveillance frequency for channel calibrations to a condition-based calibration frequency based on OLM results. The proposed LAR is based on the U.S.

Nuclear Regulatory Commission (NRC)-approved Analysis and Measurement Services Corporation (AMS) topical report (TR) AMS-TR-0720R2-A, Online Monitoring Technology to Extend Calibration Intervals of Nuclear Plant Pressure Transmitters (ML21235A493).

The NRC staff from the Office of Nuclear Reactor Regulation (NRR) has initiated its review of the LAR in accordance with NRR Office Instruction LIC-101, License Amendment Review Procedures (ML19248C539).

2.0 REGULATORY AUDIT BASIS A regulatory audit is a planned license- or regulation-related activity that includes the examination and evaluation of primarily non-docketed information associated with the LAR. An audit is conducted to gain understanding, to verify information, and to identify information that will require docketing to support the basis of a licensing or regulatory decision. An audit will assist the NRC staff in efficiently conducting its review and gaining insights to the licensees processes and procedures. Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. This audit will be conducted in accordance with NRR Office Instruction LIC-111, Regulatory Audits, Revision 1, dated October 2019 (ML19226A274), with exceptions noted within this audit plan.

The NRC staff will perform the audit to support its evaluation of whether SNCs LAR can be approved per Title 10 of the Code of Federal Regulations (10 CFR), Section 50.90, Application for amendment of license, construction permit, or early site permit. The NRC staffs review will be informed by NUREG-0800, Standard Review Plan. The audit will assist the NRC staff with understanding the licensees proposed OLM LAR.

Enclosure

3.0 REGULATORY AUDIT SCOPE AND METHODOLOGY NRCs objectives of the audit are the following:

Gain a better understanding of the detailed calculations, analyses, and bases underlying the LAR and confirm the NRC staffs understanding of the LAR.

Gain a better understanding of plant design features and their implications for the LAR.

Identify any information needed to enable the NRC staffs evaluation of the technical basis used for this application.

Identify any information needed to enable the NRC staffs evaluation of whether the proposed changes challenge design-basis functions or adversely affect the capability or capacity of plant equipment to perform design-basis functions.

Identify questions and requests that may become formal requests for additional information (RAIs) per NRR Office Instruction LIC-115, Processing Requests for Additional Information (ML21141A238).

The NRC staff will audit the technical information and methods that the licensee used to determine the impact on the plant, and the licensees evaluation of defense-in-depth.

4.0 INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT The NRC staff will request information and an audit meeting(s) throughout the audit period. The NRC staff will use an audit items list to identify the information (e.g., methodology, process information, and calculations) to be audited. The NRC staff will provide the final audit items list as an enclosure to the audit summary report, which will be publicly available. The attachment to this audit plan includes the initial audit items list. Throughout the audit period, the NRC staff will provide SNC with audit questions and audit-related requests so that the licensee can better prepare for audit discussions with NRC staff. Any information accessed through the licensees portal will not be held or retained in any way by NRC staff. The NRC staff requests the licensee to have the requested audit information listed in the audit items list to be readily available and accessible for the NRC staffs review via a Web-based portal.

5.0 TEAM ASSIGNMENTS The audit team will consist of the following NRC staff from NRR.

John G. Lamb, Division of Operating Reactor Licensing (DORL)/Plant Licensing Branch 2-1 (LPL2-1)

Richard Stattel, Division of Engineering and External Hazards (DEX)/Instrumentation and Controls Branch (EICB)

Joe Ashcraft, DEX/EICB Tarico Sweat, Division of Safety Systems (DSS)/Technical Specifications Branch (STSB) 6.0 LOGISTICS To support the review schedule communicated to SNC when the NRC staff accepted the LAR for technical review, audit activities will be performed remotely and virtually using Microsoft Teams, teleconference, and a Web-based portal or other virtual meeting space created by the licensee. The NRC staff information requests and communications with licensee staff will be coordinated through the NRCs licensing project manager.

A desktop audit will take place between February 1, through May 31, 2023. The NRCs licensing project manager will inform the licensee of the entrance and exit meeting dates when they are established. The NRC intends to establish an approximately three-day virtual audit meeting via Microsoft Teams on mutually agreeable dates and times, to discuss information needs and questions arising from the NRCs review of the audited items. The NRC staff may change and/or add audit dates and times, or extend the audit, if necessary. Audit meeting agenda and questions, if needed, will be sent in advance of the audit meeting.

The NRC staff requests the licensee to have the information referenced in Section 4.0 of this audit plan available and accessible for the NRC staffs review via an internet-based portal within five days of this audit plan. The NRC staff requests that any supplemental information requested be available and accessible for the NRC staffs review within 5 days of the date of the NRCs notification to the licensee of the new requests. The NRCs licensing project manager will inform the licensee via routine communications when the NRC staff no longer needs access to the portal. The NRC staff requests the licensee to notify the NRCs licensing project manager when an audit item is added to its portal by sending an e-mail to the NRC licensing project manager.

7.0 SPECIAL REQUESTS The NRC requests access to requested documents and information through a Web-based portal that allows the NRC staff and contractors to access documents over the Internet. The following conditions associated with the online portal must be maintained while the NRC staff and contractors have access to the online portal:

The online portal will be password-protected. A separate password will be assigned to each member of the NRC staff and NRC contractors participating in the audit.

The online portal will prevent the NRC participants from printing, saving, downloading, or collecting any information directly from the online portal.

Conditions of use of the online portal will be displayed on the login screen and will require acknowledgment by each user.

Username and password and/or other Web-based portal access information should be provided directly to members of the NRC staff and contractors as needed. The NRC licensing project manager will provide the licensee with names and contact information of the NRC staff and contractors participating in the audit. All other communications should be coordinated through the NRC project manager.

8.0 DELIVERABLES The NRC staff will develop any RAIs, as needed, via NRR Office Instruction LIC-115 and issue such RAIs separately from audit-related correspondence. The NRC staff will issue an audit summary report prior to completing its review of the LAR.

Initial Audit Items List Item # Audit Item 1 AMS Report SNO2201R2, OLM Amenable Transmitters Report for Vogtle Units 1 and 2, December 2022.

2 AMS Report SNO2202R1, OLM Analysis Methods and Limits Report for Vogtle Units 1 and 2, December 2022.

3 AMS Report SNO2203R1, OLM Drift Monitoring Implementation Report for Vogtle Units 1 and 2, December 2022.

4 AMS Procedure OLM2201, Procedure for Online Monitoring Data Retrieval, AMS Corporation, December 2022.

5 AMS Procedure OLM2202, Procedure for Performing Online Monitoring Data Qualification and Analysis, AMS Corporation, December 2022.

6 AMS Report SNO2204R1, "Noise Analysis Technique Implementation for Vogtle Units 1 and 2, AMS Corporation, December 2022.

7 AMS Procedure NPS1501, Procedure for Noise Data Collection from Plant Sensors, AMS Corporation, March 2015.

8 AMS Procedure NAR2201, Procedure for Performing Dynamic Failure Mode Assessment Using Noise Analysis, AMS Corporation, December 2022.

ML23011A274 OFFICE NRR/DORL/LPLII-2/PM NRR/DORL/LPLII-2/LA NRR/DEX/EICB/BC NRR/DSS/STSB/BC NAME JLamb KGoldstein MWaters VCusumano DATE 1/11/2023 1/13/2023 1/17/2023 1 /14/2023 OFFICE NRR/DORL/LPLII-2/BC NRR/DORL/LPLII-2/PM NAME MMarkley JLamb DATE 1/20/2023 1/20/2023