ML23072A274
| ML23072A274 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/01/2023 |
| From: | Cayetano Santos NRC/NRR/VPOB |
| To: | Brown K Southern Nuclear Operating Co |
| Shared Package | |
| ML23072A186 | List: |
| References | |
| Download: ML23072A274 (1) | |
Text
Enclosure 3 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NOS. 191 AND 188 TO THE COMBINED LICENSE NOS. NPF91 AND NPF92, RESPECTIVELY SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 DOCKET NOS.52-025 AND 52-026
1.0 INTRODUCTION
By letter dated December 19, 2022 (Agencywide Documents Access and Management System Accession No. ML22353A621), the Southern Nuclear Operating Company (the licensee or SNC) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (VEGP), Units 3 and 4, Combined License Numbers NPF91 and NPF92, respectively.
The License Amendment Request (LAR)22-005 proposed changes would revise the VEGP Units 3 and 4 Technical Specification (TS) Surveillance Requirement (SR) 3.0.3 and the associated TS Bases to allow application of SR 3.0.3 when a Surveillance has not been previously performed and to clarify the application of SR 3.0.3. These changes are consistent with the SR 3.0.3 changes that the NRC approved in Technical Specifications Task Force (TSTF) Traveler TSTF529, Revision 4, Clarify Use and Application Rules. In addition to the requested SR 3.0.3 changes, TSTF529, Revision 4, included changes to Standard Technical Specifications (STS) Section 1.3 and STS Limiting Condition for Operation (LCO) 3.0.4 which are not included in this LAR. TSTF529, Revision 4 was approved by the NRC by letter dated April 21, 2016 (ML16060A441). The staff notes that the additional changes in the approved traveler do not affect the staffs review of this LAR because the staffs approval of the SR 3.0.3 changes in the traveler were not linked to or predicated on the Section 1.3 or LCO 3.0.4 changes that were approved in the traveler.
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2.0 REGULATORY EVALUATION
The staff considered the following regulatory requirements in reviewing the LAR:
10 CFR Part 52, Appendix D, VIII.C.6 states that after issuance of a license, Changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90.
10 CFR 50.90 addresses the application for amendment of license, construction permit, or early site permit. The proposed LAR requires changes in the TS, and therefore an LAR is required to be submitted for NRC approval.
10 CFR 50.36, Technical specifications (TS) impose limits, operating conditions, and other requirements upon reactor facility operation for the public health and safety. The TS are derived from the analyses and evaluations in the safety analysis report. In general, TS must contain: (1) safety limits and limiting safety system settings; (2) limiting conditions for operation; (3) surveillance requirements; (4) design features; and (5) administrative controls.
The NRC staffs guidance for review of the TSs is in Chapter 16, Technical Specifications, of NUREG0800, Standard Review Plan [(SRP)], Revision 3, dated March 2010 (ML100351425).
As described therein, as part of the regulatory standardization effort, the NRC staff has prepared STS (NUREG1430 to NUREG1434 and NUREG2194) for each of the light-water reactor nuclear steam supply systems and associated balance-of-plant equipment systems.
Accordingly, the NRC staffs review includes consideration of whether the proposed technical specifications are consistent with the applicable reference TS (i.e., the current STS), as modified by NRC-approved TSTF Travelers such as TSTF529, Revision 4. Special attention is given to technical specification provisions that depart from the reference technical specifications and NRC-approved TSTF Travelers to determine whether proposed differences are justified by uniqueness in plant design or other considerations so that 10 CFR 50.36 is met.
3.0 TECHNICAL EVALUATION
In reviewing this LAR, the NRC staff considered generally the guidance on acceptance criteria in Chapter 16, Technical Specifications, of NUREG0800, Revision 3. Additionally, the NRC staff evaluated the proposed changes to the STS against what is required to be in the technical specifications under 10 CFR 50.36(c).
3.1 Proposed Changes to SR 3.0.3 VEGP Units 3 and 4 TS SR 3.0.3 currently states the following:
If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, which ever is greater. This delay period is permitted to allow performance of the Surveillance. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
3 If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period, and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
The NRC has typically interpreted SR 3.0.3, which is quoted above, as inapplicable to SRs that have never been previously performed. This is because the allowance provided by SR 3.0.3 is based on the SR typically being satisfactorily met in the past and the most probable result of performing the SR is the verification of conformance with the requirements. Therefore, there is reasonable expectation the SR will be met when performed.
However, the NRC staff recognizes that there are instances in which an SR may not have been performed in the past, but there is still a reasonable expectation the SR will be met when performed. For example, an SR requires testing of a relay contact. A licensee finds the relay contact has never been tested as required in accordance with a particular SR. That licensee, however, finds there is a reasonable expectation the SR will be met when performed because the subject relay contact has been tested by another SR or historical operation of the subject relay contact has been successful.
The delay period allowed by TS SR 3.0.3 offers adequate time to complete SRs that have been missed. In addition, this delay period permits the completion of an SR before complying with required actions or other remedial measures that might preclude completion of the SR. The NRC staff finds the application of the delay period provided by STS SR 3.0.3 acceptable for use on SRs that have never been performed so as long as licensees can provide an adequate determination of reasonable expectation the SR will be met when performed.
The licensee-proposed SR 3.0.3 states the following (the new sentence reflecting the inclusion of SRs that have never been performed is shown in underlined text below):
If it is discovered that a Surveillance was not performed within its specified Frequency, then compliance with the requirement to declare the LCO not met may be delayed, from the time of discovery, up to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or up to the limit of the specified Frequency, which ever is greater. This delay period is permitted to allow performance of the Surveillance. The delay period is only applicable when there is a reasonable expectation the Surveillance will be met when performed. A risk evaluation shall be performed for any Surveillance delayed greater than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and the risk impact shall be managed.
If the Surveillance is not performed within the delay period, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
When the Surveillance is performed within the delay period and the Surveillance is not met, the LCO must immediately be declared not met, and the applicable Condition(s) must be entered.
As stated in the NRCs Safety Evaluation (ML16060A440) attached to the April 21, 2016, approval of TSTF529 and in the licensees LAR, when making a determination of reasonable expectation that the SR will be met when performed, licensees should consider many factors.
These factors include, but are not limited to, things such as the period of time since the SR was
4 last performed, or whether the SR, or a portion thereof, has ever been performed, and many other indications, tests, or activities that might support the expectation that the SR will be met when performed. It is not sufficient to infer the behavior of the associated equipment from the performance of similar equipment. The rigor of determining whether there is a reasonable expectation an SR will be met when performed should increase based on the length of time since the last performance of the SR. If the SR has been performed recently, a review of the SR history and equipment performance may be sufficient to support a reasonable expectation that the SR will be met when performed. For SRs that have not been performed for a long period or that have never been performed, a rigorous evaluation based on objective evidence should provide a high degree of confidence that the equipment is capable of performing its specified safety function(s). The evaluation should be documented in sufficient detail to allow a knowledgeable individual to understand the basis for the determination.
The proposed change, which expands the scope of SR 3.0.3 to SRs that have never been performed, is acceptable because it requires there to be an adequate determination of a reasonable expectation that the SR will be met when performed. In addition, the proposed change augments plant safety since it could prevent unnecessary shutdowns by providing adequate time to complete SRs that have never been performed but are likely to achieve satisfactory results.
3.2 Summary As described in Section 2 of this SE, the regulations contained in 10 CFR 50.36 require that technical specifications include items in specified categories, including LCOs and SRs. The proposed change modifies the SR Applicability requirements. The technical specifications will continue to specify the LCOs and specify the remedial measures to be taken if one of these requirements is not satisfied. The technical specifications will also continue to specify the appropriate SRs to ensure the necessary quality of affected structures, systems and components are maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met. Therefore, the NRC staff finds that the changes to SR 3.0.3 proposed by the licensee meet 10 CFR 50.36(c)(2) and 50.36(c)(3), respectively.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on March 13, 2023. The State official had no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendments change a requirement with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the amendments involve no significant hazards consideration, and there has been no public comment on such finding published in the Federal Register on February 21, 2023 (88 FR 10552). Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).
Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.
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6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributor: Rob Elliott, NRR/DSS/STSB