ML23128A077

COL Docs - Vogtle 3&4 LAR 23-006 More Restrictive Action for Technical Specification 3.1.9 Supplement

ML23128A077
Person / Time
Site:	Vogtle
Issue date:	05/08/2023
From:	NRC
To:	NRC/NRR/DNRL
References
Download: ML23128A077 (3)

Text

From: Billy Gleaves Sent: Monday, May 8, 2023 10:22 AM To: Dorsey, Keith A.

Cc: Dan Williamson (X2DWWILL@SOUTHERNCO.COM); Vogtle PEmails; Cayetano Santos; Lauren Nist (She); Vic Cusumano; Matthew Hamm; Stewart Bailey; Thomas Scarbrough; Nicholas Hansing

Subject:

Vogtle 3&4 LAR 23-006 "More Restrictive Action for Technical Specification 3.1.9" supplement Keith, From our phone conversation on this topic this morning, these are the draft supplemental items that will very likely be in the non-acceptance with opportunity to supplement letter that we plan to send following the public meeting on Thursday May 11th at 2pm. (official calendar scheduler for this meeting has not yet been revised to reflect this meeting but will be in a day or so).

• The application appears to characterize tests outside the control of TS as TS SRs and use that characterization to determine the SRs in TS are redundant. The LAR states, Neither SR 3.1.9.1 or SR 3.1.9.2 overtly specify a specific acceptance criterion for the stroke-closed or the stroke-timing. While the text of the SR does not contain an explicit statement of the closure acceptance criteria, the TS usage of the phrase within limits is taken to mean less than the amount of time assumed in the safety analysis. An examination of the TS Bases for SR 3.1.9 supports this connection between the phrase within limits and the time required to meet the assumptions in the safety analysis. The acceptance criteria and test description for SR 3.1.9.2 are contained in the SURVEILLANCE column of SR 3.1.9.1. The frequency for the SR is contained in the FREQUENCY column. The information in both columns together are the testing requirement. A reference to the Inservice Testing (IST) Program in the FREQUENCY column does not mean the testing requirement is exactly as in the IST Program; it means the frequency for performance of the TS SR is controlled by the IST Program.

The staff requests supplementary information as to how the Vogtle Units 3 and 4 TS would continue to meet 50.36(c)(3) if SR 3.1.9.2 is deleted, whether any plant-specific design differences between Vogtle Units 3 and 4 and the generic AP1000 plant exist to justify the deletion of SR 3.1.9.2, and a discussion of the difference on plant operations between SR test failure consequences and IST test failure consequences.

• Chapter 16, page 16.0-3 of the SRP, which the staff uses as guidance to evaluate proposed changes to TS, says the staff should consider uniqueness in plant design or other considerations so that 10 CFR 50.36 is met. The proposed changes do not appear to conform to approved guidance for TS format and content found in NUREG-2194, Standard Technical Specifications [STS], Westinghouse Advanced Passive 1000 (AP1000) Plants. The designs of Vogtle Units 3 and 4 do not appear to differ significantly from that assumed in the STS for AP1000 plants to justify the proposed deletion of SR 3.1.9.2. That is, the plant-specific TS Bases for SR 3.1.9.2 refer to an assumed closure time in the safety analysis, which is consistent with the STS bases.

The staff requests supplementary information as to the justification for deviation from the STS.

• SR 3.0.1 states that failure to meet an SR shall be failure to meet the LCO. LCO 3.0.2 requires meeting the TS required actions. Describe how a test failure would impact plant operation if the test were only controlled by the IST Program, and whether that would be sufficient to ensure that facility operation is maintained within limits.

Billy William (Billy) Gleaves Senior Project Manager NRR/Vogtle Project Office US Nuclear Regulatory Commission The contents of this message may be sensitive. If this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Do not disseminate this message without the permission of the author. Communications by this author do not represent NRC policy or staff positions and are not binding on the Commission.

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 665 Mail Envelope Properties (DM6PR09MB48396FA37BF847A069BDAB409F719)

Subject:

Vogtle 3&4 LAR 23-006 More Restrictive Action for Technical Specification 3.1.9 supplement Sent Date: 5/8/2023 10:22:23 AM Received Date: 5/8/2023 10:22:26 AM From: Billy Gleaves Created By: Bill.Gleaves@nrc.gov Recipients:

"Dan Williamson (X2DWWILL@SOUTHERNCO.COM)" <x2dwwill@southernco.com>

Tracking Status: None "Vogtle PEmails" <Vogtle.PEmails@usnrc.onmicrosoft.com>

Tracking Status: None "Cayetano Santos" <Cayetano.Santos@nrc.gov>

Tracking Status: None "Lauren Nist (She)" <lauren.nist@nrc.gov>

Tracking Status: None "Vic Cusumano" <Victor.Cusumano@nrc.gov>

Tracking Status: None "Matthew Hamm" <Matthew.Hamm@nrc.gov>

Tracking Status: None "Stewart Bailey" <Stewart.Bailey@nrc.gov>

Tracking Status: None "Thomas Scarbrough" <Thomas.Scarbrough@nrc.gov>

Tracking Status: None "Nicholas Hansing" <Nicholas.Hansing@nrc.gov>

Tracking Status: None "Dorsey, Keith A." <kadorsey@southernco.com>

Tracking Status: None Post Office: DM6PR09MB4839.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3794 5/8/2023 10:22:26 AM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: