ML23135A789
| ML23135A789 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/15/2023 |
| From: | NRC |
| To: | NRC/NRR/DNRL |
| References | |
| Download: ML23135A789 (3) | |
Text
From: Billy Gleaves Sent: Monday, May 15, 2023 4:13 PM To: Chamberlain, Amy Christine Cc: Vogtle PEmails; Cayetano Santos; Lauren Nist (She); Vic Cusumano; Joshua Wilson; Brian Wittick; Raul Hernandez; Hanry Wagage; Mike King
Subject:
Vogtle 3&4 LAR 23-003 "Relocation of TS 3.7.9 Spent Fuel Pool Makeup Water Sources" to TRM
- Amy, You will find below, a list of information insufficiency items related to NRCs acceptance review of the subject LAR 23-003.
The NRC staff does not have sufficient information at this time to accept the LAR and is forwarding these items to you so that you could potentially request a call with NRC in order to get more information, request clarification, or provide the location where the information that may satisfy the staffs information needs may exist.
Should you not require any clarification, please let me know and we plan to prepare a draft non-acceptance letter with opportunity to supplement. If you require clarification, please let me know the first opportunity to have that conversation in a public forum, preferably at the regular Thursday public licensing call. Process-wise, the issuance of a non-acceptance with opportunity to supplement letter means that the staff will not continue the acceptance review until such time as the application is supplemented and then a final determination will be made as to acceptance or non-acceptance based on the review of the supplement.
List of Information Insufficiency Items:
The staff needs clarification of the evaluation of the spent fuel pool safety related makeup water sources against LCO selection Criteria 2 and 3 of 10 CFR 50.36(c)(2)(ii), which was provided in Section 3.0 of LAR 23-003. Specifically:
In the event of an extended loss of normal spent fuel pool cooling, the SFP makeup sources listed in TS 3.7.9 may be required for adequate cooling for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. An extended loss of normal SFP cooling because of a loss of non-safety related AC electrical power to the pumps when the decay heat load in the SFP exceeds 4.0 MWt is a transient evaluated in the VEGP Units 3 and 4 FSAR Section 9.1.3.4.3 Abnormal Conditions.
10 CFR 50.36(c)(2)(ii) states, in part:
(ii) A technical specification limiting condition for operation of a nuclear reactor must be established for each item meeting one or more of the following criteria:
(B) Criterion 2. A process variable, design feature, or operating restriction that is an initial condition of a design basis accident or transient analysis that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
(C) Criterion 3. A structure, system, or component that is part of the primary success path and which functions or actuates to mitigate a design basis accident or transient that either assumes the failure of or presents a challenge to the integrity of a fission product barrier.
Provide a justification for your assertion that LCO 3.7.9 does not meet any of the 10 CFR 50.36(c)(2)(ii) selection criteria given that the SFP makeup sources initial specified water volume and alignment are (1) an operating restriction that is an initial condition of a transient analysis that presents a challenge to the integrity of a fission product barrier, and (2) part of the primary success path and which functions to mitigate a transient that presents a challenge to the integrity of a fission product barrier.
Additionally, the LAR references NUREG-1793, AP1000 Final Safety Evaluation Report, Section 16.2.10, which states in part this function does not satisfy any of the criteria in 10 CFR 50.36(c)(2)(ii), but is included in the TS for defense in depth. This statement is based on an incorrect premise and does not consider the increased heat load from additional fuel assemblies in the SFP which were added during the transition from the AP600 design to the AP1000 design. This additional heat load requires the spent fuel pool safety related makeup water sources to be included in TS as specified by 50.36(c)(2)(ii).
<end of list>
Respectfully, 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: 669 Mail Envelope Properties (DM6PR09MB4839C7C6884C4533A83026D29F789)
Subject:
Vogtle 3&4 LAR 23-003 Relocation of TS 3.7.9 Spent Fuel Pool Makeup Water Sources to TRM Sent Date: 5/15/2023 4:13:01 PM Received Date: 5/15/2023 4:13:04 PM From: Billy Gleaves Created By: Bill.Gleaves@nrc.gov Recipients:
"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 "Joshua Wilson" <Joshua.Wilson@nrc.gov>
Tracking Status: None "Brian Wittick" <Brian.Wittick@nrc.gov>
Tracking Status: None "Raul Hernandez" <Raul.Hernandez@nrc.gov>
Tracking Status: None "Hanry Wagage" <Hanry.Wagage@nrc.gov>
Tracking Status: None "Mike King" <Michael.King2@nrc.gov>
Tracking Status: None "Chamberlain, Amy Christine" <acchambe@southernco.com>
Tracking Status: None Post Office: DM6PR09MB4839.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 4386 5/15/2023 4:13:04 PM Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: