ML23137A009

COL Docs - Audit Plan for LAR 23-005 Timing of Technical Specification Effectiveness Prior to Initial Criticality

ML23137A009
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Site:	Vogtle
Issue date:	05/17/2023
From:	NRC
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Download: ML23137A009 (5)

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From:

Billy Gleaves Sent:

Wednesday, May 17, 2023 6:50 AM To:

Dan Williamson (X2DWWILL@SOUTHERNCO.COM)

Cc:

Vogtle PEmails

Subject:

Audit Plan for LAR 23-005 "Timing of Technical Specification Effectiveness Prior to Initial Criticality" Attachments:

Vogtle LAR-23-005 Audit Plan (5.10.23 version).docx

Dan, At our kickoff meeting yesterday, I said that I would correct the record and put the Audit Plan for the subject into the public view. This is that record.

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.

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Audit Plan for LAR 23-005 Timing of Technical Specification Effectiveness Prior to Initial Criticality Sent Date:

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1 U.S. NUCLEAR REGULATORY COMMISSION REGULATORY AUDIT OF VOGTLE UNIT 4 LICENSE AMENDMENT REQUEST LAR 23-005 TIMING OF TS EFFECTIVENESS PRIOR TO INITIAL CRITICALITY Docket No.52-026 Version: May 10, 2023 AUDIT PLAN LICENSEE:

Southern Nuclear Operating Company (SNC)

LICENSEE CONTACT:

Keith Dorsey, SNC LOCATION:

U.S. Nuclear Regulatory Commission One White Flint North 11545 Rockville Pike Rockville, Maryland 20852 I. BACKGROUND By letter dated April 17, 2023, Southern Nuclear Operating Company (SNC) submitted license amendment request LAR 23-005, Timing of TS Effectiveness Prior to Initial Criticality (LAR 23-005). SNC is the combined license (COL) holder for the Vogtle Electric Generating Plant (VEGP), Unit 4 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23107A278).

To facilitate the NRC staffs evaluation of LAR 23-005 and to complete its safety review in a timely manner, the NRC staff audit will enable to ensure that information is available to support the licensing basis for the facility.

II. PURPOSE AND REGULATORY AUDIT BASES The purpose of this audit is for the staff to examine and evaluate non-docketed information supporting the LAR to verify the information and conclusions in the subject LAR.

This regulatory audit is based on the following:

VEGP Unit 3, Current Facility Combined License NPF-91, revised April 26, 2023, (14100A106).

VEGP Unit 4, Current Facility Combined License NPF-92, revised April 26, 2023, (AML14100A135).

VEGP Units 3 and 4 UFSAR Tier 1, Revision 10, (ML22179A149).

VEGP Units 3 and 4 UFSAR Tier 2, Revision 11, (ML22179A160).

DCP_DCP_232126 Appendix D and Appendix E: Section 3.2, a calculation or analysis that supported the conclusion that the availability of PCS is not required to mitigate a Mode 4 steam line break accident.

DCP_DCP_232126 Appendix A supported by DCP_DCP_232127 and DCP_DCP_232126 Appendix C: Section 3.2.1,a calculation or analysis that supported

2 the conclusion that when any cold leg temperature is 275°F the injection volume from one CMT (as required by TS 3.5.3) is sufficient to replace the potential reactor coolant volume lost from flashing and evaporation in the event of a worst case breach of the RCPB to continue to maintain the reactor core adequately covered with borated water and provide continued compliance with the required SDM. This calculation provides justification for exclusion of requirements related to accumulator injection (TS 3.5.1) and IRWST injection and recirculation (TS 3.5.6) in Mode 4 when cold leg temperature is 275°F.

DCP_DCP_232126 Appendix A supported by DCP_DCP_232127 and DCP_DCP_232126 Appendix C: Section 3.2.2, a calculation or analysis that supported the conclusion that with all four cold leg temperatures > 275, the injection volume from one CMT and the IRWST is adequate to replace the potential reactor coolant volume lost from flashing and evaporation in the event of a breach of the RCPB. This analysis would also show that additional makeup from the Accumulators is not necessary to replace the potential reactor coolant volume lost from flashing and evaporation in the event of a worst-case breach of the RCPB to continue to maintain the reactor core adequately covered with borated water and provide continued compliance with the required SDM.

Additional supporting references in DCP_232126 Appendix C o APP-SSAR-GSC-607, Revision 2, WCOBRA/TRAC Analysis of AP1000 Large Break LOCA Event During Mode 3 Operation.

o APP-SSAR-GSC-765, Revision 2, Shutdown Evaluation for the AP1000 Plant:

Loss of Normal Residual Heat Removal System (RNS) Cooling Analysis with NOTRUMP.

o APP-FSAR-GEF-073, Revision 0, SBLOCA Analysis and Other Related Changes.

o APP-SSAR-GSC-810, Revision 1, NOTRUMP Predictive Analysis of the CMT Recirculation, CMT Draindown, and ADS Blowdown Pre-Operational Tests.

o APP-SSAR-GSC-732, Revision 3, AP1000 Plant Post-LOCA Long-Term Core Cooling Analysis.

Other documents may be requested during the staffs review. The staff acknowledges and will observe appropriate handling and protection of proprietary information made available for the audit.

V. AUDIT TEAM The following are the NRC audit team members:

Pravin Sawant, Nuclear Engineer Rob Elliott, Senior Safety and Plant Systems Engineer Hanry Wagage, Senior Safety and Plant Systems Engineer Billy Gleaves, Senior Project Manager VI. AUDIT SCHEDULE Date: May 15 - June 16, 2023

3 Location: Online Review via the applicants electronic reading room (eRR).

VII. AUDIT ACTIVITIES AND DELIVERABLES The NRC staff will perform the audit by reviewing the documentation made available by SNC.

The staff will review the documents via eRR from their NRC workstations. If necessary, the staff will conduct meetings or telephone conferences with SNC to discuss issues or questions regarding the documents.

The NRC staff acknowledges the proprietary nature of the information requested and will handle it appropriately throughout the audit. While the NRC staff will take notes, the NRC staff will not remove hard copies or electronic files.

The NRC staff will conduct a non-public entrance telephone conference on the first day of the audit, on or around TBD, and a non-public telephone conference on TBD, at the end of the audit to present audit results.

The staff will prepare an audit report to document the results of the audit. This report will be made publicly available in ADAMS.

The audit will assist the NRC staff in determining if additional RAIs will be necessary to complete the review of the LAR.

If necessary, any circumstances related to the conductance of the audit will be communicated to the NRC Senior Project Manager, Billy Gleaves, 301-415-5848.