ML23250A047

Request for Additional Information Regarding License Amendment Request to Relax Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Bolts in Technical Specifications Table 1.1-1, Modes

ML23250A047
Person / Time
Site:	Hatch
Issue date:	09/20/2023
From:	Bo Pham Plant Licensing Branch II
To:	Coleman J Southern Nuclear Operating Co
Kalathiveettil, D
References
EPID L-2022-LLA-0120, NCP-2023-004
Download: ML23250A047 (1)

Text

September 20, 2023 Ms. Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 - REQUEST FOR ADDITIONAL INFORMATION REGARDING LICENSE AMENDMENT REQUEST TO RELAX REQUIRED NUMBER OF FULLY TENSIONED REACTOR PRESSURE VESSEL HEAD CLOSURE BOLTS IN TECHNICAL SPECIFICATIONS TABLE 1.1-1, MODES (EPID L-2022-LLA-0120)

Dear Ms. Coleman:

By letter dated August 19, 2022, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22231B055), as supplemented by letter dated January 20, 2023 (ML23020A902), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2. Specifically, the licensee is proposing to relax the required number of fully tensioned reactor pressure vessel (RPV) head closure bolts in Technical Specification (TS) Table 1.1-1, MODES of the Hatch units.

By letter dated December 21, 2022 (ML22355A208), the NRC staff requested additional information (RAI). By letter dated January 20, 2023 (ML23020A902), SNC provided responses to the RAI. Public meetings were held with SNC on March 28, 2023 (ML23088A388) and May 2, 2023 (ML23136B294), to further discuss the licensees submittal and supplemental information.

To complete its review, the NRC staff requests additional information as shown in the enclosure to this letter.

These questions were previously provided to SNC to make sure that the RAI is understandable, the regulatory basis is clear, to ensure there is no proprietary information, and to determine if the information was docketed previously.

This request is now released formally with a 30-day calendar response period from the date of this letter.

J. Coleman If you have any questions, please contact Dawnmathews Kalathiveettil at 301-415-3100 or via email at Dawnmathews.Kalathiveettil@nrc.gov.

Sincerely, Digitally signed by Bo Bo M. M. Pham Date: 2023.09.20 Pham 20:04:50 -04'00' Bo Pham, Director Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.: 50-321 and 50-366

Enclosure:

1. Request for Additional Information cc: Listserv

REQUEST FOR ADDITIONAL INFORMATION RELATED TO LICENSE AMENDMENT REQUEST TO RELAX REQUIRED NUMBER OF FULLY TENSIONED REACTOR PRESSURE VESSEL HEAD CLOSURE BOLTS IN TECHNICAL SPECIFICATIONS TABLE 1.1-1, MODES EDWIN I. HATCH NUCLEAR PLANT, UNITS 1 AND 2 DOCKET NOS. 50-321 AND 50-366 INTRODUCTION By letter dated August 19, 2022, (Agencywide Documents Access and Management System (ADAMS) Accession No. ML22231B055), as supplemented by letter dated January 20, 2023 (ML23020A902), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Plant (Hatch), Units 1 and 2. Specifically, the licensee is proposing to relax the required number of fully tensioned reactor pressure vessel (RPV) head closure bolts in Technical Specification (TS) Table 1.1-1, MODES of the Hatch units.

To complete its review, the NRC staff requests additional information (RAI) as given below.

REGULATORY BASES Title 10 of the Code of Federal Regulations (10 CFR) Part 50.36, Technical Specifications, specifies the content required to be included in TSs.

Regulations in 10 CFR Part 50, Domestic Licensing of Production and Utilization Facilities, Appendix A, General Design Criteria [GDC] for Nuclear Power Plants, includes the following GDCs applicable to the licensees LAR:

Criterion 1 (GDC 1), Quality standards and records, requires, in part, that structures, systems, and components important to safety be designed, fabricated, erected, and tested to quality standards commensurate with the importance of the safety function to be performed.

Criterion 14 (GDC 14), Reactor coolant pressure boundary, requires the design, fabrication, erection, and testing of the reactor coolant pressure boundary so as to have an extremely low probability of abnormal leakage, or rapidly propagating failure, and of gross rupture.

Criterion 30 (GDC 30), Quality of reactor coolant pressure boundary, which requires in part, that components comprising the reactor coolant pressure boundary be designed, fabricated, erected, and tested to the highest quality standards practical.

Hatch Unit 1 was licensed to the applicable Atomic Energy Commission (AEC) preliminary general design criteria identified in the Federal Register 32 FR 10213, published July 11, 1967 (ML043310029). The Hatch Unit 1 Updated Final Safety Analysis Report (UFSAR), Appendix F, Conformance to the AEC Criteria (ML20303A202), contains the comparison of the applicable AEC criteria to the 10 CFR 50, Appendix A, GDCs.

Enclosure

RAI QUESTIONS

RAI-01

The Hatch submittal uses the term out of service extensively in describing the proposed TS changes for RPV bolts.

1) Please provide an explanation of SNCs proposed use of out of service in the TS as compared to the current TS OPERABLE/OPERABILITY definition.

2) If a bolt is less than fully tensioned, is it considered OPERABLE, and if so, please justify?

RAI-02

In its January 20, 2023, RAI response submittal (ML23020A902), the licensee states that it fully intends to employ sound engineering principles to maintain all RPV bolts in service.

If a flaw is found during a Section XI inspection in an RPV bolt that will not be repaired or replaced, what are the licensees requirements to determine the maximum allowable torque that will be applied during tensioning of that bolt prior to plant startup?

RAI-03

If approved, the latest proposed TS changes provided by the licensee during the public meeting on May 2, 2023 (Summary - ML23136B294), would allow one bolt from each unit to either not be installed or installed and not fully torqued. Please explain how this does not constitute a material alteration of the facility as originally designed and licensed.

Based on the above, please discuss whether the assertion in the No Significant Hazards Consideration that no hardware changes are proposed accurately reflects the proposed change, which would allow operation with up to two RPV head closure bolts not installed or torqued.

RAI-04

During the NRCs May 2, 2023, public meeting, SNC proposed a revision to Unit 2 TS Table 1.1-1 footnotes along with a proposed Unit 2 license condition. Please provide any updated proposed revisions to TS Table 1.1-1 along with SNCs proposed license condition(s) for each unit.

RAI-05

During the NRCs May 2, 2023, public meeting, SNC proposed a revision to Unit 2 TS Table 1.1-1 footnotes along with a proposed Unit 2 license condition.

Please discuss licensee actions that would be taken if more than one reactor head closure bolt cannot be properly examined in accordance with IWB-3515.2(c) of the American Society of Mechanical Engineers Boiler and Pressure Vessel Code,Section XI.

ML23250A047 NCP-2023-004, ADAMS Accession No.: ML23248A490 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/Lait NRR/DORL/LPL2-1/LA NAME DKalathiveettil ABaxter KGoldstein DATE 09/15/2023 09/20/2023 09/20/2023 OFFICE NRR/DNRL/NVIB/BC NRR/DSS/STSB/BC NRR/DEX/EMIB/BC NAME ABuford (JTsao for) MJardaneh SBailey DATE 09/18/2023 09/19/2023 09/19/2023 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/D NRR/DORL/LPL2-1/PM NAME MMarkley (Nonconcur) BPham DKalathiveettil DATE 07/10/2023 09/20/2023 09/20/2023