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EPID:L-2022-LLA-0120, MTS - Meeting Summary - Public Meeting on March 28, 2023- Hatch RPV Head Closure Bolts LAR LAR (Approved, Closed) |
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MONTHYEARNL-22-0406, Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes2022-08-19019 August 2022 Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes Project stage: Request ML22258A1532022-09-15015 September 2022 NRR E-mail Capture - Acceptance Review - Hatch Closure Studs in TS Table 1.1-1 Modes LAR (L-2022-LLA-0120) Project stage: Acceptance Review ML22305A7032022-11-0101 November 2022 NRR E-mail Capture - Potential Audit for Hatchs RPV Head Studs LAR Project stage: Approval ML22320A0722022-11-17017 November 2022 Regulatory Audit in Support of Review of the Application to Relax Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs Project stage: Approval ML22355A2082022-12-21021 December 2022 NRR E-mail Capture - RAI - Hatch, Units 1 and 2, Reactor Pressure Vessel RPV Head Studs LAR Project stage: RAI NL-23-0003, Response to Request for Additional Information Regarding License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 12023-01-20020 January 2023 Response to Request for Additional Information Regarding License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1 Project stage: Response to RAI ML23033A0282023-01-30030 January 2023 NRR E-mail Capture - Revised Estimates for Hatch RPV Studs LAR Project stage: Approval ML23034A2462023-02-21021 February 2023 Audit Summary for License Amendment Request to Relax Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs Project stage: Other PMNS20230217, Notice of Public Meeting with Southern Nuclear Operating Company, Inc. (SNC) to Discuss Submitted License Amendment Request (LAR) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch)2023-03-0303 March 2023 Notice of Public Meeting with Southern Nuclear Operating Company, Inc. (SNC) to Discuss Submitted License Amendment Request (LAR) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch) Project stage: Meeting ML23088A2282023-03-0303 March 2023, 28 March 2023, 3 April 2023 MTS - Meeting Summary - Public Meeting on March 28, 2023- Hatch RPV Head Closure Bolts LAR LAR Project stage: Request ML23065A0922023-03-0505 March 2023 NRR E-mail Capture - Revised Estimate Hours and Completion Date - Hatch RPV Head Closure Bolts LAR (L-2022-LLA-0120) Project stage: Approval ML23088A2362023-03-28028 March 2023 SNC Presentation - Public Meeting - 03-28-2023 - Page from ML22231B055 Project stage: Meeting ML23088A3882023-04-0303 April 2023 Summary of March 28, 2023, Observation Public Meeting Held with SNC, Regarding a License Amendment Request Regarding the Reactor Pressure Vessel Head Closure Bolts for Edwin I. Hatch Nuclear Plan, Units 1 and 2 Project stage: Meeting PMNS20230486, Notice of Public Meeting with Southern Nuclear Operating Company, Inc. (SNC) to Discuss Submitted License Amendment Request (LAR) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch)2023-04-20020 April 2023 Notice of Public Meeting with Southern Nuclear Operating Company, Inc. (SNC) to Discuss Submitted License Amendment Request (LAR) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch) Project stage: Meeting ML23136B2952023-04-20020 April 2023, 19 May 2023 Summary of May 02, 2023, Observation Public Meeting Held with Southern Nuclear Operating Company, Inc., Regarding a LAR for the Reactor Pressure Vessel Head Closure Bolts for Edwin I. Hatch Nuclear Plant, Units 1 and 2 Project stage: Request ML23136B2942023-05-19019 May 2023 Summary of May 02, 2023, Observation Public Meeting Held with Southern Nuclear Operating Company, Inc., Regarding a LAR for the Reactor Pressure Vessel Head Closure Bolts for Edwin I. Hatch Nuclear Plant, Units 1 and 2 Project stage: Meeting ML23248A4902023-07-10010 July 2023 NCP-2023-004: Non-Concurrence on Round 2 Request for Information on Hatch Reactor Pressure Bolts License Amendment Request Project stage: RAI ML23249A2082023-09-0606 September 2023 NRR E-mail Capture - Change in Estimated Review Schedule and Level of Effort for Hatch Revise TS Table 1.1-1 (Modes) LAR (L-2022-LLA-0120) Project stage: Approval ML23264A0142023-09-14014 September 2023 NRR E-mail Capture - (External_Sender) Draft Round-2 RAI - Hatch, Units 1 and 2, Revise TS 1.1-1 Modes LAR Project stage: Draft Other ML23250A0472023-09-20020 September 2023 – 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 Project stage: RAI NL-23-0752, Response to Request for Additional Information Regarding License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes2023-10-20020 October 2023 Response to Request for Additional Information Regarding License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, Modes Project stage: Response to RAI PMNS20231395, Notice of Public Meeting with Southern Nuclear Operating Company, Inc. (SNC) to Discuss Submitted License Amendment Request (LAR) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch)2023-12-21021 December 2023 Notice of Public Meeting with Southern Nuclear Operating Company, Inc. (SNC) to Discuss Submitted License Amendment Request (LAR) for the Edwin I. Hatch Nuclear Plant, Units 1 and 2 (Hatch) Project stage: Meeting ML23361A1092024-01-0808 January 2024 SNC Slides for Public Meeting on 1-8-24 to Discuss Hatch LAR - Revise TS Table 1.1-1 (Modes) to Relax Required No. of Fully Tensioned RPV Head Closure Studs Project stage: Meeting ML24012A1592024-01-30030 January 2024 Summary of January 8, 2024, Meeting Held with Southern Nuclear Operating Company, Inc., to Discuss a RAI License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Head Bolts Project stage: RAI NL-24-0014, Revised Response to Request for Additional Information Regarding License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical.2024-01-30030 January 2024 Revised Response to Request for Additional Information Regarding License Amendment Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical. Project stage: Response to RAI ML24067A0702024-03-0707 March 2024 NRR E-mail Capture - Change in Estimated Review Completion for Hatch Revise TS Table 1.1-1 (Modes) LAR (L-2022-LLA-0120) Project stage: Approval ML23032A3322024-04-24024 April 2024 Issuance of Amendments Nos. 322 and 267, Regarding LAR to Relax Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in TS Table 1.1-1, Modes Project stage: Approval 2023-03-03
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Text
Discussion of RAI Response Regarding:
Hatch Units 1 and 2 Request to Relax the Required Number of Fully Tensioned Reactor Pressure Vessel Head Closure Studs in Technical Specification Table 1.1-1, MODES
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Agenda
- On November 28, 2023, NRC staff and SNC had a public meeting [ML23338A259]
regarding SNCs RAI responses dated October 20, 2023 [ML23293A235].
- The purpose of this meeting is to present additional information that explains SNCs position and to better understand the NRC staffs questions.
- The topics / numbering follow the order of the meeting summary [ML23338A259].
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- 1. RAI-01 / OPERABILITY In November 28, 2023 public meeting, NRC staff questioned SNCs position that the Technical Specification term OPERABILITY does not apply to the reactor pressure vessel (RPV) closure studs.
- No safety evaluation (SE) for any precedent Technical Specification Table 1.1-1 change has mentioned the words operable, operability, inoperable, or inoperability.
- SE for Watts Bar emergency amendment No. 161 regarding change to TS Table 1.1-1 MODES [ML23125A220]:
- While the changes revise the definition of when the plant is in each of these operating modes, they do not substantively affect any other WBN Unit 1 technical specification requirements.
- Finds TS change acceptable since it is derived from acceptable analysis and the other technical specification requirements were unchanged (e.g., TS 3.4.13)
- Uses terms out of service and untensioned 3
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- 1. RAI-01 / OPERABILITY
- SE for Callaway conversion to Improved Technical Specifications (ITS)
[ML021640446] and SE dated May 26, 1988 [ML20155J490]
- SE dated May 26, 1988 mentions meeting ASME Section III stress limits and leakage requirements but does not mention operability.
- Only the ITS SE mentions TS - only mentions Table 1.1-1 4
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- 1. RAI-01 / OPERABILITY In November 28, 2023 public meeting, NRC staff posited that the RPV is in the scope of TS 3.4.1, Recirculation Loops Operating
- Requires two recirculation loops with matched flows to be in operation or one loop in operation with more restrictive thermal limits to be applied; it does not use term OPERABLE nor does TS Bases B 3.4.1 use the term OPERABLE.
- Recirculation loops are part of the RCPB but are external to the reactor vessel [ref TS Bases 3.4.1].
>> The reactor coolant recirculation system is arranged such that a piping failure cannot compromise the integrity of the floodable inner volume of the reactor vessel, thereby ensuring adequate core cooling following a LOCA [U2 FSAR 5.1]. The reactor vessel flange and head flange are well above this piping and floodable volume.
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- 1. RAI-01 / OPERABILITY
- Neither TS 3.4.4 nor TS Bases B 3.4.4 use the term OPERABLE
- LCO places limits on leakage
>> Analyses concluded that leakage through the flange would not occur 6
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- 2. RAI-03 / Material Alteration
- Operating with stud(s) not in service is a configuration change, however:
- Does not alter the requirements of the RPV to meet ASME Section III Code stress limits
>> Analyses show that the RPV, if operated with stud(s) not in service, would still meet the ASME Section III requirements and would not experience leakage through the flange
>> The proposed TS and proposed license conditions are consistent with the analyses
- Does not require changing operating limits (e.g., pressure, temperature, etc.) as ASME Section III is met under existing limits 7
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- 2. RAI-03 / NRC Staff Suggestion of New LCO
- If ASME Section XI requirements cannot be met, NRC approval is required.
- ASME Section XI would still apply to in service SSCs.
- Analyses establish that with stud(s) out of service, ASME Section III Code limits would continue to be met and flange geometry would be preserved. Thus, the RPVs functions to withstand design basis loads and to preclude leakage would continue to be performed.
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- 3. RAI-04 / TS and License Condition Markups 9
Unit 1 License Condition Markup Unit 1 TS Markup
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- 3. RAI-04 / TS and License Condition Markups 10 Unit 2 TS Markup Unit 2 License Condition Markup
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- 3. RAI-04 / TS and License Condition Markups The proposed license conditions are worded such that no RPV stud could be credited as in service if it does not meet ASME Section XI requirements.
- Additionally, regardless of any license condition, SNC is required to seek approval/relief when ASME Section XI requirements are not met.
- The word flaw is defined in ASME Section XI
>> Flaw: an imperfection or unintentional discontinuity that is detectable by nondestructive examination.
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- 4. RAI-05 / Analysis Assumptions
- Analysis assumptions and conditions are straightforward.
- Unit 1 only allows one stud to be out of service or untensioned.
- Unit 2 allows two studs to be out of service or untensioned provided there are at least nine studs between the two.
- It is not necessary to impose any sort of ASME Section XI assumptions as those are regulatory requirements that, if not met, would require NRC approval.
Nonetheless, the proposed license condition would reinforce that a stud that does not meet ASME Section XI requirements cannot be credited.
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