ML24030A909
| ML24030A909 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/10/2024 |
| From: | Turner Z NRC/NRR/DORL/LPL2-1 |
| To: | Coleman J Southern Nuclear Operating Co |
| Turner Z, NRR/DORL/LPL2-1 | |
| References | |
| EPID L-2023-LLA-0061 | |
| Download: ML24030A909 (18) | |
Text
April 10, 2024 Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 - ISSUANCE OF AMENDMENT NOS. 224 AND 207, REGARDING REVISION TO TECHNICAL SPECIFICATION 3.4.14 - REACTOR COOLANT SYSTEM PRESSURE ISOLATION VALVE LEAKAGE, SURVEILLANCE REQUIREMENT 3.4.14.1 (EPID L-2023-LLA-0061)
Dear Jamie Coleman:
The U.S. Nuclear Regulatory Commission (NRC) has issued the enclosed Amendment No. 224 to Renewed Facility Operating License NPF-68 and Amendment No. 207 to Renewed Facility Operating License NPF-81 for the Vogtle Electric Generating Plant (Vogtle), Units 1 and 2, respectively. The amendments consist of changes to the Technical Specifications (TS)
Surveillance Requirements (SR) in response to your application dated May 1, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23121A267), as supplemented by letters dated November 17, 2023 (ML23321A242) and February 8, 2024 (ML24039A175).
The amendments would revise TS 3.4.14 RCS [Reactor Coolant System] Pressure Isolation Valve (PIV) Leakage, SR 3.4.14.1 to limit required testing to frequencies specified in the Inservice Testing Program in accordance with the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) by removing all other SR 3.4.14.1 Frequency testing criteria from the current TSs.
A copy of the related Safety Evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice.
If you have questions, you can contact me at 301-415-2258 or Zachary.Turner@nrc.gov.
Sincerely,
/RA/
Zachary M. Turner, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425
Enclosures:
- 1. Amendment No. 224 to NPF-68
- 2. Amendment No. 207 to NPF-81
- 3. Safety Evaluation for Vogtle cc: Listserv SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-424 VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 224 Renewed License No. NPF-68
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Vogtle Electric Generating Plant, Unit 1 (the facility) Renewed Facility Operating License No. NPF-68 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated May 1, 2023, as supplemented by letters dated November 17, 2023 and February 8, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations set forth in 10 CFR Chapter I; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-68 is hereby amended to read as follows:
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 224, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 90 days.
FOR THE NUCLEAR REGULATORY COMMISSION Michael Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to License No. NPF-68 and the Technical Specifications Date of Issuance: April 10, 2024 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2024.04.10 14:43:16 -04'00'
SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-425 VOGTLE ELECTRIC GENERATING PLANT, UNIT 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 207 Renewed License No. NPF-81
- 1.
The Nuclear Regulatory Commission (the Commission) has found that:
A.
The application for amendment to the Vogtle Electric Generating Plant, Unit 2 (the facility) Renewed Facility Operating License No. NPF-81 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated May 1, 2023, as supplemented by letters dated November 17, 2023 and February 8, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations as set forth in 10 CFR Chapter I; B.
The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.
There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations set forth in 10 CFR Chapter I; D.
The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.
The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.
- 2.
Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-81 is hereby amended to read as follows:
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 207, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
- 3.
This license amendment is effective as of its date of issuance and shall be implemented within 90 days.
FOR THE NUCLEAR REGULATORY COMMISSION Michael Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation
Attachment:
Changes to License No. NPF-81 and the Technical Specifications Date of Issuance: April 10, 2024 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2024.04.10 14:43:58 -04'00'
ATTACHMENT VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 TO LICENSE AMENDMENT NO. 224 RENEWED FACILITY OPERATING LICENSE NO. NPF-68 DOCKET NO. 50-424 AND TO LICENSE AMENDMENT NO. 207 RENEWED FACILITY OPERATING LICENSE NO. NPF-81 DOCKET NO. 50-425 Replace the following pages of the Licenses and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.
Remove Pages Insert Pages License License License No. NPF-68, page 4 License No. NPF-68, page 4 License No. NPF-81, page 3 License No. NPF-81, page 3 TSs TSs 3.4.14-3 3.4.14-3 3.4.14-4 Renewed Operating License NPF-68 Amendment No. 224 (1)
Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.
(2)
Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No.
224, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
(3)
Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.
(4)
Deleted (5)
Deleted (6)
Deleted (7)
Deleted (8)
Deleted (9)
Deleted (10)
Mitigation Strategy License Condition The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:
(a)
Fire fighting response strategy with the following elements:
- 1.
Pre-defined coordinated fire response strategy and guidance
- 2.
Assessment of mutual aid fire fighting assets
- 3.
Designated staging areas for equipment and materials
- 4.
Command and control
- 5.
Training and response personnel (b)
Operations to mitigate fuel damage considering the following:
- 1.
Protection and use of personnel assets
- 2.
Communications
- 3.
Minimizing fire spread
- 4.
Procedures for Implementing integrated fire response strategy
- 5.
Identification of readily-available pre-staged equipment
- 6.
Training on integrated fire response strategy Renewed Operating License NPF-81 Amendment No. 207 (2)
Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia, pursuant to the Act and 10 CFR Part 50, to possess but not operate the facility at the designated location in Burke County, Georgia, in accordance with the procedures and limitations set forth in this license; (3)
Southern Nuclear, pursuant to the Act and 10 CFR Part 70, to receive, possess, and use at any time special nuclear material as reactor fuel, in accordance with the limitations for storage and amounts required for reactor operation, as described in the Final Safety Analysis Report, as supplemented and amended; (4)
Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70 to receive, possess, and use at any time any byproduct, source and special nuclear material as sealed neutron sources for reactor startup, sealed sources for reactor instrumentation and radiation monitoring equipment calibration, and as fission detectors in amounts as required; (5)
Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40, and 70, to receive, possess, and use in amounts as required any byproduct, source or special nuclear material without restriction to chemical or physical form, for sample analysis or instrument calibration or associated with radioactive apparatus or components; (6)
Southern Nuclear, pursuant to the Act and 10 CFR Parts 30, 40 and 70, to possess, but not separate, such byproduct and special nuclear materials as my be produced by the operation of the facility authorized herein.
C.
This license shall be deemed to contain and is subject to the conditions specified in the Commissions regulations set forth in 10 CFR Chapter 1 and is subject to all applicable provisions of the Act and to the rules, regulations, and orders of the Commission now or hereafter in effect, and is subject to the additional conditions specified or incorporated below.
(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.
(2) Technical Specifications and Environmental Protection Plan The Technical Specifications contained in Appendix A, as revised through Amendment No. 207 and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.
The Surveillance requirements (SRs) contained in the Appendix A Technical Specifications and listed below are not required to be performed immediately upon implementation of Amendment No. 74. The SRs listed below shall be
RCS PIV Leakage 3.4.14 Vogtle Units 1 and 2 3.4.14-3 Amendment No. 224 (Unit 1)
Amendment No. 207 (Unit 2)
SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.4.14.1
NOTES----------------------------
- 1.
Not required to be performed in MODES 3 and 4.
- 2.
Not required to be performed on the RCS PIVs located in the RHR flow path when in the shutdown cooling mode of operation.
- 3.
RCS PIVs actuated during the performance of this Surveillance are not required to be tested more than once if a repetitive testing loop cannot be avoided.
Verify leakage from each RCS PIV is equivalent to 0.5 gpm per nominal inch of valve size up to a maximum of 5 gpm at an RCS pressure 2215 psig and 2255 psig.
In accordance with the INSERVICE TESTING PROGRAM SR 3.4.14.2 Verify RHR System suction isolation valve interlock prevents the valves from being opened with a simulated or actual RCS pressure signal 450 psig.
In accordance with the Surveillance Frequency Control Program
SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO SOUTHERN NUCLEAR OPERATING COMPANY VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 DOCKET NOS. 50-424, 50-425 AMENDMENT NOS. 224 AND 207 TO RENEWED FACILITY OPERATING LICENSE NOS. NPF-68 AND NPF-81
1.0 INTRODUCTION
By application dated May 1, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23121A267), as supplemented by letters dated November 17, 2023 (ML23321A242) and February 8, 2024 (ML24039A175), Southern Nuclear Operating Company (SNC, the licensee), submitted a license amendment request (LAR) proposing changes to the Vogtle Electric Generating Plant (Vogtle), Units 1 and 2, Technical Specifications (TSs). The submittal also included an alternative request to requirements for the inservice testing (IST) frequencies of certain valves required by the American Society of Mechanical Engineers (ASME) Code for Operation and Maintenance of Nuclear Power Plants (OM Code) as incorporated by reference in Title 10 of the Code of Federal Regulations, Section 50.55a, Codes and standards, that is being addressed by separate correspondence.
The amendment request proposes to revise TS 3.4.14, RCS [Reactor Coolant System]
Pressure Isolation Valve (PIV) Surveillance Requirement (SR) Frequency in SR 3.4.14.1 to limit required testing to frequencies specified in the ASME OM Code for the IST program.
The supplements dated November 17, 2023, and February 8, 2024, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on July 11, 2023 (88 FR 44167).
2.0 REGULATORY EVALUATION
2.1 Regulatory Requirements and Guidance Documents The NRC staff considered the following regulatory requirements and guidance during its review of the proposed changes.
Title 10 of the Code of Federal Regulations (10 CFR) Part 50, Domestic Licensing of Production and Utilization Facilities, establishes the fundamental regulatory requirements for production and utilization facilities. Section 50.36 of 10 CFR, Technical specifications, provides the content and information that must be included in a facilitys TS. TSs are required to include (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation; (3) surveillance requirements (SRs); (4) design features; and (5) administrative controls.
The regulation 10 CFR 50.36(c)(3) states that Surveillance requirements are requirements relating to test, calibration, or inspection to assure that the necessary quality of systems and components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met.
The regulation 10 CFR 50.54(jj) states that [s]tructures, systems, and components [SSCs]
subject to the codes and standards of 10 CFR 50.55a must be designed, fabricated, erected, constructed, tested, and inspected to quality standards commensurate with the importance of the safety function to be performed.
Option B of 10 CFR Part 50, Appendix J, provides a performance-based option for establishing leak test frequencies for containment isolation valves. Although Appendix J does not apply specifically to all PIVs, it provides requirements for establishing a performance-based test program for valve leakage testing.
The regulation 10 CFR 50.55a(f)(4) Inservice testing standards requirement for operating plants, states, in part, that throughout the service life of a boiling or pressurized water-cooled nuclear power facility, pumps and valves that are within the scope of the ASME OM Code must meet the IST requirements (except design and access provisions) set forth in the ASME OM Code that become effective subsequent to editions and addenda specified in 10 CFR 50.55a(f)(2) and (3) and that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv),
to the extent practical within the limitations of design, geometry, and materials of construction of the components.
The regulation 10 CFR 50.55a(f)(5)(ii), IST program update: Conflicting IST Code requirements with technical specifications, states, in part, that if a revised IST Program for a facility conflicts with the TS for the facility, the licensee must apply for an amendment of the TS to conform the TS to the revised program.
3.0 TECHNICAL EVALUATION
3.1 Proposed Changes to TS SR 3.4.14.1 In Enclosure 1 of the licensees submittal dated May 1, 2023, the licensee proposed to revise the frequencies for TS SR 3.4.14.1 to reflect the removal of the requirement that the surveillance be performed: (1) every 18 months, (2) prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months (except for valves HV-8701A/B and HV-8702A/B), and (3) for systems rated at less than 50 percent RCS design pressure, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation (except for valves HV-8701A/B and HV-8702A/B). The only remaining SR Frequency proposed is to be in accordance with the Inservice Testing Program.
Current TS SR 3.4.14.1 would be revised as follows (strikeout text deleted):
Frequency In accordance with the INSERVICE TESTING PROGRAM, and 18 months AND Prior to entering MODE 2 whenever the unit has been in MODE 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months (except for valves HV-8701A/B and HV-8702A/B)
AND For systems rated at less than 50% RCS design pressure, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation (except for valves HV-8701A/B and HV-8702A/B).
The licensee stated that the proposed change has no effect on the PIV allowable leakage limits and only the frequency of the SR is affected. The frequency of the SR will continue to be in accordance with the IST Program and the ASME OM Code.
The current TS SR 3.4.14.1 for Vogtle contains testing requirements that are required by the ASME OM Code and are implemented by the IST Program. Performance of leakage rate testing for PIVs is performed per the requirements of the IST Program, which is governed by 10 CFR 50.55a. The TS SRs would be based on the IST Program and associated calendar and condition-based frequencies. The current various frequencies exist despite the IST Program Frequency being based on the governance of 10 CFR 50.55a and the existing requirements of the ASME OM Code.
In its letter dated May 1, 2023, the licensee stated, in part, that, The proposed change:
Eliminates the requirement to periodically perform the SR every 18 months in addition to the Frequency specified in the ASME Code; Eliminates the requirement to perform the SR prior to entering Mode 2 whenever the unit has been in Mode 5 for 7 days or more, if leakage testing has not been performed in the previous 9 months; and Eliminates the requirement to perform the SR within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation for systems rated at less than 50% RCS design pressure.
The elimination of these Frequencies also removes the need for the exceptions for valves HV-8701A/B and HV-8702A/B.
The proposed change to SR 3.4.14.1 has no effect on the TS PIV allowable leakage limits (i.e., the Surveillance Requirement itself). With the proposed change, only the frequency of the testing is affected, and RCS PIV testing would continue to be performed in accordance with the IST Program and the ASME Code.
The licensee stated that its TS define the IST Program as the program that fulfills the requirements of 10 CFR 50.55a(f).
The proposed change is intended to maintain consistency with the regulations and to allow the IST Program to govern the Frequency of the testing program. The licensee stated that the proposed change is acceptable because the current Frequency is inconsistent with the ASME OM Code, could limit plant operations unnecessarily, and is overly restrictive based on operating history. The proposed change would ensure consistency with the regulations and that ASME OM Code testing requirements for the RCS PIVs will be retained in the IST Program.
Duplicative testing requirements in the TS SR would be removed.
The elimination of the current time based 18-month and 9-month frequencies is justified by the licensee for the reasons described above. In addition, the licensee noted that the ASME OM Code specifies a testing frequency of 2 years which is greater than the current TS requirements.
In its letter dated November 17, 2023, the licensee stated that all the PIVs are required to be tested currently in accordance with the IST Program for Vogtle, Units 1 and 2. Further, the licensee stated that all the PIVs listed in Attachment 4 are required to satisfy TS SR 3.4.14.1 and all the PIVs remain in the Vogtle, Units 1 and 2, IST Program. Vogtle, Units 1 and 2, IST Program will be revised following NRC approval, to clarify that testing of the other PIVs listed in is required to satisfy TS SR 3.4.14.1. The licensee stated that the focus of this LAR is to align the performance of the TS surveillance related to RCS PIV operational leakage with the frequency of the leakage testing required in accordance with the IST Program for each site, as based on the applicable edition and addenda of the ASME OM Code incorporated by reference in 10 CFR 50.55a. The licensee added that, aside from the proposed change in testing frequency for the RCS PIVs, the current test method requirements of the TS surveillance remain unchanged, as no new leakage requirements are being added or removed. The licensee also indicated that the valves would continue to be required to meet the leakage limits provided within their respective TS SR.
The licensee describes the PIV testing regime as follows: Per ASME OM Code, Subsection ISTC, Inservice Testing of Valves in Water-Cooled Reactor Nuclear Power Plants, paragraph ISTC-3630, subparagraph (a), leakage rate testing for PIVs is required to be performed at least once every 2 years. The IST Program for Vogtle, Units 1 and 2, reflect a frequency of testing the RCS PIVs at least every 18-months. Upon issuance of the license amendment, the IST Program document will be revised to reflect the ISTC-3630 subparagraph (a) frequency of testing the RCS PIVs at least once every 2 years, as based on the ASME OM Code - 2004 Edition through 2006 Addenda reflected in the Vogtle, Units 1 and 2, fourth 10-year IST Program interval (ML17298A197).
Vogtle also has a requirement, for systems rated at less than 50 percent of the RCS design pressure, to perform the surveillance within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation. The purpose of this test is to verify that the valves are closed or seated after being actuated. The LAR stated that indications are available that would show PIV leakage into systems with pressures lower than RCS pressure. The licensee also stated that the condition-based requirement is redundant to tests specified in the ASME OM Code (e.g., exercise testing per ASME OM Code Subsection ISTC, paragraph ISTC-3520 and position indication verification per ASME OM Code, Subsection ISTC, paragraph ISTC-3700). The licensee concluded that performing the testing for this purpose is unnecessary and may result in higher occupational exposure.
The licensee stated that [t]he NRC regulations give precedence to the ASME Code when there are conflicts between the TS and the [ASME] Code. The licensee stated that this position is supported by regulation in 10 CFR 50.55a(f)(5)(ii), IST program update: Conflicting IST Code requirements with technical specifications, which states, in part, that if a revised IST Program for a facility conflicts with the TS for the facility, the licensee must apply for an amendment of the TS to conform the TS to the revised program. Therefore, the licensee is proposing that this proposed change is consistent with the regulations with respect to conflicting requirements.
The licensee states that its proposed revision to the surveillance frequencies for verifying RCS PIV leakage to remove the restrictive and redundant requirements, the frequencies would instead reflect being in accordance with the IST Program, which is required by regulation per both 10 CFR 50.54(jj) and 10 CFR 50.55a(f)(4).
In Attachment 4 of Enclosure 1 of its LAR, the licensee provided a table of PIVs subject to testing pursuant to SR 3.4.14.1. The table included the valve number, a description of the valve, the system, the ASME Code Class, and the OM Code Category for each valve covered by the SR. The licensee also provided, in Attachment 5 of Enclosure 1, a table containing the PIV leakage test history for Vogtle, Units 1 and 2.
The licensee stated that because the proposed change will not eliminate any SRs, the requirements of 10 CFR 50.36(c) will continue to be met. Additionally, the licensee stated that the proposed change does not alter the design fabrication, erection, construction, or inspection of the PIVs, and therefore, the requirements of 10 CFR 50.54(jj) will continue to be met.
The licensee concluded that the current time and condition-based frequencies specified by SR 3.4.14.1 are unnecessary and can be removed from the Vogtle Unit 1 and 2 TSs because the requirement to perform the SR in accordance with the IST Program will ensure that the PIVs can perform their safety function. The licensee concluded that the proposed frequency is consistent with the ASME OM Code and regulations and is supported by the PIV operating history.
3.2 NRC Staffs Evaluation of Changes to SR 3.4.14.1 Frequency The NRC staff evaluated the information provided in Enclosure 1 of the LAR and its supplements dated November 17, 2023, and February 8, 2024. The NRC staff concluded that the proposed changes to Vogtles TS SR Frequency would ensure ASME OM Code testing requirements for the RCS PIVs will be retained in the IST Program, in lieu of the TS SR. The staff also determined that the Frequency Change to INSERVICE TESTING PROGRAM, is consistent with TSTF-545, TS Inservice Testing Program Removal & Clarify SR Usage Rule Application to Section 5.5 Testing (ML15294A555), previously approved amendments for Vogtle, Units 1 and 2, which allowed the licensee to have component testing frequencies based on the IST Program (ML17152A218). In addition, the NRC staff has determined that the TS SR requirements to perform leakage testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation is mirrored in the IST Program, which meets the established requirements of the ASME OM Code that are incorporated by reference in 10 CFR 50.55a(a)(1)(iv). Based on the above, the staff finds that the requirement for leakage testing within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> following valve actuation is unnecessary and may be deleted from the TS.
The NRC staff reviewed the leakage test history for the Vogtle PIVs as presented in Attachment 5 of Enclosure 1 of the LAR and concluded that the history indicates that the valves have been reliable and exhibit relatively low leakage when tested. This provides additional confidence that performing TS SR 3.4.14.1 at frequencies in accordance with the IST Program and thereby eliminating the time and condition-based frequencies as delineated in their current TSs will not degrade the ability of the PIVs to perform their safety function.
In a supplemental letter dated November 17, 2023, the licensee stated that Vogtle, Units 1 and 2, IST Program Plan (ML17298A197) includes Note 4 for the following valves listed in Enclosure 1, Attachment 4, of the LAR submittal dated May 1, 2023:
1/2-1204-U6-079 1/2-1204-U6-083 1/2-1204-U6-080 1/2-1204-U6-084 1/2-1204-U6-081 1/2-1204-U6-085 1/2-1204-U6-082 1/2-1204-U6-086 Note 4 states that these PIVs are tested at the frequencies specified in TS SR 3.4.14.1.
Additionally, for the remaining valves listed in Enclosure 1, Attachment 4, of the LAR submittal dated May 1, 2023, the IST Program Plan references procedure 14450-1/2, respectively:
1/2-HV-8701A/B 1/2-1204-U4-123 1/2-1204-U4-147 1/2-HV-8702A/B 1/2-1204-U4-143 1/2-1204-U4-148 1/2-1204-U4-120 1/2-1204-U4-144 1/2-1204-U4-149 1/2-1204-U4-121 1/2-1204-U4-145 1/2-1204-U4-150 1/2-1204-U4-122 1/2-1204-U4-146 Vogtle Procedure 14450-1/2, RCS Pressure Isolation Valve Inservice Leak Test, Section 1.2, states: The purpose of this procedure is to provide instructions to demonstrate that the leakage of the [RCS PIVs] is within limits in accordance with [TS] SR 3.4.14.1. Based on the above, the NRC staff finds that all valves listed in Enclosure 1, Attachment 4, of the LAR submittal dated May 1, 2023, are tested to satisfy the requirements of TS SR 3.4.14.1.
In its letter dated May 1, 2023, the licensee provided a discussion of how the proposed frequency is consistent with the Vogtle, Unit 3 and 4 TSs. The NRC staff notes that it did not consider this discussion to provide significant additional justification for the proposed change to the Vogtle, Units 1 and 2, TSs.
Based on the above, the NRC staff finds that the proposed changes would meet 10 CFR 50.55a(f)(5)(ii), with regard to reconciling conflicting requirements between the ASME Code and TS.
Based on the above, the NRC staff concludes that the proposed changes would continue to meet 10 CFR 50.36(c)(3) because the surveillances and frequencies are maintained in the IST Program as specified in the TS.
4.0 STATE CONSULTATION
In accordance with the Commissions regulations, the Georgia State official was notified on January 29, 2024, of the proposed issuance of the amendments. On February 9, 2024, the State officials informed the NRC that the State of Georgia has no comments.
5.0 ENVIRONMENTAL CONSIDERATION
The amendment changes requirements with respect to installation or use of facility components located within the restricted area as defined in 10 CFR Part 20 and changes SRs. The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has issued previously a proposed finding that the amendments involve no significant hazards consideration (88 FR 44167, dated July 11, 2023), and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.
6.0 CONCLUSION
The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.
Principal Contributors: G. Bedi T. Scarbrough S. Smith Date: April 10, 2024
ML24030A909 NRR-058 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/SCPB/BC NAME ZTurner JLamb KGoldstein BWittick DATE 01/30/2024 02/02/2024 02/02/2024 02/14/2024 OFFICE NRR/DEX/EMIB/BC NRR/DSS/STSB/BC OGC - NLO NRR/DORL/LPL2-1/BC NAME SBailey SMehta (A)
ANaber MMarkley DATE 02/05/2024 01/29/2024 03/26/2024 04/10/2024 OFFICE NRR/DORL/LPL2-1/PM NAME ZTurner DATE 04/10/2024