ML24108A083

Summary of Observation Pre-Submittal Meeting Held with Southern Nuclear Operating Company, Inc., Regarding a Proposed License Amendment Request for Vogtle Electric Generating Plant, Units 3 and 4

ML24108A083
Person / Time
Site:	Vogtle
Issue date:	04/19/2024
From:	John Lamb NRC/NRR/DORL/LPL2-1
To:	Southern Nuclear Operating Co
Shared Package
ML24108A089	List: ML24108A083
References
EPID L-2024-LRM-0046
Download: ML24108A083 (6)

Text

April 19, 2024

LICENSEE: Southern Nuclear Operating Company, Inc.

FACILITY: Vogtle Electric Generating Plant, Units 3 and 4

SUMMARY

OF APRIL 16, 2024, OBSERVATION PRE-SUBMITTAL MEETING HELD WITH SOUTHERN NUCLEAR OPERATING COMPANY, INC.,

REGARDING A PROPOSED LICENSE AMENDMENT REQUEST FOR VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 (EPID NO. L-2024-LRM-0046)

On April 16, 2024, an Observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Southern Nuclear Operating Company, Inc. (SNC, the licensee). The purpose of the meeting was for SNC to describe its plan to submit a license amendment request (LAR) for Vogtle Electric Generating Plant (Vogtle), Units 3 and 4.

SNC is proposing to revise Vogtle, Units 3 and 4, Technical Specification (TS) Subsection 3.7.6, Main Control Room Emergency Habitability Sy stem (VES), by changing Actions Condition A, One valve or damper inoperable; and Surveillance R equirement (SR) 3.7.6.6, Verify all [main control room envelope (MCRE)] isolation valves are OPERABLE and will close upon receipt of an actual or simulated actuation signal on a Frequency of once per 24 months.

A list of attendees is provided as an Enclosure.

On March 20, 2024 (Agencywide Document s and Access Management System (ADAMS)

Accession No. ML24095A059), the meeting wa s noticed on the NRC public webpage.

The NRC staff opened the meeting with introductor y remarks and a roll call of the attendees.

The SNC representative presented slides contained in ML24089A149.

SNC representatives discussed the following topics: (1) proposed changes to TS 3.7.6, Condition A, (2) proposed changes to SR 3.7.6.6, (3) summary, and (4) schedule.

SNC Proposed Changes to TS 3.7.6, Condition A

SNC representative stated that SNC believes that TS 3.7.6, Condition A, is overly restrictive and unnecessarily increases the potential for a unit shutdown. SNC representative said that if Vogtle, Unit 3 or 4, is in Mode 1, 2, 3, or 4 and has more than one required valve inoperable, or more than one required damper inoperable, or one or more required valves and one or more required dampers concurrently inoperable, the Actions for the affected unit specify entering not

just Actions Condition A but also Actions Condition F. The current Required Actions for Condition F require an immediate unit shutdown (Be in Mode 3 within 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in Mode 5 within 36 hours4.166667e-4 days <br />0.01 hours <br />5.952381e-5 weeks <br />1.3698e-5 months <br />).

SNC representative stated that the experience at Vogtle, Units 3 and 4, that leads to an inoperable valve or valves are the following:

Packing leakage, Stem lubrication, Seat leakage, and V002B body leakage.

SNC intends to propose adding a NOTE to Condition A to state the following:

Separate Condition entry is allowed for each valve and each damper.

Currently, TS 3.7.6, Condition A states:

One valve or damper inoperable.

SNC intends to propose revising Condition A, to state:

One valve or damper inoperable with VES safety function maintained.

This allows one or more valves and one or more dampers to be concurrently inoperable, each inoperable device with its own 7-day Completion Time to restore the device to operable status -

provided all safety functions of the VES are maintained. If one or more VES safety functions are lost, the unit must then enter Condition F and be shut down.

SNC Proposed Changes to SR 3.7.6.6

Currently, SR 3.7.6.6 states:

Verify all MCRE isolation valves are OPERABLE and will close upon receipt of an actual or simulated actuation signal. l 24 months

SNC intends to propose revising SR 3.7.6.6 to state:

Verify all MCRE isolation valves are OPERABLE and will close upon receipt of an actual or simulated actuation signal, except for valves that are locked, sealed, or otherwise secured in the actuated position.

This adds an exception to performing the surveillance for MCRE isolation valves that are already secured in the actuated position.

Summary

SNC representative stated that the proposed LAR would reduce the likelihood of an unnecessary unit shutdown.

Schedule

SNC representative said that SNC plans to submit the proposed LAR to the NRC by June 29, 2024. SNC representative stated that SNC plans to request that the NRC staff complete its review 12 months after NRC acceptance of the proposed LAR.

Discussion

The NRC staff asked about the valves and dampers that SNC has declared inoperable for the TS 3.7.6, Condition A. The NRC staff wanted to know the inoperability history.

The NRC staff asked how often SNC has entered TS 3.7.6, Condition A, and has SNC ever challenged the 7-day Completion Time.

The NRC staff asked about the safety functions of the VES.

The NRC staff asked about the proposed phrasing of TS 3.7.6, Condition A, and suggested reviewing it for consistency with the examples in TS Section 1.3, Completion Times. SNC said that it would consider it.

The NRC questioned which valves are in the scope of the proposed TS 3.7.6, Condition A, and Surveillance Requirement (SR) 3.7.6.6. The licensee pointed out the applicable VES valves and some in the Nuclear Island Nonradioactive Ventilation System (VBS) design that would need to be isolated for the MCRE.

The NRC questioned if there is any connection for this proposed LAR and a previous pre-submittal meeting held in September 2023, regarding a proposed LAR to also change TS Subsection 3.7.6. SNC said the two proposed LARs are not linked but both will affect some of the same TS pages.

The NRC staff asked about technical specificat ion task force (TSTF) Traveler-541 and the proposed SR 3.7.6.6. SNC said that the change to SR 3.7.6.6 would be a plant-specific request and would not be a request to adopt TSTF-541, which had not been reviewed and approved for the Westinghouse AP1000 standard technical specifications (W-AP1000-STS).

The NRC staff questioned if SNC would consider this proposed LAR for Vogtle, Units 3 and 4, would be appropriate to consider for a TSTF to the AP1000 TSs. The licensee stated that this may depart from the current AP 1000 Standard TS (STS) and added that the AP1000 are not being maintained because Vogtle is the only U.S. AP1000.

Concluding Remarks

There were no members of the public in attendance.

The NRC staff did not make any regulatory decisions during the meeting. Once received, the NRC staff will perform a thorough review of the proposed LAR. The NRC staff will make any regulatory decisions in writing in a timely manner. Public Meeting Feedback forms were available, but no comments were received.

The meeting adjourned at 9:37 am Eastern Daylight Savings Time (EDT).

Please direct any inquiries to me at John.Lamb@nrc.gov or 301-415-3100.

/RA/

John G. Lamb, Senior Project Manager Plant Licensing Branch, II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket Nos.52-025 and 52-026

Enclosure:

List of Attendees

cc w/encls: Distribution via Listserv

LIST OF ATTENDEES

APRIL 16, 2024, PRE-SUBMITTAL MEETING WITH SOUTHERN NUCLEAR COMPANY

REGARDING A PLANNED LICENSE AMENDMENT REQUEST

TO REVISE TECHNICAL SPECIFICATIONS SUBSECTION 3.7.6,

MAIN CONTROL ROOM EMERGENCY HABITABILITY SYSTEM (VES),

ACTION AND SURVEILLANCE REQUIREMENTS

VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4

ATTENDEE REPRESENTING

John G. Lamb U.S. Nuclear Regulatory Commission (NRC)

Mike Markley NRC Joshua Wilson NRC Nageswara Karipineni NRC Bradley Davis NRC Jason Eargle NRC Brian Griman NRC JP Parent NRC John Parillo NRC Sean Meighan NRC Gurjendra Bedi NRC Ravi Grover NRC Craig Harbuck NRC Scott Egli NRC

Ken Lowery Southern Nuclear Operating Company (SNC)

Ryan Joyce SNC Jason McCrickard SNC Jonathan Hartman SNC Glendon Graybill SNC

Enclosure

ML24108A089 (Package)

ML24095A059 (Meeting Notice)

ML24108A083 (Meeting Summary)

ML24089A149 (SNC Slides)

OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/STSB/BC NAME JLamb KGoldstein SMehta DATE 04/16/2024 04/18/2024 04/19/2024 OFFICE NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MMarkley JLamb DATE 04/18/2024 04/19/2024