Text

Application to Revise Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program
	ML24255A892
Person / Time
Site:	Hatch
Issue date:	09/11/2024
From:	Coleman J; Southern Nuclear Operating Co
To:	; Office of Nuclear Reactor Regulation, Document Control Desk
References
	NL-23-0930
	Download: ML24255A892 (1)
	v • d • e

Regulatory Affairs 3535 Colonnade Parkway Birmingham, AL 35243

205 992 5000

September 11, 2024

Docket Nos.: 50-321 NL-23-0930 50-366 10 CFR 50.90

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001

Edwin I. Hatch Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program

Ladies and Gentlemen:

Pursuant to 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requests a license amendment to the Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 Renewed Facility Operating Licenses DPR-57 and NPF-5 respectively.

SNC requests adoption of TSTF-591, Revise Risk Informed Completion Time (RICT)

Program, which is an approved change to the Standard Technical Specifications (STS),

into the HNP Units 1 and 2 TS. TSTF-591 revises the Technical Specifications (TS)

Section 5.5 Program, Risk Informed Completion Time Program, to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, Reporting Requirements, to inform the NRC of newly developed methods used to calculate a RICT.

The enclosure provides a description and assessment of the proposed changes. provides the existing TS pages marked to show the proposed changes. provides revised (clean) TS pages. The proposed change does not affect the TS Bases.

SNC requests that the amendment be reviewed under the Consolidated Line Item Improvement Process (CLIIP). Approval of the proposed amendment is requested within 6 months of acceptance. Once approved, the amendment shall be implemented within 90 days.

In accordance with 10 CFR 50.91, a copy of this application, with attachments, is being provided to the designated Georgia State Officials.

This letter contains no NRC commitments. If you have any questions, please contact Ryan Joyce at 205.992.6468.

U. S. Nuclear Regulatory Commission NL-23-0930 Page 2

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 11th day of September 2024.

Respectfully submitted,

Jamie M. Coleman Director, Regulatory Affairs Southern Nuclear Operating Company

JMC/agq/cbg

Enclosure:

Description and Assessment

Attachments: 1. Proposed Technical Specification Changes (Mark-up)

2. Revised Technical Specification Pages

cc: Regional Administrator, Region ll NRR Project Manager - Hatch 1 & 2 Senior Resident Inspector - Hatch 1 & 2 Director, Environmental Protection Division - State of Georgia RType: CHA02.004

Edwin I. Hatch Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program

Enclosure to NL-23-0930

Description and Assessment

Enclosure to NL-23-0930 Description and Assessment

1.0 DESCRIPTION

Southern Nuclear Operating Company (SNC) requests adoption of TSTF-591, Revise Risk Informed Completion Time (RICT) Program, which is an approved change to the Standard Technical Specifications (STS), into the HNP Units 1 and 2 TS. TSTF-591 revises the Technical Specifications (TS) Section 5.5 Program, Risk Informed Completion Time Program, to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, Reporting Requirements, to inform the NRC of newly developed methods used to calculate a RICT.

2.0 ASSESSMENT

2.1 Applicability of Safety Evaluation

SNC has reviewed the safety evaluation for TSTF-591 provided to the Technical Specifications Task Force in a letter dated September 21, 2023. This review included a review of the NRC staffs evaluation, as well as the information provided in TSTF-591.

SNC has concluded that the justifications presented in TSTF-591 and the safety evaluation prepared by the NRC staff are applicable to HNP Units 1 and 2 and justify this amendment for the incorporation of the changes to the HNP Units 1 and 2 TS.

2.2 Variations

SNC is not proposing any variations from the TS changes described in TSTF-591 or the applicable parts of the NRC staffs safety evaluation dated September 21, 2023.

3.0 REGULATORY ANALYSIS

3.1 No Significant Hazards Consideration Analysis

Southern Nuclear Operating Company (SNC) requests adoption of TSTF-591, Revise Risk Informed Completion Time (RICT) Program, which is an approved change to the Standard Technical Specifications (STS), into the HNP Units 1 and 2 TS. TSTF-591 revises the Technical Specifications (TS) Section 5.5 Program, Risk Informed Completion Time Program, to reference Regulatory Guide (RG) 1.200, Revision 3, instead of Revision 2, and to make other changes. A new report is added to TS Section 5.6, Reporting Requirements, to inform the NRC of newly developed methods used to calculate a RICT.

SNC has evaluated if a significant hazards consideration is involved with the proposed amendment(s) by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No

E-1 Enclosure to NL-23-0930 Description and Assessment

The proposed change updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used.

The proposed change does not involve a significant increase in the probability of an accident previously evaluated because the change involves no change to the plant or its modes of operation. The proposed change does not increase the consequences of an accident because the design-basis mitigation function of the affected systems is not changed and the consequences of an accident during the extended Risk Informed Completion Time are no different from those during the existing Completion Time. The submittal of information-only reports has no effect on the initiators or consequences of any accidents previously evaluated.

Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No

The proposed change updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used. The proposed change does not change a design function or method of operation of the plant. The proposed change does not involve a physical alteration of the plant (no new or different kind of equipment will be installed).

Therefore, the proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No

The proposed change updates the standard for maintaining and updating PRA models used to calculate a RICT from NRC-approved Regulatory Guide 1.200, Revision 2, to NRC-approved Regulatory Guide 1.200, Revision 3. A new report is added to inform the NRC when a newly developed method is used.

The proposed change supports the extension of Completion Times provided risk is assessed and managed in accordance wi th the NRC-approved RICT Program. The proposed change does not alter any design basis or safety limits. The proposed change affects the standard used to maintain the PRA models used in the RICT Program by changing from one NRC-approved standard to a later NRC-approved version and requiring submittal of an information-only report. The RICT Program will continue to assure that adequate margins of safety are maintained.

E-2 Enclosure to NL-23-0930 Description and Assessment

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, SNC concludes that the proposed change presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards consideration is justified.

3.2 Conclusion

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) 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.

4.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the proposed amendment meets t he eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or envir onmental assessment need be prepared in connection with the proposed amendment.

E-3 Edwin I. Hatch Nuclear Plant - Units 1 & 2 Application to Revise Technical Specifications to Adopt TSTF-591, Revise Risk Informed Completion Time (RICT) Program

Attachment 1 to NL-23-0930

Proposed Technical Specification Changes (Markup)

Programs and Manuals 5.5

5.5 Programs and Manuals

5.5.16 Risk Informed Completion Time Program (continued)

c. When a RICT is being used, any change to the plant config uration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on theRICT.

1. For planned changes, the revised RI CT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration change would lower plant risk and would result in a longer RICT.

d. For emergent conditions, if the extent of condition evaluation for inoper able structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure ( CCF) by either:

1. Numerically accounting for increased possibility of CCF in the RICT calculation;or

2. Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support redundant or diverse SSCs that perform the function(s) of the inoperable SSCs, and, if practicable, reduce the frequency of initiating even ts that challenge the function(s) performed by the ino perable SSCs.

e. The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support this license amendment, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundar ies require prior NRC approval.

e. A RICT calculation must include the following hazard groups: Internal Events PRA model, Internal Flooding PRA model, Internal Fire Events PRA model, and seismic hazards using penalty factors. Changes to these means of assessing the hazard groups require prior NRC approval.

HATCH UNIT 1 5.0-19a Amendment No. 319 Programs and Manuals 5.5

f. The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities."

g. A report shall be submitted in accordance with Specification 5.6.8 before a newly developed method is used to calculate a RICT.

HATCH UNIT 1 5.0-19a Amendment No. 319 Reporting Requirements 5.6

5.6 Reporting Requirements

5.6.7 Reactor Coolant System (RCS) PRESSURE AND TEMPER ATURE LIMITS REPORT (PTLR) (continued)

ii. BWROG-TP-11-023-A, Revision 0 (0900876.401, Revision 0-A),

Linear Elastic Fracture Mechanics Evaluation of General Electric Boiling Water Reactor Water Level Instrument Nozzles for Pressure-Temperature Curve Evaluations, dated May 2013.

c. The PTLR shall be provided to the NRC upon issuance for each reactor vessel fluence period and for any revision or supp lement thereto.

5.6.8 Risk Informed Completion Time (RICT) Program Upgrade Report

A report describing newly developed methods and their implementation must be submitted following a probabilistic risk assessment (PRA) upgrade associated with newly developed methods and prior to the first use of those methods to calculate a RICT. The report shall include:

a. The PRA models upgraded to include newly developed methods;

b. A description of the acceptability of the newly de veloped methods consistent with Section 5.2 of PWROG-19027-NP, Revision 2, "Newly Developed Method Requirements and Peer Review;"

c. Any open findings from the peer-review of the implementation of the newly developed methods and how those findings were dispositioned; and

d. All changes to key assumptions related to newly developed methods or their implementation.

HATCH UNIT 1 5.0-23 Amendment No. 287 Programs and Manuals 5.5

5.5 Programs and Manuals

5.5.16 Risk Informed Completion Time Program (continued)

c. When a RICT is being used, any change to the plant configuration, as defined in NEI 06-09-A, Appendix A, must be considered for the effect on the RICT.

1. For planned changes, the revised RI CT must be determined prior to implementation of the change in configuration.

2. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e.,

not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

3. Revising the RICT is not required if the plant configuration cha nge would lower plant risk and would result in a longer RICT.

d. For emergent conditions, if the extent of condition evaluatio n for inoperable structures, systems, or components (SSCs) is not complete prior to exceeding the Completion Time, the RICT shall account for the increased possibility of common cause failure (CCF) by either:

1. Numerically accounting for the increased possibility of CCF in the RICT calculation; or

2. Risk Management Actions (RMAs) not already credited in the RICT calculation shall be implemented that support re dundant or diverse SSCs that perform the function(s) of the inoperab le SSCs, and, if practicable, reduce the frequency of initiating even ts that challenge the function(s) performed by the inoperable SSCs.

e. The risk assessment approaches and methods shall be acceptable to the NRC. The plant PRA shall be based on the as-built, as-operated, and maintained plant; and reflect the operating experience at the plant, as specified in Regulatory Guide 1.200, Revision 2. Methods to assess the risk from extending the Completion Times must be PRA methods used to support this license amendment, or other methods approved by the NRC for generic use; and any change in the PRA methods to assess risk that are outside these approval boundarie s require prior NRC approval.

e. A RICT calculation must include the following hazard groups: Internal Events PRA model, Internal Flooding PRA model, Internal Fire Events PRA model, and seismic hazards using penalty factors. Changes to these means of assessing the hazard groups require prior NRC approval.

HATCH UNIT 2 5.0-19a Amendment No. 264 Programs and Manuals 5.5

f. The PRA models used to calculate a RICT shall be maintained and upgraded in accordance with the processes endorsed in the regulatory positions of Regulatory Guide 1.200, Revision 3, "Acceptability of Probabilistic Risk Assessment Results for Risk-Informed Activities."

g. A report shall be submitted in accordance with Specification 5.6.8 before a newly developed method is used to calculate a RICT.

HATCH UNIT 2 5.0-19a Amendment No. 264 Reporting Requirements 5.6