ML24352A079
| ML24352A079 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/30/2024 |
| From: | John Lamb Plant Licensing Branch II |
| To: | Southern Nuclear Operating Co |
| Shared Package | |
| ML24352A116 | List: |
| References | |
| EPID L-2024-LRM-0142 | |
| Download: ML24352A079 (8) | |
Text
December 30, 2024 LICENSEE:
Southern Nuclear Operating Company, Inc.
FACILITY:
Vogtle Electric Generating Plant, Units 1 and 2
SUBJECT:
SUMMARY
OF DECEMBER 16, 2024, OBSERVATION PRE-SUBMITTAL MEETING HELD WITH SOUTHERN NUCLEAR OPERATING COMPANY, INC.,
REGARDING A PROPOSED LICENSING ACTION FOR A LICENSE RENEWAL COMMITMENT ITEM RELATED TO AGING MANAGEMENT PLANS FOR REACTOR INTERNALS FOR VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 (EPID L-2024-LRM-0142)
On December 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 proposed licensing action for Vogtle Electric Generating Plant (VEGP, or Vogtle), Units 1 and 2.
SNC is proposing a licensing action for a License Renewal commitment item related to aging management plans (AMPs) for Reactor Internals for Vogtle, Units 1 and 2. SNC plans to be compliant with the latest NRC-approved revision of MRP-227, Materials Reliability Program:
Pressurized Water Reactor Internals Inspection and Evaluation Guidelines.
A list of attendees is provided as an Enclosure.
On December 2, 2024 (Agencywide Documents and Access Management System (ADAMS)
Accession No. ML24337A017), the meeting was noticed on the NRC public webpage.
Background Information NUREG-1920, Volume 2, Safety Evaluation Report Related to the License Renewal of Vogtle Electric Generating Plant, Units 1 and 2, was issued in April 2009 (ML091320236).
NUREG-1920, Volume 2, Appendix A, VEGP Units 1 and 2 License Renewal Commitments, states, in part:
Item No.
Commitment UFSAR Supplement Location Schedule Related LRA Sections/Refs 20 Implement the Reactor Vessel Internals Program as described in LRA Section B.3.24.
The program will be based on the following commitments:
(1) SNC will participate in the industry program for investigating and managing aging effects on reactor internals. This is an ongoing commitment.
(2) SNC will evaluate and implement the results of the industry programs, such as the Electric Power Research Institute Material Reliability Program, as applicable to the VEGP reactor internals. This commitment will be fully implemented prior to the period of extended operation.
(3) SNC will submit an inspection plan for the VEGP reactor internals to the NRC for review and approval not less than 24 months before entering the period of extended operation for VEGP Units 1 and 2. This inspection plan will address the bases, inspection methods, and acceptance criteria associated with aging management of the reactor vessel thermal sleeves and the core support lugs (along with the associated support pads and attachment welds).
A.2.24 Program implementation to be completed prior to the period of extended operation; Numbered items are implemented as noted in each item.
B.3.24 Vogtle, Units 1 and 2 will enter the period of extended operation on January 17, 2027, and February 10, 2029, for Units 1 and 2, respectively.
The Vogtle, Units 1 and 2, Updated Final Safety Analysis Report (UFSAR) (ML24297A651),
Section 19.2.24, Reactor Vessel Internals Program, states:
The Reactor Vessel Internals Program is a plant-specific program that addresses material degradation issues for the VEGP reactor vessel internals.
The program will be based on the following set of implementation commitments:
- a.
SNC will participate in the industry program for investigating and managing aging effects on reactor vessel internals.
- b.
SNC will evaluate and implement the results of the industry programs, such as the [Electric Power Research Institute]
EPRI Material Reliability Program (MRP), as applicable to the VEGP reactor vessel internals.
- c.
SNC will submit an inspection plan for the VEGP reactor vessel internals to the NRC for review and approval not less than 24 months before entering the period of extended operation for VEGP Units 1 and 2. This inspection plan will address the bases, inspection methods, and acceptance criteria associated with aging management of the reactor vessel thermal sleeves and the core support lugs (along with the associated support pads and attachment welds).
The Reactor Vessel Internals Program will be implemented prior to the period of extended operation.
On April 25, 2019 (ML19339G350), the NRC staff issued a safety evaluation for the EPRI MRP-227, Revision 1-A, Materials Reliability Program: Pressurized Water Reactor Internals Inspection and Evaluation Guidelines. The NRC staff found that MRP-227, Revision 1-A is acceptable for referencing in licensing applications for nuclear power plants to the extent specified and under the limitations delineated in the topical report and the final safety evaluation.
EPRI MRP-227, Revision 2, is under NRC review currently.
EPRI MRP-227, Revision 1-A, Appendix B is Guidance on Plan-Specific Applicability Related to Fuel Design or Fuel Management, which states, in part, in Section 2.4, Guideline Applicability, the following:
The guidelines are intended to serve as the primary basis for owner preparation of an engineering program for managing aging in reactor internal components in accordance with the requirement cited in Section 7. The guidelines also serve as the primary basis for preparation of an AMP for reactor internal components to support license renewal. It is beyond the scope of the guidelines to ensure the satisfaction of every plant-specific license renewal or power uprate commitment. Plant-specific commitments remain the responsibility of the owner.
Meeting The NRC staff opened the meeting with introductory remarks and a roll call of the attendees.
The SNC representative presented slides contained in ML24345A004.
The SNC representative discussed the following topics: (1) description, (2) history, (3) schedule, and (4) discussion.
The SNC representative said that Vogtle, Units 1 and 2, meet the conditions in Appendix B of EPRI MRP-227, Revision 1-A.
The SNC representative stated that the Vogtle, Units 1 and 2, thermal sleeve aging management is in compliance with materials initiative requirements in pressurized-water reactor owners group (PWROG)-16003, Revision 2, Evaluation of Potential Thermal Sleeve Flange Wear, March 14, 2024 (ML24074A343), Appendix A, Guidance for Thermal Sleeve Flange Wear Inspection.
The SNC representative said that the Vogtle, Units 1 and 2, core support lugs are inspected in accordance with American Society of Mechanical Engineers (ASME)Section XI 10-year B-N visual examinations.
The SNC representative stated that SNC believes that there is not a need for additional NRC staff review and approval of the technical details and/or basis for the Vogtle, Units 1 and 2, plant-specific inspection plans, because the technical basis for the scope, periodicity, nondestructive examination requirements, and acceptance criteria are all now generically approved through EPRI MRP-227, Revision 1-A.
The SNC representative stated that the proposed Vogtle, Units 1 and 2, inspection plans are compliant with EPRI MRP-227, Revision 1-A.
The SNC representative said that once EPRI MRP-227, Revision 2, is approved by the NRC staff, SNC will update the Vogtle, Units 1 and 2, licensing action to EPRI MRP-227, Revision 2, as outlined in the schedule provided by the EPRI MRP.
The SNC representative stated that licensing action items associated with EPRI MRP-227, Revision 1-A, will not be evaluated due to these no longer being required with the expected approval of EPRI MRP-227, Revision 2.
The SNC representative said that the planned submittal fulfills the intent of commitment item 20 from NUREG-1920.
The SNC representative stated that when EPRI MRP-227, Revision 2, is approved by the NRC staff, SNC will update its Vogtle, Units 1 and 2, Reactor Internals Strategic Plan in accordance with the schedule provided by the EPRI MRP.
The SNC representative said that if guidance is not implemented in accordance with EPRI MRP-227, Revision 2, SNC will submit a deviation in accordance with Nuclear Energy Institute (NEI) 03-08, Guideline for Management of Material Issues, dated February 2017 (ML19079A256).
The SNC representative stated that the proposed licensing action will be submitted to the NRC by January 15, 2025.
The following items were discussed:
MRP-227, Revision 2 Currently approved MRP (MRP-227, Revision 1-A)
Implementation requirements Guidelines The NRC staff stated that it cannot review a licensing action based on a document that has yet to be approved such as MRP-227, Revision 2. The NRC staff stated that it could review the licensing action in accordance with NRC-approved MRP-227, Revision 1-A.
There were two members of the public in attendance that had no comments.
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 licensing action. 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 10:23 am Eastern Time (ET).
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. 50-424 and 50-425
Enclosure:
List of Attendees cc: Listserv
LIST OF ATTENDEES DECEMBER 16, 2024, PRE-SUBMITTAL MEETING WITH SOUTHERN NUCLEAR COMPANY REGARDING A PROPOSED LICENSING ACTION RELATED TO MRP-227 VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 ATTENDEE REPRESENTING John G. Lamb U.S. Nuclear Regulatory Commission (NRC)
Mike Markley NRC John Tsao NRC Carolyn Fairbanks NRC James Medoff NRC Michael Benson NRC On Yee NRC Steven Levitus NRC Zach Turner NRC Rachel Qian NRC Grace Pennington NRC Jeanne Johnston Southern Nuclear Operating Company (SNC)
Ryan Joyce SNC Corey Thomas SNC Aaron Knighton SNC Joel Sausman SNC Paul Guill Duke Energy Sofia Bouhrizi
Électricité de France (EDF)
Enclosure
ML24352A116 (Package)
ML24337A017 (Meeting Notice)
ML24352A079 (Meeting Summary)
ML24345A004 (SNC Slides)
OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA DNRL/NVIB/BC DORL/LPL2-1/BC DORL/LPL2-1/PM NAME JLamb KZeleznock ABuford MMarkley (EMiller for) JLamb DATE 12/16/2024 12/26/2024 12/17/2024 12/30/2024 12/30/2024