ML25137A001
| ML25137A001 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/17/2025 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | Coleman J Southern Nuclear Operating Co |
| References | |
| EPID L-2025-LLA-0082 | |
| Download: ML25137A001 (1) | |
Text
May 17, 2025 Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Company, Inc.
3535 Colonnade Parkway, Bin N-274-EC Birmingham, AL 35243
SUBJECT:
VOGTLE ELECTRIC GENERATING PLANT, UNIT 4 - REQUEST FOR ADDITIONAL INFORMATION REGARDING THE EMERGENCY AMENDMENT TO REVISE TECHNICAL SPECIFICATION 3.7.6, MAIN CONTROL ROOM EMERGENCY HABITABILITY SYSTEM (VES) (EMERGENCY CIRCUMSTANCES) (EPID NO. L-2025-LLA-0082)
Dear Ms. Coleman:
In response to your application dated May 16, 2025, the Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR), under emergency circumstances, to the U.S. Nuclear Regulatory Commission (NRC) for the Combined License (COL) No. NPF-92 for Vogtle Electric Generating Plant (Vogtle), Unit 4. The proposed LAR would revise Technical Specifications (TS) 3.7.6, Main Control Room Emergency Habitability System (VES), to add a one-time allowance to provide time to repair VES bottled air system valve leakage.
The NRC staff has determined that additional information is required for the staff to complete its review.
Please respond to the enclosed request for additional information (RAI) on May 17, 2025.
If you have questions, please contact me at 301-415-3100 or John.Lamb@nrc.gov.
Sincerely,
/RA/
John G. Lamb, Senior Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket No.: 52-026
Enclosure:
RAI cc: Listserv
REQUEST FOR ADDITIONAL INFORMATION OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO EMERGENCY AMENDMENT REQUEST TO TS 3.7.6 TO THE COMBINED LICENSE NO. NPF-92 SOUTHERN NUCLEAR OPERATING COMPANY, INC.
GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MEAG POWER SPVM, LLC MEAG POWER SPVJ, LLC MEAG POWER SPVP, LLC CITY OF DALTON, GEORGIA VOGTLE ELECTRIC GENERATING PLANT, UNIT 4 DOCKET NO.52-026 By letter dated May 16, 2025 (Agencywide Documents Access and Management System Accession No. ML136A392, Southern Nuclear Operating Company (SNC, the licensee) requested that the U.S. Nuclear Regulatory Commission (NRC) amend Vogtle Electric Generating Plant (Vogtle), Unit 4, Combined License (COL) Number NPF-92.
The emergency license amendment request (LAR) proposed to revise Technical Specifications (TS) 3.7.6, Main Control Room Emergency Habitability System (VES), under emergency circumstances, to add a one-time allowance to provide time to repair VES bottled air system valve leakage.
The NRC staff has determined that additional information is required for the staff to complete its review.
REGULATORY EVALUATION In accordance with paragraph C.6. of Section VIII Processes for Changes and Departures of Appendix D to Part 52 Design Certification Rule for the AP1000 Design, changes to the plant-specific TS will be treated as license amendments under 10 CFR 50.90. Pursuant to 10 CFR 50.90, whenever a COL holder desires to amend the license, application for an amendment must be filed with the Commission fully describing the changes desired, and following as far as applicable, the form prescribed for original applications. Per 10 CFR 52.79(a), an application for a COL must contain a final safety analysis report that describes the facility, presents the design bases and the limits on its operation, and presents a safety analysis of the structures, systems, and components of the facility as a whole.
Per 10 CFR 52.79(a)(11), the application for a COL shall include proposed TSs prepared in accordance with the requirements of 10 CFR 50.36. 10 CFR 50.36(c)(2)(i) requires that TS include limiting conditions for operation (LCO) that are the lowest functional capability or performance levels of equipment required for safe operation of the facility. Further, per 10 CFR 50.36(c)(2)(i), when an LCO is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TS until the LCO can be met. Per 10 CFR 50.36(c)(3), TS will include SRs that 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 LCOs will be met. Per 10 CFR 52.97(c), a COL shall contain the terms and conditions, including TSs, as the Commission deems necessary and appropriate.
Under 10 CFR 50.92(a), determinations on whether to grant an applied-for license amendment are to be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. Both the common standards for licenses in 10 CFR 50.40(a)
(regarding, among other things, consideration of the operating procedures, the facility and equipment, the use of the facility, and other TSs, or the proposals) and those specifically for issuance of combined licenses in 10 CFR 52.97(a)(3), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public, and that the applicant will comply with the Commission's regulations.
The regulation in 10 CFR Part 50, Appendix A, General Design Criteria (GDC) 19, Control room, states:
A control room shall be provided from which actions can be taken to operate the nuclear power unit safely under normal conditions and to maintain it in a safe condition under accident conditions, including loss-of-coolant accidents.
Adequate radiation protection shall be provided to permit access and occupancy of the control room under accident conditions without personnel receiving radiation exposures in excess of 5 rem whole body, or its equivalent to any part of the body, for the duration of the accident. Equipment at appropriate locations outside the control room shall be provided (1) with a design capability for prompt hot shutdown of the reactor, including necessary instrumentation and controls to maintain the unit in a safe condition during hot shutdown, and (2) with a potential capability for subsequent cold shutdown of the reactor through the use of suitable procedures.
REQUEST FOR ADDITIONAL INFORMATION (RAI)
RAI #1 The LAR states The proposed change to TS 3.7.6 is based on design provisions that continue to support the MCR habitability during design basis events while crediting non-safety VBS and standby diesel generators. The proposed TS note does not include a requirement to ensure VBS is available during the one-time completion time extension, when VES has a complete loss of function. Without an explicit requirement in the TS for VBS to be available during the one-time completion time extension, the remedial actions permitted by the technical specifications are inadequate to ensure sufficient safety margins are maintained. Provide additional justification for not including VBS in the proposed note or update the note to include VBS.
ML25137A001 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME JLamb KZelenock MMarkley (EMiller for)
JLamb DATE 05/17/2025 05/17/2025 05/172025 05/17/2025