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Category:Letter type:NL
MONTHYEARNL-24-0031, Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R232024-01-29029 January 2024 Inservice Inspection Program Owner'S Activity Report (OAR-1) for Outage 2R23 NL-24-0020, Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report2024-01-22022 January 2024 Plan, Unit 1 Responses to NRC Request for Additional Information for Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0926, Correction of Technical Specification Typographical Error2024-01-12012 January 2024 Correction of Technical Specification Typographical Error NL-23-0878, Request for Exemption from Security Event Notification Implementation2023-11-29029 November 2023 Request for Exemption from Security Event Notification Implementation NL-23-0827, Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.142023-11-17017 November 2023 Response to Requests for Additional Information for a License Amendment Request and a Proposed Alternative Related to TS 3.4.14 NL-23-0750, Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr2023-10-0404 October 2023 Response to Second Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the Colr NL-23-0745, Refueling Outage 1R24 Steam Generator Tube Inspection Report2023-09-22022 September 2023 Refueling Outage 1R24 Steam Generator Tube Inspection Report NL-23-0695, Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2)2023-08-31031 August 2023 Response to Round 2 Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters Operating, Completion Time Extension (LAR-22-002S2) NL-23-0666, License Amendment Request: Remove Combined License Appendix C (LAR 23-008)2023-08-28028 August 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-008) NL-23-0670, Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-08-11011 August 2023 Response to Request for Additional Information Regarding License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0658, Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal2023-08-11011 August 2023 Southern Nuclear Operating Company - Response to Request for Additional Information Regarding Quality Assurance Topical Report Submittal NL-23-0672, Licensee Guarantees of Payment of Deferred Premiums2023-08-10010 August 2023 Licensee Guarantees of Payment of Deferred Premiums NL-23-0542, CFR 50.46 ECCS Evaluation Model Annual Report for 20222023-08-0909 August 2023 CFR 50.46 ECCS Evaluation Model Annual Report for 2022 NL-23-0624, Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis2023-08-0404 August 2023 Report of Changes to Emergency Plan and Summary of 50.54(q) Analysis NL-23-0611, Core Operating Limits Report, Cycle 11 Version 12023-07-19019 July 2023 Core Operating Limits Report, Cycle 11 Version 1 NL-23-0584, Preservice Inspection Program Owner'S Activity Report2023-07-10010 July 2023 Preservice Inspection Program Owner'S Activity Report NL-23-0555, Request for Exemption from Physical Barrier Requirement2023-07-0707 July 2023 Request for Exemption from Physical Barrier Requirement NL-23-0506, to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications2023-07-0505 July 2023 to Non-Voluntary License Amendment Request: Technical Specification Revision to Adopt WCAP-17661-P-A, Improved RAOC and CAOC Fq Surveillance Technical Specifications NL-23-0541, Inservice Inspection Program Owners Activity Report for Outage 1R242023-06-28028 June 2023 Inservice Inspection Program Owners Activity Report for Outage 1R24 NL-23-0444, Quality Assurance Topical Report Submittal2023-06-15015 June 2023 Quality Assurance Topical Report Submittal NL-23-0339, Response to Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters - Operating, Completion Time Extension (LAR-22-002S1)2023-06-13013 June 2023 Response to Request for Additional Information Regarding License Amendment Request for Technical Specification 3.8.3, Inverters - Operating, Completion Time Extension (LAR-22-002S1) NL-23-0455, Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report2023-06-12012 June 2023 Report of 10 CFR 50.59 Changes, Tests, and Experiments and 10 CFR 52 Appendix D Departure Report NL-23-0467, Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S1)2023-06-0909 June 2023 Response to Request for Additional Information Regarding License Amendment Request: Timing of Unit 4 Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005S1) NL-23-0346, License Amendment Request for Exception to Regulatory Guide 1.163 (LAR 23-007)2023-05-25025 May 2023 License Amendment Request for Exception to Regulatory Guide 1.163 (LAR 23-007) NL-23-0383, SNC Response to Regulatory Issue Summary 2023-01:Preparation And.2023-05-19019 May 2023 SNC Response to Regulatory Issue Summary 2023-01:Preparation And. NL-23-0385, License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006R1)2023-05-17017 May 2023 License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006R1) NL-23-0398, Withdrawal of Request of License Amendment Request Regarding More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006)2023-05-16016 May 2023 Withdrawal of Request of License Amendment Request Regarding More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006) NL-23-0372, Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 20222023-05-10010 May 2023 Units 1 & 2, Joseph M. Farley Nuclear Plant - Units 1 & 2, Vogtle Electric Generating Plant - Units 1 & 2, Annual Radiological Environmental Operating Reports for 2022 NL-23-0360, Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel2023-05-0505 May 2023 Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel NL-23-0326, Response to Apparent Violation in NRC Inspection Report 05000424, 425/2023090; EA-22-1082023-05-0101 May 2023 Response to Apparent Violation in NRC Inspection Report 05000424, 425/2023090; EA-22-108 NL-23-0217, License Amendment Request to Revise Technical Specification Surveillance Requirement 3.4.14.1 and Proposed Inservice Testing Alternative ALT-VR-022023-05-0101 May 2023 License Amendment Request to Revise Technical Specification Surveillance Requirement 3.4.14.1 and Proposed Inservice Testing Alternative ALT-VR-02 NL-23-0330, Core Operating Limits Report, Cycle 25, Version 12023-04-26026 April 2023 Core Operating Limits Report, Cycle 25, Version 1 NL-23-0310, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20222023-04-25025 April 2023 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2022 NL-23-0135, License Amendment Request: Timing of Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005)2023-04-17017 April 2023 License Amendment Request: Timing of Technical Specifications Effectiveness Prior to Initial Criticality (LAR-23-005) NL-23-0019, GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI2023-04-12012 April 2023 GEN-ISI-ALT-2023-01, Request to Use Provision of a Later Edition of the ASME Boiler and Pressure Vessel Code, Section XI NL-23-0152, License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-144832023-04-11011 April 2023 License Amendment Request: Technical Specification Revision to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 NL-23-0263, Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report2023-04-0505 April 2023 Southern Nuclear Company Submittal of Drug and Alcohol Testing Errors Identified 10 CFR 26.719(c) 30-Day Report NL-23-0136, License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006)2023-04-0505 April 2023 License Amendment Request: More Restrictive Action for Technical Specification 3.1.9 (LAR-23-006) NL-23-0132, License Amendment Request: Remove Combined License Appendix C (LAR 23-001)2023-04-0404 April 2023 License Amendment Request: Remove Combined License Appendix C (LAR 23-001) NL-23-0014, Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding2023-03-29029 March 2023 Southern Nuclear Operating Co Submittal of Report on Status of Decommissioning Funding NL-23-0208, Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update2023-03-29029 March 2023 Independent Spent Fuel Storage Installation ISFSI, Decommissioning Funding Plan Triennial Update NL-23-0193, Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003)2023-03-24024 March 2023 Request for License Amendment: Relocation of TS 3.7.9, Spent Fuel Pool Makeup Water Sources (LAR-23-003) NL-23-0196, Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-4902023-03-24024 March 2023 Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-490 NL-23-0228, Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21)2023-03-20020 March 2023 Nuclear Property Insurance Coverage as of April 1, 2023 and Licensee Guarantees of Payment of Deferred Premiums (10 CFR 140.21) NL-22-0977, License Amendment Request to Modify Technical Specification 5.5.11.c Acceptance Criteria for Charcoal Filter Testing2023-02-0909 February 2023 License Amendment Request to Modify Technical Specification 5.5.11.c Acceptance Criteria for Charcoal Filter Testing NL-23-0010, Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-4902023-02-0606 February 2023 Response to Request for Additional Information Regarding License Amendment Request for Alternative Source Term, TSTF-51, TSTF-471, and TSTF-490 NL-23-0076, Exigent License Amendment Request: Technical Specification Exceptions for In-containment Refueling Water Storage Tank Operability Prior to Initial Criticality (LAR-23-004)2023-01-31031 January 2023 Exigent License Amendment Request: Technical Specification Exceptions for In-containment Refueling Water Storage Tank Operability Prior to Initial Criticality (LAR-23-004) NL-23-0013, Response to Request for Additional Information Related to 10CFR 50.75 Decommissioning Funding Assurance Requirements2023-01-30030 January 2023 Response to Request for Additional Information Related to 10CFR 50.75 Decommissioning Funding Assurance Requirements NL-23-0068, Responses to NRC Request for Additional Information Related to the Refueling Outage 2R22 Steam Generator Tube Inspection Report2023-01-27027 January 2023 Responses to NRC Request for Additional Information Related to the Refueling Outage 2R22 Steam Generator Tube Inspection Report NL-23-0012, Post-Audit Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel2023-01-20020 January 2023 Post-Audit Supplement to License Amendment Request and Exemptions to Allow Use of Lead Test Assemblies for Accident-Tolerant Fuel 2024-01-29
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Text
B. L. "Pete" lvey Southern Nuclear Vice President Operating Company, Inc.
Regulatory Affairs 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 Tel 205.992.7619 Fax 205.992.5217 5 January 29, 2014 Docket Nos.: 50-424 NL-14-0086 50-425 U. S. Nuclear Regulatory Commission ATTN : Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Units 1 and 2 Response to the Request for Additional Information Associated with Near-Term Task Force Recommendation 2.3, Flooding Walkdowns
References:
- 1. NRC Letter, Request for Information Pursuant to 10 CFR 50.54(f) Regarding Recommendations 2.1, 2.3, and 9.3, of the NTTF Review of Insights from the Fukushima Daiichi Accident, dated March 12, 2012. ML12073A348.
- 2. NRC Letter, Endorsement of Nuclear Energy Institute (NEI) 12-07, "Guidelines for Performing Verification Walkdowns of Plant Flood Protection Features," dated May 31, 2012. ML12144A142.
- 3. Letter to NRC, Vogtle Electric Generating Plant - Units 1 and 2, Flooding Recommendation 2.3 Walkdown Report, dated November 27, 2012.
ML13003A237.
4 . NRC Letter, Request for Additional Information Associated with NTTF Recommendation 2.3, Flooding Walkdowns, dated December 23, 2013, ML13325A891.
Ladies and Gentlemen:
On March 12, 2012, the NRC staff issued Reference 1 requesting information in accordance with 10 CFR 50.54(f). Enclosure 4 of that letter contains specific Requested Information associated with Near-Term Task Force Recommendation 2.3 for Flooding. Using NEI 12-07, as endorsed by the NRC in Reference 2, Southern Nuclear Operating Company (SNC) submitted Reference 3 in response to the request for information.
One of the requirements of NEI12-07 is to identify the available physical margin (APM) associated with each applicable flood protection feature, determine if the margin provided is small, and evaluate any small margins that have potentially significant consequences through the corrective action process. The results of this effort were to be maintained on site for future NRC audits.
U. S. Nuclear Regulatory Commission NL-14-0086 Page 2 Following the NRC staffs initial review of the walkdown reports, regulatory site audits were conducted at a sampling of plants. Based on the walkdown report reviews and site audits, the staff identified additional information necessary to allow them to complete the assessments. Accordingly, by Reference 4 the NRC staff has issued a request for addition information (RAI). The RAI questions and the responses are provided below:
NRC RAI 1: Confirm that the process for evaluating APM was reviewed .
SNC Response: Southern Nuclear Operating Company has completed a review of the process used at Vogtle Electric Generating Plant - Units 1 and 2 to evaluate APMs.
NRC RAI 2: Confirm that the APM process is now or was always consistent with the guidance in NEI 12-07 and discussed in this RAI.
SNC Response: The original walkdown effort followed the guidance provided in NEI 12-07. Additional actions have been taken to make the process consistent with the information provided in this RAI.
NRC RAI 3: If changes are necessary, provide a general description of any process changes to establish this consistency.
SNC Response: While the original walkdown effort followed the guidance provided in NEI 12-07, small margins have now been defined. Also, a specific APM had not been assigned to the seals associated with flood protection features. These items have now been addressed in accordance with the guidance provided in this RAI and entered into the corrective action process, as appropriate, for further evaluation.
NRC RAI 4: As a result of the audits and subsequent interactions with industry during public meetings, NRC staff recognized that evaluation of APM for seals (e.g., flood doors, penetrations, flood gates, etc.) was challenging for some licensees. Generally, licensees were expected to use either Approach A or Approach 8 (described below) to determine the APM for seals:
a) If seal pressure ratings were known, the seal ratings were used to determine APM (similar to example 2 in Section 3.13 of NEI 12-07). A numerical value for APM was documented. No further action was performed if the APM value was greater than the pre-established small-margin threshold value. If the APM value was small, an assessment of "significant consequences" was performed and the guidance in NEI 12-07 Section 5.8 was followed .
U.S. Nuclear Regulatory Commission NL-14-0086 Page 3 b) If the seal pressure rating was not known , the APM for seals in a flood barrier is assumed to be greater than the pre-established small-margin threshold value if the following conditions were met: (1) the APM for the barrier in which the seal is located is greater than the small-margin threshold value and there is evidence that the seals were designed/procured, installed, and controlled as flooding seals in accordance with the flooding licensing basis. Note that in order to determine that the seal has been controlled as a flooding seal, it was only necessary to determine that the seal configuration has been governed by the plant's design control process since installation. In this case, the APM for the seal could have been documented as "not small. "
As part of the RAI response, state if either Approach A or Approach B was used as part of the initial walkdowns or as part of actions taken in response to this RAI .
No additional actions are necessary if either Approach A or B was used.
If neither Approach A or B was used to determine the APM values for seals (either as part of the walkdowns or as part of actions taken in response to this RAI), then perform the following two actions:
- Enter the condition into the CAP (note: it is acceptable to utilize a single CAP entry to capture this issue for multiple seals). CAP disposition of "undetermined" APM values for seals should consider the guidance provided in NEI 12-07, Section 5.8. The CAP disposition should confirm all seals can perform their intended safety function against floods up to the current licensing basis flood height. Disposition may occur as part of the Integrated Assessment. If an Integrated Assessment is not performed, determine whether there are significant consequences associated with exceeding the capacity of the seals and take interim action(s) , if necessary, via the CAP processes. These actions do not need to be complete prior to the RAI response.
- Report the APM as "undetermined" and provide the CAP reference in the RAI response.
SNC Response: Neither Approach A nor B, as described above, were used to determine the APM values for seals. All seals were inspected as part of the original walkdowns for signs of degradation, and corrective actions were taken, if required . As part of the actions taken to address this RAI , the seals have been assigned an APM value of "undetermined" and have been entered into the Corrective Action Program for further evaluation of their available physical margin. Implementation of interim actions will be pursued, if necessary.
This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.
U.S. Nuclear Regulatory Commission NL-14-0086 Page 4 Mr. B. L. lvey states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true.
Respectfully submitted ,
~~ - 7 Mr. B. L. lvey Vice President - Regulatory Affairs BLI/JMG Sworn to and subscribed before me this J_lftkd.ay of V()_ ~<.-<A.f'r , 2014.
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My commission expires: (v\4re;k_ :J.--31 J--o 1f cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski , Chairman , President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Mr. T. E. Tynan , Vice President- Vogtle Mr. C . R. Pierce, Regulatory Affairs Director Mr. D. R. Madison , Vice President- Fleet Operations RType : CVC7000 U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle Mr. L. M. Cain , Senior Resident Inspector- Vogtle State of Georgia Mr. J. H. Turner, Environmental Director Protection Division