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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
Charles R. Pierce Southern Nuclear Regulatory Affairs D1rector Operating Company, Inc.
40 Inverness Center Parkway Post Office Box 1295 B1rmmgham. AL 35201 Tel 205.992.7872 Fax 205 992.7601 SOUTHERN...\.
COMPANY February 26, 2014 Docket Nos.: 50-425 NL-14-0250 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant - Unit 2 Request for Relaxation of Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
References:
- 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012. ML12056A045.
- 2. Letter to NRC, Vogtle Electric Generating Plant - Units 1 and 2, Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013. ML13059A382.
Ladies and Gentlemen:
This letter transmits a request for relaxation of the requirements contained in NRC Order EA-12-049. On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference 1) to Southern Nuclear Operating Company (SNC). Reference 1 was immediately effective and directs the Vogtle Electric Generating Plant (VEGP) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. As described in the Overall Integrated Plan for VEGP (Reference 2), one assumption of the VEGP mitigation strategies is dependent upon installation of low leakage Reactor Coolant Pump (RCP) shutdown seals.
SNC planned to install RCP shutdown seals by the Fall 2014 refueling outage (2R17) that would have supported our FLEX strategies for the plant. However, recent post-operational testing of RCP shutdown seals has potentially invalidated that assumption.
U. S. Nuclear Regulatory Commission NL-14-0250 Page 2 An extension of one additional refueling cycle is requested, which would move the implementation date to completion of the Spring 2016 refueling outage.
Section IV of NRC Order EA-12-049 (Reference 1) states that licensees proposing to deviate from requirements contained in NRC Order EA-12-049 may request that the Director, Office of Nuclear Reactor Regulation, relax those requirements. Therefore, in accordance with Section IV of NRC Order EA-12-049, SNC is requesting that the Director, Office of Nuclear Reactor Regulation, relax the requirement for completion of full implementation as prescribed in Section IV.A.2 of NRC Order EA-12-049 and as described in the attachment to this letter.
SNC considers that, upon approval by the NRC, the alternative full implementation date proposed in the attachment will constitute a relaxation to the NRC Order EA-12-049 for VEGP Unit 2.
This letter contains no new NRC commitments. If you have any questions, please contact John Giddens at 205.992.7924.
Mr. C. R. Pierce states he is the Regulatory Affairs Director for 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,
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C. R. Pierce Regulatory Affairs Director CRP/JMG/RCW Swom to and subscribed before me this~ day of ~~ 1 2014.
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Enclosure:
Vogtle Electric Generating Plant - Unit 2 Request for Relaxation
U.S. Nuclear Regulatory Commission NL-14-0250 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Bost, Executive Vice President & Chief Nuclear Officer Ms. T. E. Tynan, Vice President- Vogtle Mr. B. L. lvey, Vice President - Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations RType: CVC7000 U.S. Nuclear Regulatory Commission Mr. E. Leeds, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle Mr. L. M. Cain, Senior Resident Inspector- Vogtle Ms. J. A. Kratchman, NRRIJLD/PMB Mr. E. E. Bowman, NRRIDPRIPGCB Alabama Department of Public Health Mr. J. H. Turner, Environmental Director Protection Division
Vogtle Electric Generating Plant - Unit 2 Request for Relaxation of Requirement IV.A.2 of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)
Enclosure Vogtle Electric Generating Plant - Unit 2 Request for Relaxation
Enclosure to NL-14-0250 Request for Relaxation Vogtle Electric Generating Plant- Unit 2 Request for Relaxation 1 Relaxation Request In accordance with the process specified in Section IV of Nuclear Regulatory Commission (NRC) Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Reference 1), Southern Nuclear Operating Company(SNC) hereby submits a request for schedule relaxation from the Order requirements for completion of full implementation for Vogtle Electric Generating Plant (VEGP) Unit 2 either no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required in Condition C.l.a of the Order, or December 31, 2016, whichever comes first.
2 Order Requirement from Which Relaxation is Requested NRC Order EA-12-049,Section IV.A.2 requires completion of full implementation of the Order requirements either no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required by Condition C.l.a, or December 31, 2016, whichever comes first.
In accordance with the requirements of the Order, SNC submitted the Overall Integrated Plan for VEGP (Reference 2) on February 27, 2013. The Overall Integrated Plan milestone schedule identified the completion dates for full implementation of NRC Order EA-12-049 for Unit 1 as completion of the Fall 2015 refueling outage, and for Unit 2 as completion of the Fall 2014 refueling outage.
NRC Order EA-12-049 requires the development, implementation, and maintenance of guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond design basis external event (BDBEE). As described in the Overall Integrated Plan for VEGP, these mitigation strategies are dependent upon installation of low leakage Reactor Coolant Pump (RCP) shutdown seals. These seals will ensure the safety functions of containment integrity (during an extended loss of alternating current power or ELAP), and core cooling (RCS inventory and level) are maintained for beyond design basis external events (BDBEEs).
3 Justification for Relaxation Request The RCP shutdown seals provide additional safety margin during a BDBEE by serving as a passive means of protecting the reactor. The seals reduce the risk to the plant (Core Damage Frequency) by limiting the loss of reactor coolant system (RCS) water inventory during the event.
Due to recent post-operational testing of the RCP shutdown seals at other plants, there is a need to enhance that design. The total implications of the shutdown seal testing results for reactor coolant pumps are currently being assessed. Resolution of these issues will require additional analytical work. Additionally, procedural development and training will also be necessary. These factors also affect SNC's ability to safely plan, and implement activities supporting FLEX.
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Enclosure to NL-14-0250 Request for Relaxation Based on this timeline, there is uncertainty that the full implementation of the mitigation strategies in accordance with NRC Order EA-12-049 would be completed by the Order requirement date.
The current required implementation date for Unit 2 is at the end of the Fall 2014 refueling outage. An extension of one additional refueling cycle is requested, which would move the implementation date to the end of the Spring 2016 refueling outage. This revised completion date is still within the maximum allowed time frame of December 2016. The extension would provide additional time to resolve industry issues; design, test and qualify the new seals; and, for SNC to safely plan, schedule, and install the new seals at VEGP. Additionally, the new seals will provide added safety margin during a BDBEE.
4 Conclusion As described above, compliance with the current NRC Order EA-12-049 schedule requirement for full completion of implementation of mitigation strategies would result in hardship or unusual difficulty without a compensating increase in the level of safety. Therefore, in accordance with the provisions of Section IV of the Order, SNC requests relaxation of the requirement described in Section IV.A.2, as explained above.
5 References
- 1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events,"
dated March 12,2012.
- 2. Vogtle Electric Generating Plant- Units 1 and 2 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013.
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