NL-14-0960, Pilot 10 CFR 50.69 License Amendment Request, Response to Request for Additional Information Implementation Items
| ML14203A252 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/22/2014 |
| From: | Pierce C Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-14-0960, TAC ME9472, TAC ME9473 | |
| Download: ML14203A252 (14) | |
Text
Charles R. Pierce Southern Nuclear Regulatory Affairs Director Operating Company. Inc.
40 Inverness Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.7872 Fax 205.992.7601 JUL 2 2 2014 SOUTHERN A COMPANY Docket Nos.: 50-424 NL-14-0960 50-425 U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Pilot 10 CFR 50.69 License Amendment Request Response to Request for Additional Information Implementation Items Ladies and Gentlemen:
By letter dated August 31, 2012, Southern Nuclear Operating Company (SNC) requested amendments to the Vogtle Electric Generating Plant (VEGP) Units 1 and 21icensing basis (TAC NOS ME9472 and ME9473). The proposed amendments would revise the VEGP licensing basis to implement 10 CFR 50.69, risk informed categorization and treatment of structures, systems, and components for nuclear power plants.
By letter dated April 17, 2013, the NRC requested additional information. SNC responded to the request by letter dated May 17, 2013 and noted responses to requests for additional information (RAis) 19, 25, 26 and 27 would require additional time to develop and would be provided within 120 days from the date of the SNC letter. SNC provided the responses to RAis 19 and 27 by letter dated July 2, 2013. By letter dated September 13, 2013, SNC provided the results of the Base-Case Sensitivity (BCS) model and the response to RAis that request sensitivity analyses on NRC approved methods including RAis 25 and 26.
By letter dated April 3, 2014, the NRC staff requested additional information. By letter dated May 2, 2014, SNC provided the requested responses.
On June 16, 2014, a conference call was held between SNC and the NRC staff to discuss future implementation items provided in the RAJ responses. The enclosure to this letter provides a summary of these implementation items.
This letter contains no NRC commitments. If you have any questions, please contact Ken McElroy at (205) 992-7369.
U. S. Nuclear Regulatory Commission NL-14-0960 Page2 Mr. C. R. Pierce states he is Regulatory Affairs Director 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, . *..
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C. R. Pierce
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Regulatory Affairs Director CRP~b/Jac Swam to and subscribed before me this d;). dayof~
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Notary Public My commission expires: /0/1 /2 o 11
~I : Response to Request for Additional Information Regarding Pilot 10 CFR 50.69 License Amendment Request Implementation Items 2: Operating Licenses Clean Typed Pages 3: Operating Licenses Marked Up Pages 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 1 & 2 Mr. B. L. lvey, Vice President- Regulatory Affairs Mr. D. R. Madison, Vice President- Fleet Operations Mr. B. J. Adams, Vice President - Engineering Mr. S. C. Waldrup, Regulatory Affairs Manager- Vogtle RType: CVC7000 U. S. Nuclear Reaulatory Commission Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager- Vogtle 1 & 2 Mr. L. M. Cain, Senior Resident Inspector- Vogtle 1 & 2 State of Georgia Mr. J. H. Turner, Environmental Director Protection Division
Vogtle Electric Generating Plant Request to Revise the Licensing Basis to Implement 10 CFR 50.69 Response to Request for Additional Information Regarding Pilot 10 CFR 50.69 License Amendment Request Enclosure 1 Response to Request for Additional Information Regarding Pilot 10 CFR 50.69 License Amendment Request Implementation Items
Implementation Items:
By letters dated May 17,2013, July 2, 2013, and September 13,2013, SNC provided responses to requests for additional information from the NRC staff regarding the Vogtle pilot 10 CFR 50.69 license amendment request. In some responses, SNC provided certain specific actions to address NRC Staff concerns or provided changes to meet current NRC Staff requirements for approval. These actions are considered implementation items required to receive NRC staff approval of the Pilot 10 CFR 50.69 License Amendment Request. Specifically, these implementation items are as follows:
Description Source SNC shall revise its procedures to ensure that when categorizing systems per 10CFR50.69, Plant Vogtle will use a Probabilistic Risk Assessment (PRA) model to assess the following two hazards -Internal Events (including Internal 1 Flooding) and Internal Fire. As mentioned in NEI 00-04, Revision 0, Plant RAI2 Vogtle will use Seismic Margin Analysis method to assess seismic risk, IPEEE screening to assess Other External Events risk, and shutdown safety assessment process per NUMARC 91-06 to assess shutdown risk.
SNC shall use the passive component categorization method as approved by NRC for AN0-2 and as outlined in the Safety Evaluation Report by the Office of Nuclear Reactor Regulation "Request tor Alternative AN02-R&R-004, Revision 2 1, Request to Use Risk-informed Safety Classification and Treatment for RAI5 Repair/Replacement Activities in Class 2 and 3 Moderate and High Energy Systems, Third and Fourth 10-Year In-service Inspection IntervalS', dated April 22, 2009. (ML090930246)
SNC shall revise its procedures to ensure that when performing a risk-informed assessment of the functions, one of the considerations relates to a function being the "sole means" for the successful performance of operator actions required to mitigate an accident or transient OR achieving actions for assuring 3 long term containment integrity, monitoring of post-accident conditions, or RAI7 offsite emergency planning activities. The procedure revision will ensure that when performing a risk-informed assessment of the functions, Plant Vogtle will take credit for alternate means only if the alternate means are proceduralized and included in the Licensed Operator training.
SNC shall update the fire PRA model to include the guidance in NUREG/CR-7150, Vol. 2 (JACQUE-FIRE) which is supported by the Supplemental Interim RAI26 4 Technical Guidance on Fire-Induced Circuit Failure Mode Likelihood Analysis (ADAMS Accession No.: ML14086A165 and ML14017A135).
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Description Source In response to RAI 27, SNC identified that only the following four (4) unendorsed methods included in the Vogtle Fire PRA:
- Not using 0.001 as the lowest value for failure of manual suppression *
- Not using lower failure threshold for sensitive electronics.
- Electrical cabinet heat release rate or severity factors and cabinet to cabinet 5 fires (one method rejected, one method commented, others exist). RAI27
- The alignment factor used for the Vogtle fire PRA for pump oil fires is slightly different than the factor accepted by the NRC staff in the NRC endorsement letter dated June 21, 2012 (ML12171A583).
The fire PRA model that will be used for categorization of systems at Plant Vogtle will not include these unendorsed methods. SNC shall replace them with method(s) acceptable to the NRC staff.
SNC shall revise the categorization procedure to match the guidance in NEI 00-04 regarding the identification of preliminary HSS components. Specifically, Plant Vogtle shall revise its procedure to ensure that if any Structure, System, or Component (SSC) is identified as safety significant from either the integrated 6 PRA component safety significance assessment (Section 5 of NEI 00-04) or the RAI28 defense-in-depth assessment (Section 6 of NEI 00-04), then the associated system function(s) will be identified as preliminary HSS. The Integrated Decision-making Panel (IDP) must intervene to assign any of these components to LSS.
SNC shall complete the following activities related to the Plant Vogtle PRA models:
- Modify the internal events (including internal flooding) PRA model to ensure that no credit is given to AC power recovery for the unrecoverable loss of power scenarios.
7
- Address crediting battery DC power for a longer time than the design in the RAI30 internal events (including internal flooding) PRA model.
- Update human error probability estimation using ERPI's latest state-of-the-practice methodology (e.g., caused based decision tree (CBDT) method and Human Cognitive Reliability/Operator Reliability Experiment (HCR/ORE) method), which addresses time sensitive activities for the internal events (including internal flooding) PRA model and internal fire PRA model.
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Vogtle Electric Generating Plant Pilot 10 CFR 50.69 License Amendment Request Enclosure 2 Operating Licenses Clean Typed Pages
Amendment Additional Condition Implementation Date Number 102 The licensee will implement all applicable crane, load path and Before and height, rigging and load testing guidelines of NUREG-0612 and during reracking ANSI Standard 830.2, as described in the licensee's letters dated operations, as September4, 1997, May 19 and June 12,1998, and evaluated in appropriate.
the staff's Safety Evaluation dated June 29, 1998 154 Upon implementation of the Amendment adopting TSTF-448, As stated in the Revision 3, the determination of CRE unfiltered air inleakage as Additional required by SR 3.7.10.5, in accordance with TS 5.5.20.c.(i), and Condition the measurement of CFE pressure as required by Specification 5.5.20.d, shall be considered met. Following implementation:
(a) The first performance of SR 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
(b) The first performance of the periodic assessment of CRE habitability, specification 5.5.20.c.(ii), shall be within 3 years, plus the 9-month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
The first performance of the periodic measurement of CRE pressure, specification 5.5.20.d, shall be within 18 months, plus the 138 days allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.
Southern Nuclear Operating Company (SNC) is approved to As stated in the implement 10 CFR 50.69 using the processes for categorization of Additional Condition Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the licensee amendment request dated August 31, 2012.
The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.
NRC prior approval is required for a change to a categorization process that is outside the bounds specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment).
Vogtle Unit 1 Amendment No.
APPENDIXD ADDITIONAL CONDITIONS FACILITY OPERATING LICENSE NO. NPF*81 Amendment Additional Condition Implementation Date Number 78 The licensee shall implement a procedure that will prohibit entry into Prior to an extended Emergency Diesel Generator Allowed Outage time (14 implementation of days), for scheduled maintenance purposes, if severe weather Amendment No. 78.
conditions are expected, as described in the licensee's application dated January 22, 1998, as supplemented by letter dated March 18, 1998, and evaluated in the staff's Safety Evaluation dated May 20, 1998.
80 The UFSAR will be updated to include the heat load that will ensure To be included in the temperature limit of 170°F will not be exceeded, as the next appropriate well as the requirement to perform a heat load evaluation before UFSAR update transferring irradiated fuel to either pool, as described in the following the licensee's letters dated September 4, 1997, May 19 and June 12, installation of the 1998, and evaluated in the staff's Safety Evaluation dated June Unit 1 spent fuel 29, 1998. racks.
135 Upon implementation of the Amendment adopting TSTF448, As stated in the Revision 3, the determination of CRE unfiltered air inleakage as Additional Condition required by SR 3.7.10.5, in accordance with TS 5.5.20.c.(i), and the measurement of CFE pressure as required by Specification 5.5.20.d, shall be considered met. Following implementation:
(a) The first performance of SR 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 18*month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003*01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
(b) The first performance of the periodic assessment of CRE habitability, specification 5.5.20.c.(ii), shall be within 3 years, plus the 9*month allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003*01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
The first performance of the periodic measurement of CRE pressure, specification 5.5.20.d, shall be within 18 months, plus the 138 days allowance of SR 3.0.2, as measured from March 23, 2004, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.
Vogtle Unit 2 Amendment No.
Amendment Additional Condition Implementation Date Number Southern Nuclear Operating Company (SNC) is approved to As stated in the implement 10 CFR 50.69 using the processes for categorization of Additional Condition Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the licensee amendment request dated August 31,2012.
The licensee shall implement the items listed in enclosure 1, Implementation items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.
NRC prior approval is required for a change to a categorization process that is outside the bounds specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment).
Vogtle Unit 2 Amendment No.
Vogtle Electric Generating Plant Pilot 10 CFR 50~69 License Amendment Request Enclosure3 Operating Licenses Marked-up Pages
Amendment Additional Changes Implementation Number Date 102 The license will implement all applicable crane , load path Before and and height, rigging and load testing guidelines of NUREG- during 0612 and ANSI Standard 830.2, as described in the reracking licensee's letters dated September 4, 1997, May 19 and operations, as June 12, 1998, and evaluated in the staff's Safety appropriate Evaluation dated June 29, 1998.
154 Upon Implementation of the Amendment adopting TSTF-448, Revision 3, the determination of CAE unfiltered air inleakage as required by SR 3.7.10.5, in accordance with TS 5.5.20.c(i), and the measurement of CFE pressure as required by Specification 5.520.d, shall be considered met.
Following implementation:
(a) The first performance of SA 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SA 3.0.2, as measured from March 23, 2004, the date of the most resent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
(b) The first performance of SA 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 9-month allowance of SA 3.0.2, as measured from March 23, 2004, the date of the most resent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
The first performance of the periodic measurement of CAE pressure, specification 5.5.20.d, shall be within 18 months, plus the 138 days allowance of SA 3.0.2, as measured from March 23, 2004, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.
Insert 1 here Vogtle Unit 1 Amendment No.
Insert 1 Amendment Additional Condition Implementation Number Date Southern Nuclear Operating Company (SNC) is approved to As stated in the implement 10 CFR 50.69 using the processes for additional condition categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the licensee amendment request dated August 31,2012.
The licensee shall implement the items listed in enclosure 1, Implementation Items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.
NRC prior approval is required for a change to a categorization process that is outside the bounds specified above (e.g.,
change from a seismic margins approach to a seismic probabilistic risk assessment).
Amendment Additional Changes Implementation Number Date 102 The license will implement all applicable crane , load path Before and and height, rigging and load testing guidelines of NUREG- during 0612 and ANSI Standard 830.2, as described in the reracking licensee's letters dated September 4, 1997, May 19 and operations, as June 12, 1998, and evaluated in the staff's Safety appropriate Evaluation dated June 29, 1998.
154 Upon Implementation of the Amendment adopting TSTF-448, Revision 3, the determination of CAE unfiltered air in leakage as required by SA 3. 7.1 0.5, in accordance with TS 5.5.20.c(i), and the measurement of CFE pressure as required by Specification 5.520.d, shall be considered met.
Following implementation:
(c) The first performance of SA 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 18-month allowance of SA 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 18 months if the time period since the most recent successful tracer gas test is greater than 6 years.
(d) The first performance of SA 3.7.10.5, in accordance with Specification 5.5.20.c.(i), shall be within the specified frequency of 6 years, plus the 9-month allowance of SA 3.0.2, as measured from March 23, 2004, the date of the most recent successful tracer gas test, as stated in the June 16, 2004 letter response to Generic Letter 2003-01, or within the next 9 months if the time period since the most recent successful tracer gas test is greater than 3 years.
The first performance of the periodic measurement of CAE pressure, specification 5.5.20.d, shall be within 18 months, plus the 138 days allowance of SA 3.0.2, as measured from March 23, 2004, the date of the most recent successful pressure measurement test, or within 138 days if not performed previously.
I Insert 2 here Vogtle Unit 2 Amendment No.
Insert 2 Amendment Additional Condition Implementation Number Date Southern Nuclear Operating Company (SNC) is approved to As stated in the implement 10 CFR 50.69 using the processes for additional condition categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the licensee amendment request dated August 31, 2012.
The licensee shall implement the items listed in enclosure 1, Implementation Items of SNC letter NL-14-0960, dated July 22, 2014, prior to categorizing systems under the process.
NRC prior approval is required for a change to a categorization process that is outside the bounds specified above (e.g.,
change from a seismic margins approach to a seismic probabilistic risk assessment).