NL-16-2710, Request for One-Time Exception to LIC-109, LIC-101, and LIC-500 Acceptance Review Criteria

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Request for One-Time Exception to LIC-109, LIC-101, and LIC-500 Acceptance Review Criteria
ML17010A325
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 01/10/2017
From: Pierce C
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-16-2710
Download: ML17010A325 (2)


Text

& Southern Nuclear Charles R. Pierce Regulatory Affairs Director 40 Inverness Center Parkway Post Office Box 1295 Birmingham, AL 35242 205 992 7872 tel 205 992 7601 fax crpierce@ southernco.com JAN 1 0 2017 Docket Nos.: 50-424 NL-16-2710 50-425 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant- Units 1 and 2 Request for One-Time Exception to LIC-1 09, LIC-1 01. and LIC-500 Acceptance Review Criteria Ladies and Gentlemen:

The Office of Nuclear Reactor Regulation (NRR) Office Instructions No. LIC-1 09, Revision 1, Acceptance Review Procedures, provides guidance to the NRR staff for determining the acceptability of an application for an amendment to a license. One of the criteria listed in LIC-109, Revision 1 is that a requested licensing action (ALA) cannot cite any unapproved guidance. To address Generic Safety Issue (GSI-191) in a timely manner, Southern Nuclear Operating Company (SNC) requests a one-time exception to this LIC-109 acceptance criteria. This exception would allow the reliance of WCAP-17788, "Comprehensive Analysis and Test Program for GSI-191 Closure," for the Vogtle Electric Generating Plant (VEGP) Units 1 and 2 prior to this report being approved by the Nuclear Regulatory Commission (NRC). WCAP-17788 is used to establish the acceptance limits for fiber in the reactor vessel, and thus comprises only a small part of the SNC response. NRR Office Instructions No. LIC-101, Revision 4, License Amendment Review Procedures, and LIC-500, Revision 5, Topical Report Process, also discuss that topical reports (such as WCAP-17788) are to be approved by the NRC prior to being implemented by reference as the technical basis for a licensee action. SNC therefore requests a one-time exception for this specific requirement in these two other NRR Office Instructions.

SNC intends to submit their ALA to resolve GSI-191 (including an updated response to Generic Letter 2004-02, a license amendment request to use a risk-informed methodology for the emergency core cooling systems (ECCS) acceptance criteria, and specific exemption requests) during March or April of 2017. Due to delays during the review process for WCAP-17788, NRC approval is not expected until the third or fourth quarter of 2017. As discussed in a public meeting held November 29, 2016, this delay creates issues for SNC's submittal.

Due to the voluminous nature of WCAP-17788, incorporating the relied-upon information from the 6 volume WCAP-17788 into SNC's submittal is not practical. This would create unnecessary work for the NRC staff and potentially introduce further delay in the approval of this report due to the unnecessary expenditure of resources. The NRC would basically be writing two Safety Evaluation Reports for this methodology: one for the actual WCAP-17788, and another for SNC's application. For these reasons, this was not the preferred approach of the NRC staff in attendance of the November 29, 2016 public meeting.

U.S. Nuclear Regulatory Commission NL-16-2710 Page 2 Waiting until WCAP-17788 is formally approved prior to SNC submitting their RLA is undesirable and/or unpractical for the following reasons:

1. SNC delaying their submittal will ultimately delay resolution to this outstanding generic safety issue. Beneficial plant modifications (e.g. modified sump strainer heights) dependent upon NRC approval of this RLA will be unnecessarily delayed.
2. Delaying the SNC submittal for six or more months creates a personnel resource issue, as personnel resources are reassigned to other tasks and may not be able to reinvest themselves back into the GSI-191 project once the topical report is approved.

Lastly, allowing a one-time exception to the aforementioned NRR Office Instructions is beneficial for the following reasons:

1. Accepting the SNC submittal for review prior to the WCAP-17788 being approved would allow the NRC to see the implementation of the methodology with plant data, possibly increasing the efficiency of the review and acceptance.
2. Most of the technical review of the SNC submittal, including the entire risk-informed portion, does not directly involve this topical report methodology. Therefore, the NRC staff will be able to perform much of their review of SNC's submittal in parallel with the review of the methodology.

For these reasons, this one-time waiver to the NRC acceptance criteria was discussed favorably at the November 29, 2016 public meeting.

So that SNC can proceed with their submittal (including review by the appropriate SNC management committees) it is respectfully requested that the NRC grant this waiver in writing by February 10, 2017.

RespecttuWsubmitted, t.fl- f~

C. R. Pierce Regulatory Affairs Director CRP/RMJ cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President & CEO Mr. D. G. Best, Executive Vice President & Chief Nuclear Officer Mr. D. R. Madison, Vice President- Fleet Operations Mr. M. D. Meier, Vice President- Regulatory Affairs Mr. B. K. Taber, Vice President- Vogtle 1 & 2 Mr. B. J. Adams, Vice President- Engineering Mr. D. D. Sutton, Regulatory Affairs Manager- Vogtle 1 & 2 RType: CVC7000 U.S. Nuclear Regulatory Commission Ms. C. Haney, Regional Administrator Mr. M. D. Orenak, NRR Project Manager- Vogtle 1 & 2 Mr. E. T. Coffman, Senior Resident Inspector- Vogtle 1 & 2