ML24204A072

Issuance of Amendment No. 225, Regarding LAR to Revise TS 3.7.9 for a one-time Change to Support Nuclear Service Cooling Water Transfer Pump Repairs - Emergency Circumstances

ML24204A072
Person / Time
Site:	Vogtle
Issue date:	07/23/2024
From:	Dawnmathews Kalathiveettil Plant Licensing Branch II
To:	Coleman J Southern Nuclear Operating Co
References
EPID L-2024-LLA-0099
Download: ML24204A072 (18)

Text

July 23, 2024

Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNIT 1 - ISSUANCE OF AMENDMENT NO. 225, REGARDING LICENSE AMENDMENT REQUEST TO REVISE TECHNICAL SPECIFICATION 3.7.9 FOR A ONE-TIME CHANGE TO SUPPORT NUCLEAR SERVICE COOLING WATER TRANSFER PUMP REPAIRS - EMERGENCY CIRCUMSTANCES (EPID L-2024-LLA-0099)

Dear Jamie Coleman:

The U.S. Nuclear Regulatory Commission ( NRC) has issued the enclosed Amendment No. 225 to Renewed Facility Operating License NPF-68 for the Vogtle Electric Generating Plant (Vogtle), Unit 1. The amendment consists of changes to the Technical Specifications (TSs) in response to your application dated July 20, 2024.

The amendment would revise TS 3.7.9, Ultimate Heat Sink (UHS), to allow a 92-day Completion Time (CT) for Required Action D.2 for an inoperable Nuclear Service Cooling Water (NSCW) basin transfer pump. The TS changes would be a one-time change and in effect only until September 9, 2024, during Vogtle Unit 1 Cycle 25 (1R25). The change also includes a Required Action D.2 Note which prevents application of limiting conditions for operation (LCO) 3.0.4.a and b for entry into MODE 4 following 1R25 unless repairs to the 1A NSCW transfer pump have been completed.

The amendment is issued under emergency circumst ances as described in the provisions of paragraph 50.91(a)(5) of Title 10 of the Code of Federal Regulations due to the time critical nature of the amendment.

In this instance, an emergency exists because the 1A NSCW transfer pump is inoperable and will likely not be declared OPERABLE until after the expiration of the current Required Action and associated CT of TS 3.7.9 Condition D, upon which time Condition F would be entered.

TS 3.7.9 Condition F requires the plant to be in MODE 3 (Hot Standby) in 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in MODE 4 (Hot Shutdown) in 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. Vogtle wants to avoid entry into TS 3.7.9 Condition F, which would require orderly shutdown of the Unit 1 reactor.

A copy of the related safety evaluation is also enclosed. The safety evaluation describes the emergency circumstances under which the am endment was issued and the final no significant hazards consideration determination. A Notice of Issuance addressing the final no significant hazards consideration determination and opportunity for a hearing associated with the emergency circumstances will be in cluded in the Commissions monthly Federal Register notice.

J. Coleman

If you have questions, you can contact me at 301-415-3100 or Dawnmathews.Kalathiveettil@nrc.gov.

Sincerely,

/RA/

Dawnmathews Kalathiveettil, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Docket No. 50-424

Enclosures:

1. Amendment No. 225 to NPF-68

2. Safety Evaluation for Vogtle

cc: Listserv SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY

OGLETHORPE POWER CORPORATION

MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA

CITY OF DALTON, GEORGIA

DOCKET NO. 50-424

VOGTLE ELECTRIC GENERATING PLANT, UNIT 1

AMENDMENT TO RENEWED FA CILITY OPERATING LICENSE

Amendment No. 225 Renewed License No. NPF-68

1. The Nuclear Regulatory Commission (the Commission) has found that:

A. The application for amendment to the Vogtle Electric Generating Plant, Unit 1 (the facility) Renewed Facility Operating License No. NPF-68 filed by the Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated July 20, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commission's rules and regulations as set forth in 10 CFR Chapter I;

B. The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission;

C. There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commission's regulations set forth in 10 CFR Chapter I;

D. The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and

E. The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commission's regulations and all applicable requirements have been satisfied.

Enclosure 1

J. Coleman

2. Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-68 is hereby amended to read as follows:

Technical Specifications and Environmental Protection Plan

The Technical Specifications contained in Appendix A, as revised through Amendment No. 225, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3. This license amendment is effective as of its date of issuance and shall be implemented immediately.

FOR THE NUCLEAR REGULATORY COMMISSION

Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to License No. NPF-68 and the Technical Specifications

Date of Issuance: July 23, 2024

ATTACHMENT TO

VOGTLE ELECTRIC GENERATING PLANT, UNIT 1

LICENSE AMENDMENT NO. 225

TO RENEWED FACILITY OPERATING LICENSE NO. NPF-68

DOCKET NO. 50-424

Replace the following pages of the Renewed Facility Operating License and the Appendix A Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages

License License License No. NPF-68, page 4 License No. NPF-68, page 4

TSs TSs 3.7.9-2 3.7.9-2

(1) Maximum Power Level

Southern Nuclear is authorized to operate the facility at reactor core power levels not in excess of 3625.6 megawatts thermal (100 percent power) in accordance with the conditions specified herein.

(2) Technical Specifications and Environmental Protection Plan

The Technical Specifications contained in Appendix A, as revised through Amendment No. 225, and the Environmental Protection Plan contained in Appendix B, both of which are attached hereto, are hereby incorporated into this license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3) Southern Nuclear Operating Company shall be capable of establishing containment hydrogen monitoring within 90 minutes of initiating safety injection following a loss of coolant accident.

(4) Deleted

(5) Deleted

(6) Deleted

(7) Deleted

(8) Deleted

(9) Deleted

(10) Mitigation Strategy License Condition

The licensee shall develop and maintain strategies for addressing large fires and explosions and that include the following key areas:

(a) Fire fighting response strategy with the following elements:

1. Pre-defined coordinated fire response strategy and guidance

2. Assessment of mutual aid fire fighting assets

3. Designated staging areas for equipment and materials

4. Command and control

5. Training and response personnel

(b) Operations to mitigate fuel damage considering the following:

1. Protection and use of personnel assets

2. Communications

3. Minimizing fire spread

4. Procedures for Implementing integrated fire response strategy

5. Identification of readily-available pre-staged equipment

6. Training on integrated fire response strategy

Renewed Operating License NPF-68 Amendment No. 225 UHS 3.7.9 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME

D. One NSCW basin D.1 Implement an alternate 8 days transfer pump method of basin transfer inoperable. to the affected basin.

AND

D.2 ------------NOTE------------- ------------NOTE----------

LCO 3.0.4.a and b are A one-time only not applicable for initial change of the entry into MODE 4 Completion Time to following 1R25 until 92 days is permitted completion of 1A NSCW for the 1A NSCW transfer pump repair. transfer pump repair during Vogtle Unit 1,

---

Cycle 25. The increased Completion Time is applicable only to the 1A NSCW transfer pump.

Restore the transfer 46 days pump to OPERABLE status.

E. Two NSCW basin E.1 Implement an alternate 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> transfer pumps method of basin transfer inoperable. for one NSCW basin transfer pump.

AND

E.2 Restore one NSCW 8 days basin transfer pump to OPERABLE status.

F. Required Action and F.1 Be in MODE 3. 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> associated Completion Time not met. AND

OR F.2 -------------NOTE------------

UHS inoperable for LCO 3.0.4.a is not reasons other than applicable when entering Conditions A, B, C, D, or MODE 4.

E. ---------------------------------

Be in MODE 4. 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />

Vogtle Units 1 and 2 3.7.9-2 Amendment No. 225 (Unit 1)

Amendment No. 175 (Unit 2)

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION

RELATED TO

VOGTLE ELECTRIC GENERATING PLANT, UNIT 1

AMENDMENT NO. 225 TO RENEWED FA CILITY OPERATING LICENSE NPF-68

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

DOCKET NO. 50-424

1.0 INTRODUCTION

By letter dated July 20, 2024 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML24202A001), Southern Nu clear Operating Company, Inc. (SNC, the licensee), submitted a license amendment request (LAR) to revise the Vogtle Electric Generating Plant (Vogtle), Unit 1, Technical Sp ecification (TS) Limiting Condition for Operation (LCO) 3.7.9, "Ultimate Heat Sink (UHS)." Specifically, the amendment would add a Note to Condition D of TS 3.7.9 to allow one inoperable Nuclear Service Cooling Water (NSCW) transfer pump for up to 92 days for transfer pump motor repair. This TS change would be a one-time change and in effect until September 9, 2024, which is 92 days from the time Condition D was entered for the inoperable 1A NSCW transfer pump. The licensee requested this change because the 1A NSCW transfer pump became inoperable during scheduled quarterly run testing and there were further complications during pump repair and testing. The licensee determined that TS Condition 3.7.9.F, which would require an orderly shutdown of Unit 1, would be entered prior to the expected completion of necessary repairs to the 1A NSCW transfer pump.

The change also includes a Required Action D.2 Note which prevents application of LCO 3.0.4.a and b for entry into MODE 4 following Vogtle Unit 1, Refueling Cycle 25 unless the 1A NSCW transfer pump repairs have been completed.

2.0 REGULATORY EVALUATION

2.1 System Description

Sections 9.2.1 and 9.2.5 of the Vogtle Final Safety Analysis Report (FSAR) provide a description of the Vogtle NSCW system and the Vogtle UHS, respectively. The NSCW system provides cooling water for the containment coolers, control building essential chiller condensers, various engineered safety features (ESF) pump coolers, standby diesel generator jacket water coolers, and the component cooling water (CCW) and auxiliary component cooling water (ACCW) heat exchangers. The UHS for each Vogtle unit consists of two NSCW towers, with one tower associated with each train of the NSCW system. Each NSCW tower includes a large water basin, three NSCW pumps (two 50 percent capacity and one standby), one 600-gallon-per-minute NSCW transfer pump (for the opposite train), and a mechanical-draft cooling tower

Enclosure 3

structure with four fan cells. The two normally operating NSCW pumps in each train provide water from the basin to remove heat from equipment supporting normal operation, reactor cooldown, and accident mitigation. The NSCW system flow returns to the basin via the mechanical draft cooling tower, which transfers heat to the atmosphere. Each tower provides 100 percent of the required heat removal capacity.

The water mass data from FSAR Table 9.2.5-3 and FSAR Table 9.2.5-5 indicates that each cooling tower would provide sufficient cooling for several days after a design basis accident (DBA). Consequently, should a DBA occur requiring the NSCW system and the UHS when a basin transfer pump is inoperable, either tower can perform the safety function of providing cooling water and requires no initial basin transfer capability. FSAR Section 9.2.5.2.3 confirms the use of each tower separately by stating the loss of a transfer pump in one train can be compensated for by operating the other NSCW train or by operating each train separately.

Therefore, if one tower had a failure, the transfer function would not be necessary for several days post-accident, allowing significant time to make the alternate method available.

The Vogtle UHS is operable when the basin level and water temperature are within limits, the required number of fans for the atmospheric conditions and basin water temperature are operable, and the NSCW transfer pumps are operable. The tower basins each contain a safety-related NSCW transfer pump to permit the use of the combined storage capacity of the basins.

Section 1.9.27 of the Vogtle FSAR states that Vogtle conforms to Regulatory Guide (RG) 1.27, Ultimate Heat Sink for Nuclear Power Plants, Revision 2, January 1976 (ML003739969),

which specifies sufficient water inventory to support design-basis post-accident and safe-shutdown heat removal requirements for 30 days without makeup. The combined inventory of both basins is necessary to provide this capability. The 30-day performance reflects operation of both NSCW trains for one day, operation of one NSCW train for the following 29 days, and transfer of water from the non-operating tower basin to the operating tower basin as necessary to maintain adequate cooling water inventory.

2.2 Scope of Amendment

Vogtle TS LCO 3.7.9 requires the UHS to be operable in operating MODES 1, 2, 3, and 4.

Condition D of TS 3.7.9 applies when the UHS is inoperable because one NSCW basin transfer pump is inoperable. If one transfer pump becomes inoperable, making its cooling tower basin inventory unavailable to the other cooling tower, the redundant cooling tower basin would not have sufficient inventory to remain operable for 30 days. The required actions and completion times (CTs) for this condition are to implement an alternative method of basin transfer within 8 days (Required Action D.1) and to restore the transfer pump to operable status within 46 days (Required Action D.2).

As described in the LAR, the licensee removed 1A NSCW Transfer Pump from service for the scheduled quarterly run test on June 9, 2024. After approximately one minute of run time, the pump tripped and TS 3.7.9, Ultimate Heat Sink, Condition D was entered for an inoperable NSCW transfer pump. The licensee investigated the cause on June 9 and June 10, 2024, and an alternate method of basin transfer was implemented to satisfy Required Action D.1 of TS 3.7.9 on June 13, 2024. The pump motor was shipped to an off-site vendor for testing and inspection on June 19, 2024. The motor inspection showed a failure in the windings, which would require a full rewind. On June 20, 2024, the pump was shipped to an offsite vendor for inspection and repairs of damage that was found on the second stage wear ring due to stress corrosion cracking. The licensee reinstalled the repaired 1A NSCW transfer pump, using an equivalent motor on July 17, 2024, but experienced out-of-specification motor current readings.

The licensee identified additional time needed and estimated 1004 hours0.0116 days <br />0.279 hours <br />0.00166 weeks <br />3.82022e-4 months <br /> to repair (rewind) the original 1A NSCW transfer pump motor.

If the time needed to restore the 1A NSCW transfer pump to OPERABLE status is greater than the time allowed to operate the plant while in Condition D, the plant would enter Condition F of TS 3.7.9, which requires an orderly shutdown of the reactor. The licensee determined that the time allowed to operate the plant while in Condition D would be insufficient for repair of the 1A NSCW transfer pump and requested a license amendment to incorporate a proposed note modifying the CT for Condition D of TS 3.7.9.

2.3 Description of Proposed Change

The proposed change would revise TS 3.7.9 for Vogtle, Unit 1 to extend CT for D.2 from 46 days to 92 days for the inoperable 1A NSCW transfer pump. The proposed change also adds a restriction on the use of LCO 3.0.4.a and LCO 3.0.4.b for initial entry into MODE 4 following 1R25 until completion of the 1A NSCW transfer pump repair.

Current TS 3.7.9 Condition D and associated Required Actions and CTs state:

CONDITION REQUIRED ACTION COMPLETION TIME D. One NSCW basin transfer D.1 Implement an alternate 8 days pump inoperable. method of basin transfer to the affected basin.

AND

D.2 Restore the transfer pump to OPERABLE status. 46 days

Revised TS 3.7.9 Condition D and associated Required Actions and CTs would state:

CONDITION REQUIRED ACTION COMPLETION TIME

D. One NSCW basin transfer D.1 Implement an alternate 8 days pump inoperable. method of basin transfer to the affected basin.

AND

D.2 ------------NOTE-----------LCO ---------------NOTE----------------

3.0.4.a and b are not A one-time only change of the applicable for initial entry Completion Time to 92 days is into MODE 4 following permitted for the 1A NSCW 1R25 until completion of transfer pump repair during 1A NSCW transfer pump Vogtle Unit 1, Cycle 25. The repair. ----------------------increased Completion Time is

---

Restore the transfer applicable only to the 1A NSCW pump to OPERABLE transfer pump.

status ----------------------------------------

46 days

These one-time Notes will expire once TS 3.7.9 Condition D is exited or 92 days from June 9, 2024, the date the 1A NSCW transfer pump was declared inoperable. Thus, the 92-day CT expires on September 9, 2024, and would require entry into Action F if not restored to OPERABLE prior to the end of the extended CT.

The licensee described the complex process of removal of the pump and multiple outside vendor evaluations. The NSCW transfer pumps are a column design over 80 feet in length, and each pump column is held in place by 8 pairs of seismic restraint pins spaced along the length of the pump. The licensee stated that the mating loops for the restraint pins were welded in position with the pump in place, establishing a custom fit, which makes removal and replacement of the pump challenging. The licensee provided a repair timeline in Section 2.3 of the LAR, which reflected the complexity of the repair activities and the status as of July 19, 2024. As of that date, the 1A NSCW transfer pump had been removed from the Train B NSCW tower basin. From this timeline, the expected time to restore to OPERABLE status is approximately 46 days from July 19, 2024. The proposed 92-day CT (which began June 9, 2024) for the NSCW basin transfer pump allows additional time as a contingency for unexpected circumstances. The licensee requested the additional 46 days permitted by the note as a contingency for unexpected circumstances that may affect the repair schedule.

2.4 Applicable Regulatory Requirements

Section 182a. of the Atomic Energy Act of 1954, as amended (the Act), requires applicants for nuclear power plant operating licenses to include TSs as part of the license. These TSs are derived from the plant safety analyses.

Title 10 of the Code of Federal Regulations (10 CFR), Section 50.36, Technical specifications, established the NRCs regulatory requirements related to the content of TSs. Pursuant to 10 CFR 50.36, TSs are required to include items in the following five specific categories related to station operation: (1) safety limits, limiting safety system settings, and limiting control settings; (2) limiting conditions for operation (LCOs); (3) surveillance requirements; (4) design features; and (5) administrative controls. The rule does not specify the particular requirements to be included in a plant's TSs.

The regulation in 10 CFR50.36(b) requires:

Each license authorizing operation of a... utilization facility... will include technical specifications. The technical specifications will be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, submitted pursuant to [10 CFR] 50.34 [Contents of applications; technical information]. The Commission may include such additional technical specifications as the Commission finds appropriate.

The regulation in 10 CFR 50.36(c)(2)(i) states, in part, that:

Limiting conditions for operation are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When a limiting condition for operation of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the technical specifications until the condition can be met.

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 in 10 CFR 50.40(a), and those specifically for issuance of operating licenses in 10 CFR 50.57(a)(3) and 50.57(a)(6), provide that there must be reasonable assurance that the activities at issue will not endanger the health and safety of the public and will not be inimical to the common defense and security or to the health and safety of the public.

The Vogtle, Units 1 and 2, TS 1.3, Completion Times, establishes the CT convention and provides guidance for its use. Usage rules for LCOs are in TS Section 3.0, 3.0 LIMITING CONDITION FOR OPERATION (LCO) APPLICABILITY. LCO 3.0.4 contains several allowances for entry into a MODE or other specified condition in the applicability when the LCO is not met.

While the Vogtle TS Sections 1.0 and 3.0 are not regulations, they constitute license requirements imposed on plant operation.

2.5 Applicable Regulatory Guidance

The NRC staffs guidance for the review of TSs is in Chapter 16.0, Technical Specifications, of NUREG-0800, Revision3, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, LWR [Light-Water Reactor] Edition (SRP), March 2010 (ML100351425).

As described therein, as part of the regulatory standardization effort, the NRC staff has prepared Standard Technical Specifications (STS) for each of the LWR nuclear power plant designs. Accordingly, the NRC staffs review includes consideration of whether the proposed changes are consistent with the applicable reference STS (i.e., the current STS), as modified by NRC-approved travelers. The NRC staff used NUREG-1431, Standard Technical Specifications, Westinghouse Plants, Volume 1, Specifications, and Volume2, Bases, Revision5.0, September 2021 (ML21259A155 and ML21259A159, respectively).

Regulatory Position C.1 of RG 1.27 states the following with respect to cooling capacities of less than 30 days:

A cooling capacity of less than 30 days may be acceptable if it can be demonstrated that replenishment or use of an alternate water supply can be effected to assure the continuous capability of the sink to perform its safety functions, taking into account the availability of replenishment equipment and limitations that may be imposed on "freedom of movement" following an accident or the occurrence of severe natural phenomena.

3.0 TECHNICAL EVALUATION

The NRC staff reviewed the amendment reques t by comparing the proposed TS changes against the requirements and guidelines of 10 CFR 50.36, NUREG-0800 Section 16.0, NUREG 1431, RG 1.27 and FSAR Section 9.2.5.

3.1 Safety Evaluation

The proposed change to Vogtle TS 3.7.9 Required Action D.2 adds a Note extending the existing CT to restore an inoperable NSCW transfer pump to operable status when an alternative method of basin inventory transfer is available from 46 days to a total of 92 days,

with 46 days of that time already consumed by the ongoing refurbishment and repair efforts on the 1A NSCW transfer pump and motor. The use of an alternative method of basin inventory transfer is explicitly included in the existing TS as a basis to extend the CT to restore an inoperable NSCW pump to service from 8 days to 46 days. The proposed change adds an additional 46 days to extend the CT for Vogtle TS 3.7.9 Required Action D.2 to a total of 92 days. Since the change is effectively an increase in the time the facility relies on the alternative method of basin inventory transfer, the staff concluded that acceptance should be based on reliability of the alternative method commensurate with the duration of the refurbishment and potential challenges to the operation of the alternative method.

In Section 3.3 of the LAR provided by letter dated July 20, 2024, the licensee described the alternative method of basin inventory transfer. The alternate method utilizes a B-Train NSCW pump, the NSCW crosstie fill connection, and a 6-inch hose staged for routing along the ground to the 1A NSCW tower. To improve readiness, the licensee stated that a flange with a fire hose adapter would be connected to the 6-inch cross pumping flange within the 1B NSCW tower piping and 6-inch hose will be pre-staged. In the case of an event requiring water transfer from the 1B NSCW tower basin to the 1A NSCW tower basin, a 6-inch fire hose would be routed the approximately 330 feet to the 1A tower basin. Flow from the 1B NSCW pumps could be directed to the cross-pumping flange connection by operation of a single butterfly valve, and both the NSCW pumps and the valves are safety-related and seismically qualified.

The licensee indicated the actions that will be performed in support of the alternative source for transfer are governed by procedure and supported by system operating training and initial maintenance training. In addition, the licensee stated that standing orders were issued in the control room to promote awareness and communicate expectations and guidance to all oncoming shift operators.

Based on the above, the NRC staff finds that the remedial actionswhich would allow continued operations of Vogtle, Unit 1 for a period longer than currently allowed by TS 3.7.9 while repairs are being madeprovided the requisite reasonable assurance that the amended steps taken when the LCO is not met will not endanger the health and safety of the public.

The licensee described the following measures that would enhance the reliability and risk of the proposed alternative method of transfer:

The electrical power to the Operable NSCW train is protected per plant procedures for the duration of the extension and work is limited to further ensure the reliability of the opposite train power.

TS 3.7.9, Required Action D.1, require s compensatory measures for alternate basin transfer to be implemented within 8 days. This action was completed on June 13, 2024.

Additional defense-in-depth strategies using FLEX are available should the primary alternate basin transfer compensatory method fail. Methods to makeup the UHS basins during a DBA (from the test well or from the circulating water basin) are discussed in FLEX procedure NMP-OS-019-002-GL03.

Based on the above, the NRC staff finds the proposed alternative method of basin inventory transfer sufficiently reliable to support the extension in the CT to a total of 92 days for Required Action D.2.

In addition, the licensee identified supplemental equipment that could be used to perform the inventory transfer function in the event the proposed alternative method was not available. This equipment included a hydraulically driven submer sible pump and a diesel-hydraulic power skid that, combined with appropriate hoses and fittings, would be able to pump water from one NSCW basin to another. The licensee stated that operational guidance for the use of this supplemental equipment is described in the operational guidance in the NSCW System operating procedure. The NRC staff found this additional capability enhances defense-in-depth and adds to the reliability of the transfer function.

3.2 Technical Specifications Changes

The NRC staff reviewed the proposed TS NOTEs that would change the CT for Required Action D.2 and restrict use of LCO 3.0.4.a and b.

SNC provided an explanation of the need for the proposed emergency amendment in Section 2.3 of the LAR. SNC also provided an explanation of the proposed emergency TS changes in Section 2.4 of the LAR. Regarding the NOTE restricting use of LCO 3.0.4.a and b, SNC stated:

A Note is also added to Required Action D.2 to preclude use of LCO 3.0.4.a and b to return to MODE 4 following 1R25 (which is scheduled to begin on September 9, 2024). Since unlimited operation is allowed in MODE 4 with the pump inoperable, LCO 3.0.4 would allow for a return to operation with the pump inoperable, re-entering Required Action D.2 and allowing for another 46 days for repair. This is not the intended purpose and SNC is adding the Required Action Note to preclude such entry following 1R25 if the repairs have not been completed and the 1A NSCW transfer pump has not been restored to OPERABLE status.

The NRC staff determined that the proposed NOTE above the 46-day CT would restrict the use of the 92-day CT to only the 1A NSCW transfer pump during the remainder of Cycle 25. Given the entry into Condition D on June 9, 2024, the staff determined that the 92-day CT would expire on September 9, 2024. The staff determined that given the current lack of restrictions on use of LCO 3.0.4 for the NSCW transfer pumps, the proposed NOTE would restrict use of LCO 3.0.4 for an inoperable 1A NSCW transfer pump until completion of repairs for this pump.

3.3 Technical Evaluation Conclusion

The NRC staff reviewed the licensees evaluation and found it acceptable because the extended CT and NOTEs are based on the justifications provided by the licensee in the application. That is, the extended CT will only be applicable to support 1A NSCW transfer pump replacement activities and will not be available after Unit 1 exits MODE 4 at the end of operating Cycle 25.

Therefore, the NRC staff determined that the regulatory requirements of 10 CFR 50.36 will continue to be met, because the TSs will continue to be derived from the analyses and evaluation included in the safety analysis report, and amendments thereto, in accordance with 10 CFR 50.36(b), and the TSs will continue to require that the licensee shall shut down the reactor or follow any remedial action permitted by the technical specification until the LCO can be met, in accordance with 10 CFR 50.36(c)(2).

Consistent with NUREG-0800, special attention is given to TS provisions that depart from the reference TS (STS) to determine whether proposed differences from the STS can be justified by

other considerations so that 10 CFR 50.36 is met. The NRC staff further notes that while similar NOTEs do not exist in NUREG-1431, the proposed changes requested in this emergency LAR provide an acceptable CT and MODE entry restriction for the particular situation at Vogtle, as discussed in Section 3.2 above. Given the one-time nature of the condition, the NRC staff finds this departure from the STS is acceptable. Therefore, the NRC staff determined the proposed change to the TS is acceptable.

4.0 EMERGENCY CIRCUMSTANCE

The NRCs regulations in 10 CFR 50.91(a)(5) state that where the NRC finds that an emergency situation exists, in that failure to act in a timely way would result in derating or shutdown of a nuclear power plant, or in prevention of either resumption of operation or of increase in power output up to the plants licensed power level, the NRC may issue a license amendment involving no significant hazards consideration without prior notice and opportunity for a hearing or for public comment. In such a situation, the NRC will publish a notice of issuance under 10 CFR 2.106, providing for opportunity for a hearing and for public comment after issuance.

As discussed in Section 2.3 of SNCs submittal dated July 20, 2024 (ML24202A001), the licensee requested that the proposed amendm ent be reviewed by the NRC on an emergency basis to allow for the removal and repair of the 1A NSCW transfer pump motor with the out-of-specification motor current condition. With the pump motor off-site for these repairs, TS 3.7.9, Condition F, is set to be entered on July 25, 2024, at 1013 EDT. Additional time is needed because of the complexity of the repair, and the expected time to restore to OPERABLE is approximately 46 days from July 19, 2024. The proposed 92-day CT (which began June 9, 2024) for the NSCW basin transfer pump allows additional time as a contingency for unexpected circumstances. However, SNC stated in its submittal that it will strive to return the pump to OPERABLE status in the minimal time achievable.

NRC Staff Conclusion

The NRC staff reviewed the licensees basis fo r processing the proposed amendment as an emergency amendment (as discussed above) and has determined that an emergency situation exists consistent with the provisions in 10 CFR 50.91(a)(5). Furthermore, the NRC staff determined that: (1) the licensee used its best efforts to make a timely application; (2) the licensee could not reasonably have avoided the situation; and (3) the licensee has not abused the provisions of 10 CFR 50.91(a)(5). Based on these findings, and the determination that the amendment involves no significant hazards consideration as discussed below, the NRC staff has determined that a valid need exists for issuance of the license amendment using the emergency provisions of 10 CFR 50.91(a)(5).

5.0 FINAL NO SIGNIFICANT HAZARDS CONSIDERATION

DETERMINATION

The NRCs regulation in 10 CFR 50.92(c) states that the NRC may make a final determination, under the procedures in 10 CFR 50.91, that a license amendment involves no significant hazards consideration if operation of the facility, in accordance with the amendment, would not:

(1) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated; or (3) involve a significant reduction in a margin of safety.

The licensees evaluation of the issue of no significant hazards consideration is presented below:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change does not alter any plant equipment or operating practices in such a manner that the probability of an accident is increased. The proposed changes will not alter assumptions relative to the mitigation of an accident or transient event. Furthermore, the ultimate heat sink (UHS) will remain capable of adequately responding to a design basis event during the period of the extended completion time (CT). Therefore, the proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed change create the possibi lity of a new or different accident from any accident previously evaluated?

Response: No.

The proposed change does not introduce any new or unanalyzed modes of operation. The repair of the pump does not involve any unanalyzed modifications to the design or operational limits of the nuclear service cooling water (NSCW) system.

The redundant pump and compensatory meas ures allowed by the Technical Specifications will remain unaffected. Therefore, no new failure modes or accident precursors are created due to the pump repair during the extended Completion Time.

For the reasons noted above, the proposed change will not create the possibility of a new or different accident previously evaluated.

3. Does the proposed change involve a significant reduction in a margin of safety?

Response: No.

The margin of safety is related to the ability of the fission product barriers to perform their design functions during and following an accident. These barriers include the fuel cladding, the reactor coolant system, and the containment. The performance of these fission product barriers will not be affected by the proposed change; therefore, the margin to the onsite and offsite radiological dose limits are not significantly reduced.

During the extended CT for the 1A NSCW transfer pump, the NSCW system and the UHS will remain capable of mitigating the consequences of a design basis event such as a loss of coolant accident (LOCA). Technical Specifications 3.7.9 Action D.1 will be taken to provide an alternate method of basin transfer.

For the reasons noted above, there is no significant reduction in a margin of safety.

Based on the above evaluation, the NRC staff concludes that the three standards of 10 CFR 50.92(c) are satisfied. Therefore, the NRC staff has made a final determination that no significant hazards consideration is involved for the proposed amendment and that the amendment should be issued as allowed by the criteria contained in 10 CFR 50.91.

6.0 STATE CONSULTATION

In accordance with the Commission's regulations, the State of Georgia officials were notified of the proposed issuance of the amendment on July 20, 2024. The State officials confirmed to the NRC that the State of Georgia has no comments on July 23, 2024.

7.0 ENVIRONMENTAL CONSIDERATION

The NRC staff has determined that the amendment involves no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure.

Accordingly, the amendment meets the eligibility cr iteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendment.

8.0 CONCLUSION

Based on the information provided by the licensee and the analysis in Section 3.0 of this safety evaluation, the NRC staff concludes that while the licensees proposed TS changes are temporarily less restrictive than the licensees current TS requirements, the proposed changes still provide reasonable assurance of safety when judged against current regulatory standards.

The licensees proposed CT extension does not have any impact on the licensees compliance with the regulatory requirements listed in Section 2.0. Therefore, the extension of the CT and restriction on use of LCO 3.0.4.a and b associated with the inoperability of the 1A NSCW transfer pump is acceptable.

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: Gordon Curran Matthew Hamm

Date: July 23, 2024

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