ML24292A002

Summary of October 16, 2024, Observation Pre-Submittal Meeting Held with Southern Nuclear Operating Company, Inc., Regarding a Proposed License Amendment Request to Increase Flexibility in Mode Restraints

ML24292A002
Person / Time
Site:	Vogtle
Issue date:	10/22/2024
From:	John Lamb NRC/NRR/DORL/LPL2-1
To:	Southern Nuclear Operating Co
References
EPID L-2024-LRM-0117
Download: ML24292A002 (1)

Text

October 22, 2024 LICENSEE:

Southern Nuclear Operating Company, Inc.

FACILITY:

Vogtle Electric Generating Plant, Units 3 and 4

SUMMARY

OF OCTOBER 16, 2024, OBSERVATION PRE-SUBMITTAL MEETING HELD WITH SOUTHERN NUCLEAR OPERATING COMPANY, INC.,

REGARDING A PROPOSED LICENSE AMENDMENT REQUEST TO INCREASE FLEXIBILITY IN MODE RESTRAINTS FOR VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 (EPID NO. L-2024-LRM-0117)

On October 16, 2024, an Observation meeting was held between the U.S. Nuclear Regulatory Commission (NRC) and representatives of Southern Nuclear Operating Company, Inc. (SNC, the licensee). The purpose of the meeting was for SNC to describe its plan to submit a license amendment request (LAR) for Vogtle Electric Generating Plant (Vogtle), Units 3 and 4.

SNC is proposing a LAR to increase the flexibility in MODE restraints at Vogtle, Units 3 and 4.

Introduction A list of attendees is provided as an Enclosure.

On October 2, 2024 (Agencywide Documents and Access Management System (ADAMS)

Accession No. ML24276A024), the meeting was noticed on the NRC public webpage.

The NRC staff opened the meeting with introductory remarks and a roll call of the attendees.

The SNC representative presented slides contained in ML24283A204.

SNC representatives discussed the following topics: (1) background information, (2) current requirements, (3) proposed changes, (4) technical evaluation, (5) regulatory evaluation, (6) precedent, (7) schedule, and (8) discussion/feedback.

Background Information SNC stated that Technical Specification Task Force (TSTF)-359 Traveler (ML031190607) made changes to the standard technical specifications (STSs) and revised limiting condition for operation (LCO) 3.0.4. LCO 3.0.4 allows entry into a MODE or other specified condition in the Applicability, while relying on the associated ACTIONS, if the provisions of LCO 3.0.4 are met.

TSTF-529 Traveler, Rev. 4 (TSTF-529) proposed changes to clarify and expand the use and application of the STS usage rules, which included minor enhancements to LCO 3.0.4 (ML16060A441).

Current Requirements Vogtle, Units 3 and 4, LCO 3.0.4 states:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not be made except when the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time. This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or are part of a shutdown of the unit.

Exceptions to this Specification are stated in the individual Specifications.

LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.

Vogtle, Units 3 and 4, Surveillance Requirement (SR) 3.0.4 states:

Entry into a MODE or other specified condition in the Applicability of a LCO shall not be made unless the LCOs Surveillances have been met within their specified Frequency. This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.

Proposed Changes SNC proposes the following changes to LCO 3.0.4:

When an LCO is not met, entry into a MODE or other specified condition in the Applicability shall not only be made except when:

a. When the associated ACTIONS to be entered permit continued operation in the MODE or other specified condition in the Applicability for an unlimited period of time;

b. After performance of a risk assessment addressing inoperable systems and components, consideration of the results, determination of the acceptability of entering the MODE or other specified condition in the Applicability, and establishment of risk management actions, if appropriate (exceptions to this Specification are stated in the individual Specifications; or

c. When an allowance is stated in the individual value, parameter, or other Specification.

This Specification shall not prevent changes in MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

Exceptions to this Specification are stated in the individual Specifications.

LCO 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.

SNC proposes the following changes to SR 3.0.4:

Entry into a MODE or other specified condition in the Applicability of an LCO shall not only be made unless when the LCOs Surveillances have been met within their specified Frequency., except as provided by SR 3.0.3. When an LCO is not met due to Surveillances not having been met, entry into a MODE or other specified condition in the Applicability shall only be made in accordance with LCO 3.0.4.

This provision shall not prevent entry into MODES or other specified conditions in the Applicability that are required to comply with ACTIONS or that are part of a shutdown of the unit.

SR 3.0.4 is only applicable for entry into a MODE or other specified condition in the Applicability in MODES 1, 2, 3, and 4.

SNC proposes to make the following additional changes:

Remove the current LCO 3.0.4 exceptions in TSs 3.3.17, 3.3.18, and 3.4.9.

Revise the current LCO 3.0.4 exception in TS 3.4.10 (RCS Activity) from LCO 3.0.4 is not applicable to LCO 3.0.4.c is applicable.

Add a Note to TS 3.4.14, Low Temperature Overpressure Protection (LTOP), to prohibit the application of LCO 3.0.4.b to an inoperable LTOP system.

SNC Technical Evaluation SNC stated that the Vogtle, Units 3 and 4, proposed LAR uses similar arguments as those in the Justification section of TSTF-359.

SNC Regulatory Evaluation SNC stated that the proposed changes provide additional flexibility by allowing use of a risk assessment to determine the acceptability of entering a MODE or other specified condition in the Applicability, and through the establishment of risk management actions, if appropriate. SNC stated that the proposed changes are consistent with the requirements of Title 10 of the Code of Federal Regulations, Section 50.36, Technical specifications.

Precedent SNC stated that the proposed changes to the Vogtle, Units 3 and 4, TS are similar to those in approved for Millstone (ML23058A454). SNC also stated that Farley, Hatch and Vogtle, Units 1 and 2 were granted amendments for TSTF-529 (ML17137A041).

Schedule SNC stated that it plans to submit the proposed LAR in December 2024.

Discussion/Feedback The NRC staff asked if the mark-up on the slides 6 and 7 are identical to TSTF-359 and whether SNC will have variations to TSTF-359.

The NRC staff questioned whether SNC will take exceptions to the Traveler when changing MODES per LCO 3.0.4.b using the Configuration Risk Management Program (CRMP) and shutdown Defense-In-Depth (DID) model used to evaluate the configuration specific risk?

The NRC also asked the following questions:

Does the SNC CRMP follow the NRC endorsed guidance in NUMARC 93-01?

Will SNC perform a qualitative risk analysis of all technical specification structures, systems and components (SSCs) like what each vendor did for TSTF-359 to determine which SSCs should be excluded from the use of LCO 3.0.4.b? Will the results of the evaluation be discussed in the LAR?

SNC noted that the emergency diesel generators are not credited in VEGP 3 and 4 technical specifications. The NRC staff asked how the batteries will be considered in its risk significance determination for VEGP 3 and 4 use of TSTF-359?

Is SNC planning to adopt all of TSTF-529 without exceptions or variations?

Please identify which parts of the proposed LAR are in accordance with TSTF-359 and which pertain explicitly to TSTF-529?

Conclusion There were no members of the public in attendance.

The NRC staff did not make any regulatory decisions during the meeting. Once received, the NRC staff will perform a thorough review of the proposed LAR. The NRC staff will make any regulatory decisions in writing in a timely manner. Public Meeting Feedback forms were available, but no comments were received.

The meeting adjourned at 10:28 am Eastern Time (ET).

Please direct any inquiries to me at John.Lamb@nrc.gov or 301-415-3100.

/RA/

John G. Lamb, Senior Project Manager Plant Licensing Branch, II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos.52-025 and 52-026

Enclosure:

List of Attendee cc w/encls: Distribution via Listserv

Enclosure LIST OF ATTENDEES OCTOBER 16, 2024, PRE-SUBMITTAL MEETING WITH SOUTHERN NUCLEAR COMPANY REGARDING A PROPOSED LICENSE AMENDMENT REQUEST TO INCREASE FLEXIBILITY IN MODE RESTRAINTS VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 ATTENDEE REPRESENTING John G. Lamb U.S. Nuclear Regulatory Commission (NRC)

Summer Sun NRC Jo Ambrosini NRC Ravi Grover NRC Rob Elliott NRC Brian Griman NRC Zach Turner NRC Ken Lowery Southern Nuclear Operating Company (SNC)

Ryan Joyce SNC Jeremiah Gilbreath SNC Michael Coker SNC Justin Wheat SNC Contractor Dan Williamson SNC Eddie Grant SNC

PKG ML24283A204 Meeting Notice ML24276A024 SNC Slides ML24283A202 Meeting Summary ML24292A002 OFFICE DORL/LPL2-1/PM DORL/LPL2-1/LA DSS/STSB/BC DORL/LPL2-1/BC DORL/LPL2-1/PM NAME JLamb KGoldstein ARussell for SMehta MMarkley JLamb DATE 10/16/2024 10/18/2024 10/18/2024 10/22/2024 10/22/2024