NL-20-0670, Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors: Difference between revisions
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{{#Wiki_filter:Cheryl A. Gayheart | {{#Wiki_filter:Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 cagayhea@southernco.com June 2, 2020 Docket Nos.: 50-321 NL-20-0670 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Ladies and Gentlemen: | ||
By {{letter dated|date=June 7, 2018|text=letter dated June 7, 2018}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18158A583), and as supplemented by letters dated July 16, 2019 and December 18, 2019 (ADAMS Accession Nos. ML19197A097 and ML19352F705), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 to adopt Title 10 of Code of Federal Regulations (CFR) 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors." | By {{letter dated|date=June 7, 2018|text=letter dated June 7, 2018}} (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18158A583), and as supplemented by letters dated July 16, 2019 and December 18, 2019 (ADAMS Accession Nos. ML19197A097 and ML19352F705), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 to adopt Title 10 of Code of Federal Regulations (CFR) 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors." | ||
By email correspondence dated June 1, 2020, the Nuclear Regulatory Commission (NRC) staff requested additional information to complete its review. Enclosure 1 provides the SNC response to the NRC request. Enclosure 2 provides the revised facility operating license (FOL) condition. The conclusions of the No Significant Hazards Consideration and Environmental Consideration contained in the original LAR have been reviewed and are unaffected by this response. | By email correspondence dated June 1, 2020, the Nuclear Regulatory Commission (NRC) staff requested additional information to complete its review. Enclosure 1 provides the SNC response to the NRC request. Enclosure 2 provides the revised facility operating license (FOL) condition. The conclusions of the No Significant Hazards Consideration and Environmental Consideration contained in the original LAR have been reviewed and are unaffected by this response. | ||
This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611. | This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611. | ||
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of June 2020. | I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of June 2020. | ||
Respectfully submitted, C. A. Gayheart Director, Regulatory Affairs Southern Nuclear Operating Company CAG/TLE | Respectfully submitted, C. A. Gayheart Director, Regulatory Affairs Southern Nuclear Operating Company CAG/TLE | ||
U.S. Nuclear Regulatory Commission NL-20-0670 Page 2 | U.S. Nuclear Regulatory Commission NL-20-0670 Page 2 | ||
==Enclosures:== | ==Enclosures:== | ||
: 1. Response to NRC RAI | : 1. Response to NRC RAI | ||
: 2. Proposed FOL Conditions cc: | : 2. Proposed FOL Conditions cc: | ||
Regional Administrator, Region ll NRR Project Manager - Hatch Senior Resident Inspector - Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004 | |||
Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" | Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Response to NRC RAI to NL-20-0670 Response to NRC RAI E1-1 Request for Additional Information The current third proposed license condition states: | ||
Prior to implementation, SNC shall update the PRA models to reflect the as-built, as-operated plant following installation of the required NFPA 805 modifications, implementation items, and the as-built installation details required to meet the risk acceptance guidelines found in RG 1.174, Revision 3, for transition to NFPA 805. If, prior to the issuance of renewed license amendment dated [DATE], the risk estimates from the updated PRA models do not meet the risk acceptance guidelines found in RG 1.174, Revision 3, measures will be taken to reduce the risk. Measures may include approaches such as plant modifications or analytical updates to the PRA model. If any of the measures taken include the use of an upgrade that have not been Peer Reviewed for use in the Hatch PRA models, a focused scope Peer Review will be conducted. | Prior to implementation, SNC shall update the PRA models to reflect the as-built, as-operated plant following installation of the required NFPA 805 modifications, implementation items, and the as-built installation details required to meet the risk acceptance guidelines found in RG 1.174, Revision 3, for transition to NFPA 805. If, prior to the issuance of renewed license amendment dated [DATE], the risk estimates from the updated PRA models do not meet the risk acceptance guidelines found in RG 1.174, Revision 3, measures will be taken to reduce the risk. Measures may include approaches such as plant modifications or analytical updates to the PRA model. If any of the measures taken include the use of an upgrade that have not been Peer Reviewed for use in the Hatch PRA models, a focused scope Peer Review will be conducted. | ||
This license condition leaves much to be determined later and is very unclear as to who has control, who is to do what, what criteria would determine acceptability, and how the NRC staff could take enforcement action. | This license condition leaves much to be determined later and is very unclear as to who has control, who is to do what, what criteria would determine acceptability, and how the NRC staff could take enforcement action. | ||
Please revise the license condition (i.e., such as, Prior to implementation of the Renewed License Amendment dated [DATE], Southern Nuclear Operating Company shall update the Probabilistic Risk Assessment (PRA) models to reflect the as-built, as-operated, and as-maintained plant and shall ensure the risk acceptance guidelines found in Regulatory Guide (RG) 1.174, Revision 3 are met). | Please revise the license condition (i.e., such as, Prior to implementation of the Renewed License Amendment dated [DATE], Southern Nuclear Operating Company shall update the Probabilistic Risk Assessment (PRA) models to reflect the as-built, as-operated, and as-maintained plant and shall ensure the risk acceptance guidelines found in Regulatory Guide (RG) 1.174, Revision 3 are met). | ||
SNC Response SNC agrees with the NRCs proposed license condition revision. See Enclosure 2 for the proposed license condition. The first and second license condition paragraphs remain unchanged. The third license condition paragraph has been revised. | SNC Response SNC agrees with the NRCs proposed license condition revision. See Enclosure 2 for the proposed license condition. The first and second license condition paragraphs remain unchanged. The third license condition paragraph has been revised. | ||
Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" | Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Proposed FOL Conditions to NL-20-0670 Proposed FOL Conditions E2-1 Facility Operating License Condition Insert: | ||
Southern Nuclear Operating Company is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the renewed license amendment dated [DATE]. | Southern Nuclear Operating Company is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the renewed license amendment dated [DATE]. | ||
Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach). | Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach). | ||
Prior to implementation of the Renewed License Amendment dated [DATE], Southern Nuclear Operating Company shall update the Probabilistic Risk Assessment (PRA) models to reflect the as-built, as-operated, and as-maintained plant and shall ensure the risk acceptance guidelines found in Regulatory Guide (RG) 1.174, Revision 3 are met. | Prior to implementation of the Renewed License Amendment dated [DATE], Southern Nuclear Operating Company shall update the Probabilistic Risk Assessment (PRA) models to reflect the as-built, as-operated, and as-maintained plant and shall ensure the risk acceptance guidelines found in Regulatory Guide (RG) 1.174, Revision 3 are met.}} | ||
Latest revision as of 00:16, 11 December 2024
| ML20154K716 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 06/02/2020 |
| From: | Gayheart C Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-20-0670 | |
| Download: ML20154K716 (6) | |
Text
Cheryl A. Gayheart Regulatory Affairs Director 3535 Colonnade Parkway Birmingham, AL 35243 205 992 5316 cagayhea@southernco.com June 2, 2020 Docket Nos.: 50-321 NL-20-0670 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant - Units 1 and 2 Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Ladies and Gentlemen:
By letter dated June 7, 2018 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML18158A583), and as supplemented by letters dated July 16, 2019 and December 18, 2019 (ADAMS Accession Nos. ML19197A097 and ML19352F705), Southern Nuclear Operating Company (SNC) submitted a license amendment request (LAR) for Edwin I. Hatch Nuclear Plant (HNP) Units 1 and 2 to adopt Title 10 of Code of Federal Regulations (CFR) 50.69, "Risk-informed categorization and treatment of structures, systems and components for nuclear power reactors."
By email correspondence dated June 1, 2020, the Nuclear Regulatory Commission (NRC) staff requested additional information to complete its review. Enclosure 1 provides the SNC response to the NRC request. Enclosure 2 provides the revised facility operating license (FOL) condition. The conclusions of the No Significant Hazards Consideration and Environmental Consideration contained in the original LAR have been reviewed and are unaffected by this response.
This letter contains no NRC commitments. If you have any questions, please contact Jamie Coleman at 205.992.6611.
I declare under penalty of perjury that the foregoing is true and correct. Executed on the 2nd day of June 2020.
Respectfully submitted, C. A. Gayheart Director, Regulatory Affairs Southern Nuclear Operating Company CAG/TLE
U.S. Nuclear Regulatory Commission NL-20-0670 Page 2
Enclosures:
- 1. Response to NRC RAI
- 2. Proposed FOL Conditions cc:
Regional Administrator, Region ll NRR Project Manager - Hatch Senior Resident Inspector - Hatch Director, Environmental Protection Division - State of Georgia RType: CHA02.004
Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Response to NRC RAI to NL-20-0670 Response to NRC RAI E1-1 Request for Additional Information The current third proposed license condition states:
Prior to implementation, SNC shall update the PRA models to reflect the as-built, as-operated plant following installation of the required NFPA 805 modifications, implementation items, and the as-built installation details required to meet the risk acceptance guidelines found in RG 1.174, Revision 3, for transition to NFPA 805. If, prior to the issuance of renewed license amendment dated [DATE], the risk estimates from the updated PRA models do not meet the risk acceptance guidelines found in RG 1.174, Revision 3, measures will be taken to reduce the risk. Measures may include approaches such as plant modifications or analytical updates to the PRA model. If any of the measures taken include the use of an upgrade that have not been Peer Reviewed for use in the Hatch PRA models, a focused scope Peer Review will be conducted.
This license condition leaves much to be determined later and is very unclear as to who has control, who is to do what, what criteria would determine acceptability, and how the NRC staff could take enforcement action.
Please revise the license condition (i.e., such as, Prior to implementation of the Renewed License Amendment dated [DATE], Southern Nuclear Operating Company shall update the Probabilistic Risk Assessment (PRA) models to reflect the as-built, as-operated, and as-maintained plant and shall ensure the risk acceptance guidelines found in Regulatory Guide (RG) 1.174, Revision 3 are met).
SNC Response SNC agrees with the NRCs proposed license condition revision. See Enclosure 2 for the proposed license condition. The first and second license condition paragraphs remain unchanged. The third license condition paragraph has been revised.
Response to Request for Additional Information (RAI) Regarding Application to Adopt 10 CFR 50.69, "Risk-Informed Categorization and Treatment of Structures, Systems and Components for Nuclear Power Reactors" Proposed FOL Conditions to NL-20-0670 Proposed FOL Conditions E2-1 Facility Operating License Condition Insert:
Southern Nuclear Operating Company is approved to implement 10 CFR 50.69 using the processes for categorization of Risk-Informed Safety Class (RISC)-1, RISC-2, RISC-3, and RISC-4 structures, systems, and components (SSCs) specified in the renewed license amendment dated [DATE].
Prior NRC approval, under 10 CFR 50.90, is required for a change to the categorization process specified above (e.g., change from a seismic margins approach to a seismic probabilistic risk assessment approach).
Prior to implementation of the Renewed License Amendment dated [DATE], Southern Nuclear Operating Company shall update the Probabilistic Risk Assessment (PRA) models to reflect the as-built, as-operated, and as-maintained plant and shall ensure the risk acceptance guidelines found in Regulatory Guide (RG) 1.174, Revision 3 are met.