ML14070A107

Southern Nuclear Company Vogtle Units 1 and 2- Regulatory Audit in Support of the License Amendment Request to Implement Risk-Informed Technical Specifications Initiative 4B (TAC No. ME9555 and ME9556)

ML14070A107
Person / Time
Site:	Vogtle
Issue date:	03/19/2014
From:	Elliott R B, Hamzehee H G NRC/NRR/DRA/APLA, NRC/NRR/DSS/STSB
To:	Pascarelli R J Plant Licensing Branch II
Evans J, NRR/DRA, 415-4024
References
TAC ME9555, TAC ME9556
Download: ML14070A107 (8)

Text

March 19, 2014 MEMORANDUM TO: Robert J. Pascarelli, Chief Plant Licensing Branch Il-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation FROM: Hossein G. Hamzehee, Chief

/RA/ PRA Licensing Branch Division of Risk Assessment Office of Nuclear Reactor Regulation Robert Elliott, Chief

/RA/ Technical Specifications Branch Division of Safety Systems Office of Nuclear Reactor Regulation

SUBJECT:

SOUTHERN NUCLEAR COMPANY VOGTLE UNITS 1 AND 2- REGULATORY AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT RISK-INFORMED TECHNICAL SPECIFICATIONS INITIATIVE 4B (TAC NO.

ME9555 and ME9556

)

Office of Nuclear Reactor Regulation (NRR) Division of Risk Assessment and Division of Safety Systems staff will be conducting an audit of the Southern Nuclear Company (SNC) Vogtle Units 1 and 2 (Vogtle) license amendment request (LAR) to implement its technical specifications improvement that establishes a risk informed approach for voluntary extension of completion times for Limiting Conditions of Operations (LCO) based off the NEI 06-09 methodology, "Risk-Informed Technical Specification Initiative 4B Risk-Managed Technical Specification Guidelines." This memorandum provides the enclosed regulatory audit plan based on the Vogtle LAR submitted September 13, 2012.

CONTACT: Jonathan Evans, NRR/DRA/APLA 301-415-4024 R. Pascarelli 2 The audit will take place at SNC's offices in Birmingham, AL the week of April 14, 2014. Staff from the Probabilistic Risk Assessment Licensing Branch and the Technical Specifications Branch will perform the audit, with support from an inspector from the Region or Headquarters.

Docket Nos.: 50-424 and 50-425

Enclosure:

As stated

ML14070A107 OFFICE NRR/DRA/APLA NRR/DRA/APLA NRR/DRA/APLA NRR/DSS/STSB NRR/DSS/STSB NRR/DRA/APLA NAME JEvans DGennardo DOneal KBucholtz RElliott HHamzehee DATE 3/13/14 3/13/14 3/13/14 3/13/14 3/14/14 3/19/14 ENCLOSURE SOUTHERN NUCLEAR COMPANY VOGTLE UNITS 1 AND 2 REGULATORY AUDIT IN SUPPORT OF THE LICENSE AMENDMENT REQUEST IN SUPPORT OF THE LICENSE AMENDMENT REQUEST TO IMPLEMENT RISK-INFORMED TECHNICAL SPECIFICATIONS INITIATIVE 4B FLEXIBLE COMPLETION TIMES DOCKET NUMBERS 50-424 AND 50-425 I. BACKGROUND The Southern Nuclear Company Vogtle Units 1 and 2 (Vogtle) has submitted a license amendment request (LAR) (Reference 1) to implement its technical specifications improvement that establishes a risk informed approach for voluntary extension of completion times for Limiting Conditions of Operations (LCO) based off the NEI 06-09 methodology, "Risk-Informed Technical Specification Initiative 4B Risk-Managed Technical Specification Guidelines."

The Nuclear Regulatory Commission (NRC) staff's review of the LAR has commenced in accordance with the Office of Nuclear Reactor Regulation's (NRR) Office Instruction LIC-101, "License Amendment Review Procedures." The NRC staff has determined that a regulatory audit of the Vogtle LAR should be conducted in accordance with LIC-111, "Regulatory Audits,"

for the staff to gain a better understanding of the licensee's proposed risk-informed completion time (RICT) program.

A regulatory audit is a planned, license or regulation-related activity that includes the examination and evaluation of primarily non-doc keted information. A regulatory audit is conducted with the intent to gain understanding, to verify information, and/or to identify information that will require docketing to support the basis of the licensing or regulatory decision. Performing a regulatory audit of licensee information is expected to assist the staff in efficiently conducting its review or gain insights on the licensee's processes or procedures.

Information that the NRC staff relies upon to make the safety determination must be submitted on the docket. However, there may be supporting information retained as records under 10 CFR 50.71 and/or 10 CFR 54.37 that, although not required to be submitted as part of the licensing action, would help the staff better understand the licensee's submitted information.

The objectives of this regulatory audit are to:

• Gain a better understanding of the detailed calculations, analyses and bases underlying the Risk-Informed Technical Specification Initiative 4b LAR and confirm the staff's understanding of the LAR; and,

• Identify further information that is necessary for the licensee to submit for the staff to reach a licensing or regulatory decision; this will result in requests for additional

information (RAIs).

2 II. REGULATORY AUDIT BASIS The basis of this audit is the licensee's LAR (Reference 1), the response to RAIs (Reference 2), and the Standard Review Plan (SRP) Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance,"

(Reference 3). References 4 through 6 provide additional information that will be used to support the audit.

III. REGULATORY AUDIT SCOPE OR METHOD The staff will review the licensee's RICT program and its application to the Technical Specifications (TS) Completion Times as proposed in the LAR. The NRC staff will include in the scope of the audit a review of the Findings and Observations (F&Os) for the Internal Events and Fire Probabilistic Risk Assessment (PRA) models, the RICT program implementation including both technical and programmatic aspects, and will also discuss inspection-related aspects. Documentation, presentations requested, and discussion sessions to gain a better understanding of the program are identified below.

IV. INFORMATION AND OTHER MATERIAL NECESSARY FOR THE AUDIT At a minimum, a hardcopy and electronic copy of the following documentation should be available to the audit team:

• 1762171-R-003, Revision 2, "Vogtle Electric Generating Plant Internal Flooding Probabilistic Risk Assessment," ABS Consulting Report, January 8, 2009.

• Analyses for PRA Success Criteria which differ from Design Basis Criteria.

• Internal Events and Fire Events PRA peer review reports

• Risk Management Action procedure

• The LAR and RAI responses

• Plant and PRA configuration control procedures In addition, the following presentations and/or discussion sessions are requested:

• RICT Program Presentation o Configuration risk Management Program (CRMP) demonstration (including presentation of user interface for evaluations) 3 o Walkthrough sample RICT calculations o Discussion on how External Events are considered for the RICT o Discussion on how Risk Management Actions (RMAs) are determined and implemented o Discuss reviews and acceptance testing of the CRMP model o Discussion on how the CRMP is maintained consistent with the baseline PRA model o Discuss how cumulative risk will be evaluated and tracked

• Discuss LAR and RICT Program.

• Discuss inspection-related aspects of Risk-Informed Technical Specification Initiative 4B V. TEAM ASSIGNMENTS

The audit will be conducted by NRC staff from the Office of Nuclear Reactor Regulation (NRR) Division of Risk Assessment (DRA) and Division of Safety Systems (DSS). Staff knowledgeable in PRA and Technical Specifications will comprise the audit team, with support from an inspector from the Region or Headquarters.

The NRC Audit Team Leader will be Robert Martin and the NRC Technical Lead will be Daniel O'Neal. The team leader will conduct daily briefings on the status of the review and coordinate audit activities while on site. The NRC staff members participating in the audit are noted below:

NRC Staff Organization Robert Martin NRR/DORL Hossein Hamzehee NRR/DRA/APLA Daniel O'Neal NRR/DRA/APLA Jonathan Evans NRR/DRA/APLA David Gennardo NRR/DRA/APLA Kristy Bucholtz NRR/DSS/STSB James Isom NRR/DIRS/IRIB

4 The table below shows the audit milestones and schedule.

Audit Milestones and Schedule Relative to First Audit Day Onsite (04/15

/14 ) Activity Time Frame Comments Onsite Audit Kick-Off Meeting 04/15/14 NRC/Vogtle will conduct a brief introduction and review scope of the audit. Conduct Audit/End of Day Summary Briefing 04/15/2014 - 04/16/2014 Discuss audit questions, hold presentations, and discussion sessions. End of day meeting with licensee to provide a summary of any significant items and requests for additional assistance to support the audit. Onsite Audit Exit Meeting 04/16/2014 NRC will conduct a brief conclusion of the audit. Audit Summary (see VIII) 05/16/2014 To document the audit.

VI. LOGISTICS This regulatory audit is planned for the week of April 14, 2014, and will last approximately two days. These dates are subject to change based on mutual agreement between the licensee and the NRC. An entrance meeting for this audit will be held on the first day at 8:30 AM and an exit meeting will be held at the end of the final audit day to provide preliminary feedback to the licensee.

The audit will take place at a location agr eed upon by the licensee and NRC audit leader where (1) the necessary reference material and (2) appropriate analysts will be available to support the review.

VII. SPECIAL REQUESTS

The regulatory audit team will require the following to support the regulatory audit:

• Private conference room(s) to support document review, discussion sessions, and audit team meetings.

• Access to licensee personnel knowledgeable to the program; including technical specifications; success criteria; Fire PRA and internal events PRA, and PRA functionality.

VIII. DELIVERABLES A regulatory audit summary will be issued within approximately 30 days of the completion of the audit. The summary will use the guidance of NRR Office Instruction LIC-111 for content. Since this audit will likely result in formal RAIs for the licensee regarding the LAR, the summary itself is expected to be an internal memorandum from the audit team leader to the responsible supervisors. The audit summary will be placed in Agencywide Documents and Management System (ADAMS) to document the audit.

5 IX. REFERENCES

1. Letter from Mark J. Ajluni, Southern Nuclear Company Vogtle Units 1 and 2, to U.S. Nuclear Regulatory Commission, "License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, 'Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," September 13, 2012 (ADAMS Accession No. ML12258A055).

2. Letter from Charles R. Pierce, Southern Nuclear Company Vogtle Units 1 and 2, to U.S. Nuclear Regulatory Commission, "Response to Request for Additional Information on Plant Vogtle License Amendment Request to Revise Technical Specifications to Implement NEI 06-09, Revision 0, 'Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines," August 2, 2013 ( ADAMS Accession No. ML13217A072).

3. U.S. NRC, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants, NUREG-0800, Section 19.2, "Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance," (ADAMS Accession No. ML071700658). 4. Regulatory Guide 1.200, Rev. 2, "An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities," March 2009 (ADAMS Accession no. ML090410014). 5. Nuclear Energy Institute, NEI 06-09, "Risk-Informed Technical Specification Initiative 4B Risk-Managed Technical Specification Guidelines," Revision 0, November 2006 (ADAMS Accession no. ML063390639). 6. Nuclear Regulatory Commission, "Final Safe ty Evaluation For Nuclear Energy Institute Topical Report 06-09, 'Risk-Informed Technical Specification Initiative 4B Risk-Managed Technical Specification Guidelines'," Revision 0, May 2007 (ADAMS Accession no.

ML071200238).