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Category:Letter
MONTHYEARML24243A0072024-09-10010 September 2024 – Correction of Amendment Nos. 223 and 206 Regarding Revision to Technical Specifications to Adopt TSTF-339-A, Relocate Technical Specification Parameters to the COLR Consistent with WCAP-14483 ML24102A2642024-09-0909 September 2024 – Exemption Request Regarding Final Safety Analysis Report Update Schedule (EPID L-2024-LLE-0013) - Letter NL-24-0337, Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program2024-09-0909 September 2024 Interim 10 CFR 21.21(a)(2) Report Regarding Operation Technology, Inc., ETAP Software Error in Transient Stability Program ML24249A2942024-09-0606 September 2024 Correction of Amendment Nos. 218 and 201 Regarding Revision to Technical Specifications to Use Online Monitoring Methodology 05200025/LER-2024-002, (Vegp), Unit 3, Manual Reactor Protection System and Automatic Safeguards Actuation Due to an Unexpected Change in Position of a Main Feedwater Pump Minimum Flow Control Valve2024-09-0505 September 2024 (Vegp), Unit 3, Manual Reactor Protection System and Automatic Safeguards Actuation Due to an Unexpected Change in Position of a Main Feedwater Pump Minimum Flow Control Valve IR 05000424/20240052024-08-26026 August 2024 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 1 and 2 - Report 05000424/2024005 and 05000425/2024005 ML24235A1952024-08-22022 August 2024 Updated Inspection Plan for Vogtle Electric Generating Plant, Units 3 and 4 - Report 05200025/2024005 and 05200026/2024005 IR 05000424/20244012024-08-15015 August 2024 4 - Security Baseline Inspection Report 05000424-2024401, 05000425-2024401, 05200025-2024402, and 05200026-2024403 - Cover Letter NL-24-0299, Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information2024-08-14014 August 2024 Exemption Request: Final Safety Analysis Report Update Schedule, Response to Request for Additional Information 05000425/LER-2024-001, (Vegp), Unit 2, Manual Actuation of the Reactor Protection System Due to a Rod Control Fuse Opening Causing a Misaligned Shutdown Rod2024-08-0909 August 2024 (Vegp), Unit 2, Manual Actuation of the Reactor Protection System Due to a Rod Control Fuse Opening Causing a Misaligned Shutdown Rod ML24218A1842024-08-0707 August 2024 Examination Report and Cover Letter 05200026/LER-2024-001, (Vegp), Unit 4, Manual Reactor Protection System Actuation Due to Procedure Not Optimally Sequenced to Reset the Rapid Power Reduction Signal2024-08-0606 August 2024 (Vegp), Unit 4, Manual Reactor Protection System Actuation Due to Procedure Not Optimally Sequenced to Reset the Rapid Power Reduction Signal ML24212A1442024-08-0101 August 2024 Integrated Inspection Report 05200025/2024002 and 05200026/2024002 IR 05000424/20240022024-07-29029 July 2024 Integrated Inspection Report 05000424/2024002 and 05000425/2024002 IR 05000424/20244042024-07-26026 July 2024 Material Control and Accounting Program Inspection Report 05000424/2024404 and 05000425/2024404 (Cover Letter) NL-24-0126, – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.62024-07-25025 July 2024 – Units 3 and 4, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Action a and SR 3.7.6.6 NL-24-0282, License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements2024-07-25025 July 2024 License Amendment Request and Exemption Request: Remove Tier 1 and Tier 2* Requirements ML24204A0722024-07-23023 July 2024 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 NL-24-0286, Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair2024-07-20020 July 2024 Emergency Request to Revise Technical Specification 3.7.9 for a One-Time Change to Support a Unit 1 Nuclear Service Cooling Water Transfer Pump Repair NL-24-0261, 10 CFR 50.46 ECCS Evaluation Model Annual Report for 20232024-07-19019 July 2024 10 CFR 50.46 ECCS Evaluation Model Annual Report for 2023 ML24191A4562024-07-19019 July 2024 Request for Relief and Alternative Requirements for Squib (Explosively Actuated) Valves First Test Interval ML24194A0342024-07-12012 July 2024 Review of the Refueling Outage 1R24 Steam Generator Tube Inspection Report ML24191A3792024-07-10010 July 2024 – Initial Test Program and Operational Programs Inspection Report 05200026/2024011 NL-24-0227, Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1)2024-07-0303 July 2024 Proposed Inservice Inspection Alternative GEN-ISI-AL T-2024-03 for Pressurizer Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0234, Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown2024-06-28028 June 2024 Application to Revise Technical Specifications to Adopt TSTF-589, Eliminate Automatic Diesel Generator Start During Shutdown NL-24-0143, Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in2024-06-27027 June 2024 Proposed Alternative to Use ASME Code Case N-752, Risk-Informed Categorization and Treatment for Repair/ Replacement Activities in NL-24-0087, License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks2024-06-21021 June 2024 License Amendment Request: Changes to Technical Specification 3.7.6, Main Control Room Emergency Habitability System (Ves) Air Storage Tanks NL-24-0201, Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1)2024-06-18018 June 2024 Proposed Inservice Inspection Alternative GEN-ISI-ALT-2024-002 for Steam Generator Welds in Accordance with 10 CFR 50.55a(z)(1) NL-24-0243, Registration of Spent Fuel Cask Use2024-06-18018 June 2024 Registration of Spent Fuel Cask Use ML24163A0632024-06-12012 June 2024 2024 Licensed Operator Re-qualification Inspection Notification Letter Vogtle, Units 3 & 4 ML24155A1772024-06-0505 June 2024 Regulatory Audit in Support of Review of the LAR to Revise Emergency Diesel Generator Frequency and Voltage Ranges for Technical Specification 3.8.1, Surveillance Requirements NL-24-0202, SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations2024-05-24024 May 2024 SNC Response to Regulatory Issue Summary 2024-01: Preparation and Scheduling of Operator Licensing Examinations ML24141A0482024-05-17017 May 2024 EN 56958_1 Ametek Solidstate Controls, Inc ML24094A1402024-05-16016 May 2024 Staff Response to Request for Revision to NRC Staff Assessment of Updated Seismic Hazard Information and Latest Understanding of Seismic Hazards at the Vogtle Plant Site Following the NRC Process for the Ongoing Assessment of Natural Hazard ML24130A2412024-05-13013 May 2024 Integrated Inspection Report 05200025/2024001 and 05200026/2024001 ML24120A1812024-05-13013 May 2024 Request for Withholding Information from Public Disclosure Responses to NRC Request for Additional Information for Refueling Outage IR24 Steam Generator Tube Inspection Report – Enclosure 2 ML24101A2112024-05-11011 May 2024 Expedited Issuance of Amendment No. 198 Change to Technical Specification 5.5.13, Ventilation Filter Testing Program (VFTP) NL-24-0191, Annual Radiological Environmental Operating Reports for 20232024-05-10010 May 2024 Annual Radiological Environmental Operating Reports for 2023 ML24127A2372024-05-0909 May 2024 Initial Test Program and Operational Programs Inspection Report 05200026/2024010 NL-24-0194, Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1)2024-05-0707 May 2024 Revised Request for Relief and Alternative Requirements for Squib Valves First Test Interval (V34-IST-ALT-03-R1) IR 05000424/20244032024-05-0101 May 2024 Cyber Security Inspection Report 05000424/2024403 and 05000425/2024403 Public ML24120A2832024-04-30030 April 2024 Project Manager Reassignment NL-24-0170, Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report2024-04-25025 April 2024 Responses to Second Round NRC Request for Additional Information for Refueling Outage 1 R24 Steam Generator Tube Inspection Report NL-24-0165, Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 20232024-04-25025 April 2024 Annual Non-Radiological Environmental Operating Reports and Annual Radioactive Effluent Release Reports for 2023 IR 05000424/20240012024-04-23023 April 2024 –Integrated Inspection Report 05000424/2024001 and 05000425/2024001 NL-24-0154, Preservice Inspection Progam Owners Activity Report2024-04-16016 April 2024 Preservice Inspection Progam Owners Activity Report ML24030A9092024-04-10010 April 2024 Issuance of Amendment Nos. 224 and 207, Regarding Revision to Technical Specification 3.4.14 (Reactor Coolant System) Pressure Isolation Valve Leakage Surveillance Requirement 3.4.14.1 ML24079A0062024-04-10010 April 2024 – Proposed Alternative to the Requirements of ASME Code of Operation and Maintenance of Nuclear Power Plants for Pressure Isolation Valve Testing Frequency ML24096A1322024-04-0505 April 2024 Individual Notice of Consideration of Issuance of Amendment to Facility Operating License and Opportunity for Hearing and Order (EPID L-2024-LLA-0043) - Letter NL-24-0115, Response to Request for Additional Information Exemption Requests for Physical.2024-04-0404 April 2024 Response to Request for Additional Information Exemption Requests for Physical. 2024-09-09
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Charles R. Pierce Southern Nuclear Regulatory Affairs D1rector Operating Company, Inc. 40 Inverness Center Parkway Post Office Box 1295 B1rmmgham.
AL 35201 Tel 205.992.7872 Fax 205 992.7601 SOUTHERN...\.
COMPANY February 26, 2014 Docket Nos.: 50-425 NL-14-0250 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant -Unit 2 Request for Relaxation of Commission Order Modifying Licenses With Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)
References:
- 1. NRC Order Number EA-12-049, Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events, dated March 12, 2012. ML 12056A045.
- 2. Letter to NRC, Vogtle Electric Generating Plant -Units 1 and 2, Overall Integrated Plan in Response to Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049), dated February 27, 2013. ML 13059A382.
Ladies and Gentlemen:
This letter transmits a request for relaxation of the requirements contained in NRC Order EA-12-049.
On March 12, 2012, the Nuclear Regulatory Commission (NRC) issued an Order (Reference
- 1) to Southern Nuclear Operating Company (SNC). Reference 1 was immediately effective and directs the Vogtle Electric Generating Plant (VEGP) to develop, implement, and maintain guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond-design-basis external event. As described in the Overall Integrated Plan for VEGP (Reference 2), one assumption of the VEGP mitigation strategies is dependent upon installation of low leakage Reactor Coolant Pump (RCP) shutdown seals. SNC planned to install RCP shutdown seals by the Fall 2014 refueling outage (2R17) that would have supported our FLEX strategies for the plant. However, recent post-operational testing of RCP shutdown seals has potentially invalidated that assumption.
U. S. Nuclear Regulatory Commission NL-14-0250 Page 2 An extension of one additional refueling cycle is requested, which would move the implementation date to completion of the Spring 2016 refueling outage.Section IV of NRC Order EA-12-049 (Reference
- 1) states that licensees proposing to deviate from requirements contained in NRC Order EA-12-049 may request that the Director, Office of Nuclear Reactor Regulation, relax those requirements.
Therefore, in accordance with Section IV of NRC Order EA-12-049, SNC is requesting that the Director, Office of Nuclear Reactor Regulation, relax the requirement for completion of full implementation as prescribed in Section IV.A.2 of NRC Order EA-12-049 and as described in the attachment to this letter. SNC considers that, upon approval by the NRC, the alternative full implementation date proposed in the attachment will constitute a relaxation to the NRC Order EA-12-049 for VEGP Unit 2. This letter contains no new NRC commitments.
If you have any questions, please contact John Giddens at 205.992.7924.
Mr. C. R. Pierce states he is the Regulatory Affairs Director for Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and, to the best of his knowledge and belief, the facts set forth in this letter are true. Respectfully submitted,
&_ C. R. Pierce Regulatory Affairs Director CRP/JMG/RCW Swom to and subscribed before me day of My commission expires: /D
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Enclosure:
Vogtle Electric Generating Plant -Unit 2 Request for Relaxation 1 2014.
U.S. Nuclear Regulatory Commission NL-14-0250 Page 3 cc: Southern Nuclear Operating Company Mr. S. E. Kuczynski, Chairman, President
& CEO Mr. D. G. Bost, Executive Vice President
& Chief Nuclear Officer Ms. T. E. Tynan, Vice President-Vogtle Mr. B. L. lvey, Vice President
-Regulatory Affairs Mr. D. R. Madison, Vice President-Fleet Operations RType: CVC7000 U.S. Nuclear Regulatory Commission Mr. E. Leeds, Director of the Office of Nuclear Reactor Regulations Mr. V. M. McCree, Regional Administrator Mr. R. E. Martin, NRR Senior Project Manager-Vogtle Mr. L. M. Cain, Senior Resident Inspector-Vogtle Ms. J. A. Kratchman, NRRIJLD/PMB Mr. E. E. Bowman, NRRIDPRIPGCB Alabama Department of Public Health Mr. J. H. Turner, Environmental Director Protection Division Vogtle Electric Generating Plant -Unit 2 Request for Relaxation of Requirement IV.A.2 of the Commission Order with Regard to Mitigation Strategies for Beyond-Design-Basis External Events (EA-12-049)
Enclosure Vogtle Electric Generating Plant -Unit 2 Request for Relaxation Enclosure to NL-14-0250 Request for Relaxation Vogtle Electric Generating Plant-Unit 2 Request for Relaxation 1 Relaxation Request In accordance with the process specified in Section IV of Nuclear Regulatory Commission (NRC) Order EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events" (Reference 1 ), Southern Nuclear Operating Company(SNC) hereby submits a request for schedule relaxation from the Order requirements for completion of full implementation for Vogtle Electric Generating Plant (VEGP) Unit 2 either no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required in Condition C.l.a of the Order, or December 31, 2016, whichever comes first. 2 Order Requirement from Which Relaxation is Requested NRC Order EA-12-049,Section IV.A.2 requires completion of full implementation of the Order requirements either no later than two (2) refueling cycles after submittal of the Overall Integrated Plan, as required by Condition C.l.a, or December 31, 2016, whichever comes first. In accordance with the requirements of the Order, SNC submitted the Overall Integrated Plan for VEGP (Reference
- 2) on February 27, 2013. The Overall Integrated Plan milestone schedule identified the completion dates for full implementation of NRC Order EA-12-049 for Unit 1 as completion of the Fall 2015 refueling outage, and for Unit 2 as completion of the Fall 2014 refueling outage. NRC Order EA-12-049 requires the development, implementation, and maintenance of guidance and strategies to maintain or restore core cooling, containment, and spent fuel pool cooling capabilities in the event of a beyond design basis external event (BDBEE). As described in the Overall Integrated Plan for VEGP, these mitigation strategies are dependent upon installation of low leakage Reactor Coolant Pump (RCP) shutdown seals. These seals will ensure the safety functions of containment integrity (during an extended loss of alternating current power or ELAP), and core cooling (RCS inventory and level) are maintained for beyond design basis external events (BDBEEs).
3 Justification for Relaxation Request The RCP shutdown seals provide additional safety margin during a BDBEE by serving as a passive means of protecting the reactor. The seals reduce the risk to the plant (Core Damage Frequency) by limiting the loss of reactor coolant system (RCS) water inventory during the event. Due to recent post-operational testing of the RCP shutdown seals at other plants, there is a need to enhance that design. The total implications of the shutdown seal testing results for reactor coolant pumps are currently being assessed.
Resolution of these issues will require additional analytical work. Additionally, procedural development and training will also be necessary.
These factors also affect SNC's ability to safely plan, and implement activities supporting FLEX. Page 1 Enclosure to NL-14-0250 Request for Relaxation Based on this timeline, there is uncertainty that the full implementation of the mitigation strategies in accordance with NRC Order EA-12-049 would be completed by the Order requirement date. The current required implementation date for Unit 2 is at the end of the Fall 2014 refueling outage. An extension of one additional refueling cycle is requested, which would move the implementation date to the end of the Spring 2016 refueling outage. This revised completion date is still within the maximum allowed time frame of December 2016. The extension would provide additional time to resolve industry issues; design, test and qualify the new seals; and, for SNC to safely plan, schedule, and install the new seals at VEGP. Additionally, the new seals will provide added safety margin during a BDBEE. 4 Conclusion As described above, compliance with the current NRC Order EA-12-049 schedule requirement for full completion of implementation of mitigation strategies would result in hardship or unusual difficulty without a compensating increase in the level of safety. Therefore, in accordance with the provisions of Section IV of the Order, SNC requests relaxation of the requirement described in Section IV.A.2, as explained above. 5 References
- 1. NRC Order Number EA-12-049, "Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events," dated March 12,2012. 2. Vogtle Electric Generating Plant-Units 1 and 2 Overall Integrated Plan in Response to March 12, 2012 Commission Order Modifying Licenses with Regard to Requirements for Mitigation Strategies for Beyond-Design-Basis External Events (Order Number EA-12-049)," dated February 27, 2013. Page 2