ML24108A013

NRR E-mail Capture - (External_Sender) Responses from Wednesday 4/10/2024 Call with Southern Nuclear Operating Co. Vogtle 3&4 Licensing Actions

ML24108A013
Person / Time
Site:	Vogtle
Issue date:	04/16/2024
From:	Lowery K Southern Nuclear Operating Co
To:	Markley M NRC/NRR/DORL/LPL2-1
References
Download: ML24108A013 (3)

Text

From: Lowery, Ken G. <KGLOWERY@southernco.com>

Sent: Tuesday, April 16, 2024 5:09 PM To: Michael Markley Cc: John Lamb; Joyce, Ryan M.

Subject:

[External_Sender] Responses from Wednesday 4/10/2024 Call with SNC

Mike

The NRC asked the following questions during the call on Wednesday 4/10/2024. The responses are included below in BOLD.

1. Provide more details on the following Vogtle 3&4 licensing actions:

• Exemption from the Requirements of 10 CFR Part 52, Appendix D, Section X, Departure Report Update Schedule - Departure Report Content Exemption from the Requirements of 10 CFR Part 52, Appendix D, Section X.B.1 - resolves inconsistency in Part 50 and Part 52 reporting with no apparent safety benefit.

• Various TS Actions to Preclude Moving Between Shutdown MODES 5&6 - LAR to make certain MODE 5&6 Applicable LCOs and Actions consistent NUREG Standard Technical Specifications. AP1000 inclusion of many MODE 5&6 Applicable LCOs and Actions are inconsistent with other NUREG STS requirements and pre-dates Commissioner decisions to rely on Utility implementation of NUMARC 91-06, Guidelines for Industry Actions to Assess Shutdown Management, and not address explicitly in TS.

• Revise TS 3.3.15/16 Revision to Separate LCOs for Actuated SSC Surveillances -

This LAR will revise TS 3.3.15 and TS 3.3.16 to add separate LCOs for actuated SSC Surveillances - Separate LCOs will allow for more logical extended RAS to be justified. TS 3.3.15/16 is overly restrictive for two specific inoperabilities (Deterministic LAR):

• TS 3.3.15 & 3.3.16 has extraneous SRs for actual or simulated actuation of certain devices (RCP Breakers, Pressurizer Heater Circuits, CVS Letdown isolation Valves, Auxiliary Spray and Purification Line Isolation Valves, and Main Feedwater and Startup Feedwater Pump Trip Breakers). SR 3.0.1 therefore mandates declaring TS 3.3.15/16 not met when one or more component actuated devices become inoperable (i.e., fail the SR) - leading to excessively restrictive shutdown actions. The correct presentation is to move these SRs (and the OPERABILITY requirement) out of TS 3.3.15/16 and into new or existing TS LCOs - with more appropriate Actions consistent with the safety function approved for those systems

• Some PMS Interlock Logic occurs post-vote (pre-vote is considered part of the TS 3.3.8 channel operability). Post-Vote Interlock inoperability leads to declaring ESF Actuation Logic inop, which leads to the shutdown Actions. The correct action is to allow the affected supported systems actions to dictate (interlocks affect a limited subset of system actuations).

2. Consider separating licensing action for TSTF-554 and TSTF-571 into separate licensing actions - Agreed Ken Lowery, P.E.

Lead Licensing Engineer - Vogtle 3&4 Southern Nuclear - Regulatory Affairs 205-992-6315 (W) or 205-288-0743 (M)

Hearing Identifier: NRR_DRMA Email Number: 2475

Mail Envelope Properties (PH0PR04MB8435EDB70E26EA8ECE278C30A3082)

Subject:

[External_Sender] Responses from Wednesday 4102024 Call with SNC Sent Date: 4/16/2024 5:08:31 PM Received Date: 4/16/2024 5:08:45 PM From: Lowery, Ken G.

Created By: KGLOWERY@southernco.com

Recipients:

"John Lamb" <John.Lamb@nrc.gov>

Tracking Status: None "Joyce, Ryan M." <RMJOYCE@southernco.com>

Tracking Status: None "Michael Markley" <Michael.Markley@nrc.gov>

Tracking Status: None

Post Office: PH0PR04MB8435.namprd04.prod.outlook.com

Files Size Date & Time MESSAGE 2654 4/16/2024 5:08:45 PM

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