Text

Issuance of Amendments Nos. 324 and 269 Regarding Revision to TS to Adopt Risk-Informed Completion Times for Residual Heat Removal Service Water and Plant Service Water Systems
	ML24312A367
Person / Time
Site:	Hatch
Issue date:	12/20/2024
From:	Dawnmathews Kalathiveettil; Plant Licensing Branch II
To:	Coleman J; Southern Nuclear Operating Co
	Kalathiveettil, D
References
	EPID L-2023-LLA-0169
	Download: ML24312A367 (1)
	v • d • e

December 20, 2024 Jamie M. Coleman Regulatory Affairs Director Southern Nuclear Operating Co., Inc.

3535 Colonnade Parkway Birmingham, AL 35243

SUBJECT:

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 - ISSUANCE OF AMENDMENTS NOS. 324 AND 269 REGARDING REVISION TO TECHNICAL SPECIFICATIONS TO ADOPT RISK-INFORMED COMPLETION TIMES FOR RESIDUAL HEAT REMOVAL SERVICE WATER AND PLANT SERVICE WATER SYSTEMS (EPID L-2023-LLA-0169)

Dear Jamie Coleman:

The U.S. Nuclear Regulatory Commission (the Commission) has issued the enclosed Amendment No. 324 to Renewed Facility Operating License (RFOL) No. DPR-57 and Amendment No. 269 to RFOL No. NPF-5 for the Edwin I. Hatch Nuclear Plant (Hatch), Unit Nos. 1 and 2, respectively, in response to your application dated December 6, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23340A223), as supplemented by letter dated May 7, 2024 (ML24128A250).

The amendments revise Hatch, Unit Nos. 1 and 2, Technical Specification (TS) requirements to permit the use of risk-informed completion times, not exceeding 45 days, for the condition of one pump inoperable in TS 3.7.1, Residual Heat Removal Service Water (RHRSW) System, and in TS 3.7.2, Plant Service Water (PSW) System and Ultimate Heat Sink (UHS). The amendments also make corresponding changes to TS 5.5.16, Risk Informed Completion Time Program, and to TS 1.3, Completion Times, Example 1.3-8.

A copy of the related safety evaluation is also enclosed. A Notice of Issuance will be included in the Commissions monthly Federal Register notice. If you have any questions, please contact me at dawnmathews.kalathiveettil@nrc.gov or 301-415-5905.

Sincerely,

/RA/

Dawnmathews T. Kalathiveettil, Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321 and 50-366

Enclosures:

1. Amendment No. 324 to DPR-57

2. Amendment No. 269 to NPF-5

3. Safety Evaluation cc: Listserv

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-321 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 324 Renewed License No. DPR-57

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 1 (the facility) Renewed Facility Operating License No. DPR-57 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated December 6, 2023, as supplemented by letter dated May 7, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;

D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. DPR-57 is hereby amended to read, in part, as follows:

(2)

Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 324, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. DPR-57 and Technical Specifications Date of Issuance: December 20, 2024 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2024.12.20 13:20:23 -05'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 324 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 1 RENEWED FACILITY OPERATING LICENSE NO. DPR-57 DOCKET NO. 50-321 Replace the following pages of the License and the Appendix A, Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License 4

4 TSs TSs 1.3-12 1.3-12 3.7-1 3.7-1 3.7-2 3.7-2 3.7-2a 3.7-3 3.7-3 5.0-19 5.0-19 Renewed License No. DPR-57 Amendment No. 324 for sample analysis or instrument calibration, or associated with radioactive apparatus or components (6)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed license shall be deemed to contain, and is subject to, the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions specified or incorporated below:

(1) Maximum Power Level Southern Nuclear is authorized to operate the facility at steady-state reactor core power levels not in excess of 2,804 megawatts thermal.

(2)

Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 324, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

The Surveillance Requirement (SR) contained in the Technical Specifications and listed below, is not required to be performed immediately upon implementation of Amendment No. 195. The SR listed below shall be successfully demonstrated before the time and condition specified:

SR 3.8.1.18 shall be successfully demonstrated at its next regularly scheduled performance.

(3)

Fire Protection Southern Nuclear Operating Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c), as specified in the licensee amendment request dated April 4, 2018, supplemented by letters dated May 28, August 9, October 7, and December 13, 2019, and February 5, and March 13, 2020, and as approved in the NRC safety evaluation (SE) dated June 11, 2020. Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would require prior NRC approval, the licensee may make changes to the fire protection program without prior approval of the Commission if those changes satisfy the provisions set forth in 10 CFR 50.48(a) and 10 CFR 50.48(c), the change does not require a change to a technical specification or a license condition, and the criteria listed below are satisfied.

Completion Times 1.3 HATCH UNIT 1 1.3-12 Amendment No. 324 1.3 Completion Times EXAMPLES EXAMPLE 1.3-8 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One Subsystem inoperable.

A.1 Restore Subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2.

However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed the time limit specified in the RICT Program. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

(continued)

RHRSW System 3.7.1 HATCH UNIT 1 3.7-1 Amendment No. 324 3.7 PLANT SYSTEMS 3.7.1 Residual Heat Removal Service Water (RHRSW) System LCO 3.7.1 Two RHRSW subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One RHRSW pump inoperable.

A.1 Restore RHRSW pump to OPERABLE status.

30 days OR In accordance with the Risk Informed Completion Time Program B.

One RHRSW pump in each subsystem inoperable.

B.1 Restore one RHRSW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program (continued)

RHRSW System 3.7.1 HATCH UNIT 1 3.7-2 Amendment No. 324 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One RHRSW subsystem inoperable for reasons other than Condition A.

NOTE-----------------

Enter applicable Conditions and Required Actions of LCO 3.4.7, Residual Heat Removal (RHR)

Shutdown Cooling System - Hot Shutdown, for RHR shutdown cooling made inoperable by RHRSW System.

C.1 Restore RHRSW subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program D.

Required Action and associated Completion Time of Condition A, B, or C not met.

D.1

NOTE---------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E.

Both RHRSW subsystems inoperable for reasons other than Condition B.

NOTE------------------

Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.

E.1 Restore one RHRSW subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (continued)

RHRSW System 3.7.1 HATCH UNIT 1 3.7-2a Amendment No. 324 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time of Condition E not met.

F.1 Be in MODE 3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

In accordance with the Surveillance Frequency Control Program

PSW System and UHS 3.7.2 HATCH UNIT 1 3.7-3 Amendment No. 324 3.7 PLANT SYSTEMS 3.7.2 Plant Service Water (PSW) System and Ultimate Heat Sink (UHS)

LCO 3.7.2 Two PSW subsystems and UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One PSW pump inoperable.

A.1 Restore PSW pump to OPERABLE status.

30 days OR In accordance with the Risk Informed Completion Time Program B.

One PSW turbine building isolation valve inoperable.

B.1 Restore PSW turbine building isolation valve to OPERABLE status.

30 days C.

One PSW pump in each subsystem inoperable.

C.1 Restore one PSW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program D.

One PSW turbine building isolation valve in each subsystem inoperable.

D.1 Restore one PSW turbine building isolation valve to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program (continued)

Programs and Manuals 5.5 HATCH UNIT 1 5.0-19 Amendment No. 324 5.5 Programs and Manuals 5.5.15 Battery Monitoring and Maintenance Program (continued)

4.

In Regulatory Guide 1.129, Regulatory Position 3, Subsection 5.4.1, State of Charge Indicator, the following statements in paragraph (d) may be omitted: When it has been recorded that the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. These measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage.

5.

In lieu of RG 1.129, Regulatory Position 7, Subsection 7.6, Restoration, the following may be used: Following the test, record the float voltage of each cell of the string.

b.

The program shall include the following provisions:

1.

Actions to restore battery cells with float voltage < 2.13 V;

2.

Actions to determine whether the float voltage of the remaining battery cells is 2.13 V when the float voltage of a battery cell has been found to be < 2.13 V;

3.

Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates;

4.

Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and

5.

A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

5.5.16 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, Risk-Managed Technical Specifications (RMTS) Guidelines, with exceptions as noted below. The program shall include the following:

a.

The RICT may not exceed 30 days except:

1. The RICT may not exceed 45 days for TS 3.7.1, RHRSW System, Required Action A.1; and

2. The RICT may not exceed 45 days for TS 3.7.2, PSW System and UHS, Required Action A.1.

b.

A RICT may only be utilized in MODE 1; (continued)

SOUTHERN NUCLEAR OPERATING COMPANY, INC.

GEORGIA POWER COMPANY OGLETHORPE POWER CORPORATION MUNICIPAL ELECTRIC AUTHORITY OF GEORGIA CITY OF DALTON, GEORGIA DOCKET NO. 50-366 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 2 AMENDMENT TO RENEWED FACILITY OPERATING LICENSE Amendment No. 269 Renewed License No. NPF-5

1.

The Nuclear Regulatory Commission (the Commission) has found that:

A.

The application for amendment to the Edwin I. Hatch Nuclear Plant, Unit No. 2 (the facility) Renewed Facility Operating License No. NPF-5 filed by Southern Nuclear Operating Company, Inc. (the licensee), acting for itself, Georgia Power Company, Oglethorpe Power Corporation, Municipal Electric Authority of Georgia, and City of Dalton, Georgia (the owners), dated December 6, 2023, as supplemented by letter dated May 7, 2024, complies with the standards and requirements of the Atomic Energy Act of 1954, as amended (the Act), and the Commissions rules and regulations set forth in 10 CFR Chapter I; B.

The facility will operate in conformity with the application, the provisions of the Act, and the rules and regulations of the Commission; C.

There is reasonable assurance (i) that the activities authorized by this amendment can be conducted without endangering the health and safety of the public, and (ii) that such activities will be conducted in compliance with the Commissions regulations;

D.

The issuance of this amendment will not be inimical to the common defense and security or to the health and safety of the public; and E.

The issuance of this amendment is in accordance with 10 CFR Part 51 of the Commissions regulations and all applicable requirements have been satisfied.

2.

Accordingly, the license is hereby amended by page changes to the Technical Specifications as indicated in the attachment to this license amendment, and paragraph 2.C.(2) of Renewed Facility Operating License No. NPF-5 is hereby amended to read, in part, as follows:

(2)

Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B), as revised through Amendment No. 269, are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

3.

This license amendment is effective as of its date of issuance and shall be implemented within 90 days from the date of issuance.

FOR THE NUCLEAR REGULATORY COMMISSION Michael T. Markley, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation

Attachment:

Changes to Renewed Facility Operating License No. NPF-5 and Technical Specifications Date of Issuance: December 20, 2024 MICHAEL MARKLEY Digitally signed by MICHAEL MARKLEY Date: 2024.12.20 13:23:15 -05'00'

ATTACHMENT TO LICENSE AMENDMENT NO. 269 EDWIN I. HATCH NUCLEAR PLANT, UNIT NO. 2 RENEWED FACILITY OPERATING LICENSE NO. NPF-5 DOCKET NO. 50-366 Replace the following pages of the License and the Appendix A, Technical Specifications (TSs) with the attached revised pages. The revised pages are identified by amendment number and contain marginal lines indicating the areas of change.

Remove Pages Insert Pages License License 4

4 TSs TSs 1.3-12 1.3-12 3.7-1 3.7-1 3.7-2 3.7-2 3.7-2a 3.7-3 3.7-3 5.0-19 5.0-19

Renewed License No. NPF-5 Amendment No. 269 (6)

Southern Nuclear, pursuant to the Act and 10 CFR Parts 30 and 70, to possess, but not separate, such byproduct and special nuclear materials as may be produced by the operation of the facility.

C.

This renewed license shall be deemed to contain, and is subject to, the conditions specified in the following Commission regulations in 10 CFR Chapter I: Part 20, Section 30.34 of Part 30, Section 40.41 of Part 40, Section 50.54 of Part 50, and Section 70.32 of Part 70; all applicable provisions of the Act and the rules, regulations, and orders of the Commission now or hereafter in effect; and the additional conditions2 specified or incorporated below:

(1)

Maximum Power Level Southern Nuclear is authorized to operate the facility at steady sate reactor core power levels not in excess of 2,804 megawatts thermal, in accordance with the conditions specified herein.

(2)

Technical Specifications The Technical Specifications (Appendix A) and the Environmental Protection Plan (Appendix B); as revised through Amendment No. 269 are hereby incorporated in the renewed license. Southern Nuclear shall operate the facility in accordance with the Technical Specifications and the Environmental Protection Plan.

(3)

Additional Conditions The matters specified in the following conditions shall be completed to the satisfaction of the Commission within the stated time periods following the issuance of the renewed license or within the operational restrictions indicated. The removal of these conditions shall be made by an amendment to the license supported by a favorable evaluation by the Commission.

(a)

Fire Protection Southern Nuclear Operating Company shall implement and maintain in effect all provisions of the approved fire protection program that comply with 10 CFR 50.48(a) and 10 CFR 50.48(c),

as specified in the licensee amendment request dated April 4, 2018, supplemented by letters dated May 28, August 9, October 7, and December 13, 2019, and February 5, and March 13, 2020, and as approved in the NRC safety evaluation (SE) dated June 11, 2020.

Except where NRC approval for changes or deviations is required by 10 CFR 50.48(c), and provided no other regulation, technical specification, license condition or requirement would 2

The original licensee authorized to possess, use, and operate the facility with Georgia Power Company (GPC). Consequently, certain historical references to GPC remain in certain license conditions.

Completion Times 1.3 HATCH UNIT 2 1.3-12 Amendment No. 269 1.3 Completion Times EXAMPLES EXAMPLE 1.3-8 (continued)

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A. One subsystem inoperable.

A.1 Restore subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program B. Required Action and associated Completion Time not met.

B.1 Be in MODE 3.

AND B.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours When a subsystem is declared inoperable, Condition A is entered. The 7 day Completion Time may be applied as discussed in Example 1.3-2.

However, the licensee may elect to apply the Risk Informed Completion Time Program which permits calculation of a Risk Informed Completion Time (RICT) that may be used to complete the Required Action beyond the 7 day Completion Time. The RICT cannot exceed the time limit specified in the RICT Program. After the 7 day Completion Time has expired, the subsystem must be restored to OPERABLE status within the RICT or Condition B must also be entered.

The Risk Informed Completion Time Program requires recalculation of the RICT to reflect changing plant conditions. For planned changes, the revised RICT must be determined prior to implementation of the change in configuration. For emergent conditions, the revised RICT must be determined within the time limits of the Required Action Completion Time (i.e., not the RICT) or 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months after the plant configuration change, whichever is less.

(continued)

RHRSW System 3.7.1 HATCH UNIT 2 3.7-1 Amendment No. 269 3.7 PLANT SYSTEMS 3.7.1 Residual Heat Removal Service Water (RHRSW) System LCO 3.7.1 Two RHRSW subsystems shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One RHRSW pump inoperable.

A.1 Restore RHRSW pump to OPERABLE status.

30 days OR In accordance with the Risk Informed Completion Time Program B.

One RHRSW pump in each subsystem inoperable.

B.1 Restore one RHRSW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program (continued)

RHRSW System 3.7.1 HATCH UNIT 2 3.7-2 Amendment No. 269 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME C.

One RHRSW subsystem inoperable for reasons other than Condition A.

NOTE-----------------

Enter applicable Conditions and Required Actions of LCO 3.4.7, "Residual Heat Removal (RHR)

Shutdown Cooling System - Hot Shutdown," for RHR shutdown cooling made inoperable by RHRSW System.

C.1 Restore RHRSW subsystem to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program D.

Required Action and associated Completion Time of Condition A, B, or C not met.

D.1

NOTE---------

LCO 3.0.4.a is not applicable when entering MODE 3.

Be in MODE 3.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months E.

Both RHRSW subsystems inoperable for reasons other than Condition B.

NOTE------------------

Enter applicable Conditions and Required Actions of LCO 3.4.7 for RHR shutdown cooling made inoperable by RHRSW System.

E.1 Restore one RHRSW subsystem to OPERABLE status.

8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months (continued)

RHRSW System 3.7.1 HATCH UNIT 2 3.7-2a Amendment No. 269 ACTIONS (continued)

CONDITION REQUIRED ACTION COMPLETION TIME F.

Required Action and associated Completion Time of Condition E not met.

F.1 Be in MODE 3.

AND F.2 Be in MODE 4.

12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months 36 hours SURVEILLANCE REQUIREMENTS SURVEILLANCE FREQUENCY SR 3.7.1.1 Verify each RHRSW manual, power operated, and automatic valve in the flow path, that is not locked, sealed, or otherwise secured in position, is in the correct position or can be aligned to the correct position.

In accordance with the Surveillance Frequency Control Program

PSW System and UHS 3.7.2 HATCH UNIT 2 3.7-3 Amendment No. 269 3.7 PLANT SYSTEMS 3.7.2 Plant Service Water (PSW) System and Ultimate Heat Sink (UHS)

LCO 3.7.2 Two PSW subsystems and UHS shall be OPERABLE.

APPLICABILITY:

MODES 1, 2, and 3.

ACTIONS CONDITION REQUIRED ACTION COMPLETION TIME A.

One PSW pump inoperable.

A.1 Restore PSW pump to OPERABLE status.

30 days OR In accordance with the Risk Informed Completion Time Program B.

One PSW turbine building isolation valve inoperable.

B.1 Restore PSW turbine building isolation valve to OPERABLE status.

30 days C.

One PSW pump in each subsystem inoperable.

C.1 Restore one PSW pump to OPERABLE status.

7 days OR In accordance with the Risk Informed Completion Time Program D.

One PSW turbine building isolation valve in each subsystem inoperable.

D.1 Restore one PSW turbine building isolation valve to OPERABLE status.

72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months OR In accordance with the Risk Informed Completion Time Program (continued)

Programs and Manuals 5.5 HATCH UNIT 2 5.0-19 Amendment No. 269 5.5 Programs and Manuals 5.5.15 Battery Monitoring and Maintenance Program (continued)

4.

In Regulatory Guide 1.129, Regulatory Position 3, Subsection 5.4.1, State of Charge Indicator, the following statements in paragraph (d) may be omitted: When it has been recorded that the charging current has stabilized at the charging voltage for three consecutive hourly measurements, the battery is near full charge. These measurements shall be made after the initially high charging current decreases sharply and the battery voltage rises to approach the charger output voltage.

5.

In lieu of RG 1.129, Regulatory Position 7, Subsection 7.6, Restoration, the following may be used: Following the test, record the float voltage of each cell of the string.

b.

The program shall include the following provisions:

1.

Actions to restore battery cells with float voltage < 2.13 V;

2.

Actions to determine whether the float voltage of the remaining battery cells is 2.13 V when the float voltage of a battery cell has been found to be < 2.13 V;

3.

Actions to equalize and test battery cells that had been discovered with electrolyte level below the top of the plates;

4.

Limits on average electrolyte temperature, battery connection resistance, and battery terminal voltage; and

5.

A requirement to obtain specific gravity readings of all cells at each discharge test, consistent with manufacturer recommendations.

5.5.16 Risk Informed Completion Time Program This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, Risk-Managed Technical Specifications (RMTS) Guidelines, with exceptions as noted below. The program shall include the following:

a.

The RICT may not exceed 30 days except:

1.

The RICT may not exceed 45 days for TS 3.7.1, RHRSW System, Required Action A.1; and

2.

The RICT may not exceed 45 days for TS 3.7.2, PSW System and UHS, Required Action A.1.

b.

A RICT may only be utilized in MODE 1; (continued)

SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 324 TO RENEWED FACILITY OPERATING LICENSE NO. DPR-57 AND AMENDMENT NO. 269 TO RENEWED FACILITY OPERATING LICENSE NO. NPF-5 SOUTHERN NUCLEAR OPERATING COMPANY, INC.

EDWIN I. HATCH NUCLEAR PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-321 AND 50-366

1.0 INTRODUCTION

By application dated December 6, 2023 (Agencywide Documents Access and Management System (ADAMS) Accession No. ML23340A223), as supplemented by letter dated May 7, 2024 (ML24128A250), Southern Nuclear Operating Company, Inc. (SNC, the licensee) submitted a license amendment request (LAR) to the U.S. Nuclear Regulatory Commission (NRC, the Commission) for Edwin I. Hatch Nuclear Plant (Hatch), Unit Nos. 1 and 2. The amendments would revise Hatch, Unit Nos. 1 and 2, Technical Specification (TS) requirements to permit the use of risk-informed completion times (RICTs), not exceeding 45 days, for the condition of one pump inoperable in TS 3.7.1, Residual Heat Removal Service Water (RHRSW) System, and in TS 3.7.2, Plant Service Water (PSW) System and Ultimate Heat Sink (UHS). The amendments would also make corresponding changes to TS 5.5.16, Risk Informed Completion Time Program, and to TS 1.3, Completion Times, Example 1.3-8. In Amendment Nos. 319 and 264 for Hatch, Unit Nos. 1 and 2 (ML22297A146 and ML23018A004), respectively, the NRC approved adoption of Technical Specifications Task Force (TSTF) Traveler TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF [Risk Informed Technical Specifications Task Force] Initiative 4b, dated July 2, 2018 (ML18183A493).

The NRC staff issued a request for additional information (RAI), dated April 9, 2024 (ML24100A440). The licensees RAI response, dated May 7, 2024, provided additional information that clarified the application, did not expand the scope of the application as originally noticed, and did not change the staffs original proposed no significant hazards consideration determination as published in the Federal Register on February 20, 2024 (89 FR 12876).

2.0 REGULATORY EVALUATION

2.1 Background

2.1.1 Description of Risk-Informed Completion Time Program The regulations in Title 10 of the Code of Federal Regulations (10 CFR) 50.36(c)(2)(i), state, in part, that TS limiting conditions for operation (LCOs) are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. Specified with each stated remedial action (ACTIONS) are Condition(s), Required Action(s), Completion Time(s) (CT), and associated Note(s). The CTs are referred to as the front stops in the context of this safety evaluation (SE). For certain Conditions, the TSs require exiting the Mode of Applicability of an LCO (e.g., shutting down the reactor).

As noted above, the NRC approved the licensees proposed RICT program for Hatch, Unit Nos.

1 and 2, consistent with TSTF-505, Revision 2, including a new TS 5.5.16, Risk Informed Completion Program, that provides controls and implementation requirements as specified in Nuclear Energy Institute (NEI) Topical Report (TR) NEI 06-09, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines, Revision 0-A (ML12286A322) (hereafter referred to as NEI 06-09-A), which was approved by the NRC on May 17, 2007 (ML071200238);, provides a methodology to extend CTs and thereby delay exiting the Mode of Applicability or taking Required Actions if risk is assessed and managed within the limits and programmatic requirements.

2.1.2 Description of Residual Heat Removal Service Water System The RHRSW System is described in the Hatch, Unit No. 1, Final Safety Analysis Report (FSAR) at Section 10.6 and in the Hatch, Unit No. 2, FSAR at Section 9.2.7. The RHRSW System is designed to provide cooling water to the Residual Heat Removal (RHR) system during normal shutdown and under post-accident conditions. In addition, it provides primary containment cooling through suppression pool cooling. In Enclosure 1, Section 2.1, of the LAR, the licensee states that the RHRSW System consists of two independent subsystems, each of which includes a suction source, two 4000 gallons per minute (gpm) pumps, header, valves, piping, and heat exchanger. The licensee also states that the safety analyses results show that one subsystem with two pumps operating at 3750 gpm each (or one pump in each subsystem cross-tied to an available heat exchanger) and up to five percent of tubes plugged in the RHR heat exchanger maintains the suppression pool temperature and the primary containment pressure below the design limits.

2.1.3 Description of Plant Service Water System The PSW System is described in the Hatch, Unit No. 1, FSAR at Section 10.7 and in the Hatch, Unit No. 2, FSAR at Section 9.2.1. The PSW System is designed to provide screened cooling water to the plant during normal operating and shutdown conditions, makeup water to the circulating water system during normal operations, and cooling water to equipment required for accident conditions. In the FSAR, the licensee states that three PSW pumps are required for normal operation. In Enclosure 1, Section 2.1, of the LAR, the licensee states that the PSW System consists of two independent subsystems, each of which includes a suction source, two 8500 gpm pumps, header, valves, piping, and heat exchanger. The licensee also states that the

safety analyses results show that either subsystem, with flow from only one pump, provides adequate cooling for the emergency conditions.

2.2 Description of Proposed TS Changes The licensee proposed the following changes to the TSs for Hatch, Unit Nos. 1 and 2, as described in Section 2.3 of Attachment 1 to the LAR:

1. TS 3.7.1, Condition A, One RHRSW pump inoperable, Required Action A.1 currently requires, Restore RHRSW pump to OPERABLE status, within a CT of 30 days. The proposed revision of the CT is 30 days OR In accordance with the Risk Informed Completion Time Program.

2. TS 3.7.2, Condition A, One PSW pump inoperable, Required Action A.1 currently requires, Restore PSW pump to OPERABLE status, within a CT of 30 days. The proposed revision of the CT is 30 days OR In accordance with the Risk Informed Completion Time Program.

3. TS 5.5.16 currently states, in part, that the program is required to be implemented in accordance with NEI 06-09-A. The proposed change to the requirement is to add with exceptions as noted below so that the revised sentence reads: This program provides controls to calculate a Risk Informed Completion Time (RICT) and must be implemented in accordance with NEI 06-09-A, Revision 0, Risk-Managed Technical Specifications (RMTS) Guidelines, with exceptions as noted below.

The exceptions would be applied to TS 5.5.16.a, which currently states that The RICT may not exceed 30 days. The paragraph, with the proposed exceptions, would state:

a. The RICT may not exceed 30 days except:

1. The RICT may not exceed 45 days for TS 3.7.1, RHRSW System, Required Action A.1; and

2. The RICT may not exceed 45 days for TS 3.7.2, PSW System and UHS, Required Action A.1.

4. In Example 1.3-8 of TS 1.3, the licensee proposed to remove the reference to the current 30-day RICT limit. This section of the TSs provides the convention for how CTs are to be used, specifically for the RICTs in several LCO required actions. Example 1.3-8 currently states, in part, The RICT cannot exceed 30 days. The revised sentence would read: The RICT cannot exceed the time limit specified in the RICT Program.

2.3 Reason for Proposed TS Changes In Section 2.2, Reason for Change, of Enclosure 1 of the LAR, the licensee explains that pump replacement typically takes seven to ten calendar days, working 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months per day as conditions permit, but that the location of the facility can be prone to severe weather which can limit the time that maintenance can be performed at the river water intake structure. The licensee also states that the time of year can impact the daylight hours available to perform maintenance.

In its submittal, the licensee identified potential issues that may arise while replacing an RHRSW or PSW pump and/or motor including:

During pump replacement, the pump fails preservice testing requiring additional troubleshooting and possibly a second replacement pump; Divers may be required for inspection, searching for foreign material, etc.;

Challenges in aligning components within specified tolerances (e.g., due to very tight tolerances on the pump seismic restraints and bearings, difficulties aligning discharge head with check valve flange);

Unexpected motor problems during post-maintenance testing; and Requiring off-site refurbishment by a specialty vendor.

In its LAR, the licensee stated that there are challenges associated with the configuration of the motor, pump, discharge head, and check valve, as well as the space available for the load path.

The pump motor must be removed to facilitate removal of the discharge head and check valve.

Further, the motor cannot be reinstalled until the pump, discharge head, and discharge check valve are installed to within specified tolerances.

In its submittal, the licensee noted that SNC has submitted three emergency LARs since 2019 because of unforeseen maintenance issues encountered during RHRSW and PSW pump and motor maintenance activities including:

Emergency LAR in November 2019 (ML19333B967) associated with the replacement of Unit No. 1 RHRSW Pump B. The LAR was withdrawn (ML19336B596) after the pump was restored to operable status less than 3 days prior to the original 30-day CT.

Emergency LAR in September 2021 (ML21264A003) associated with the replacement of Unit No. 1 PSW Pump C. The approved amendment (ML21264A644) allowed, with compensatory measures established, a one-time extension of the TS 3.7.2 Required Action A.1 CT from 30 days to 45 days.

Emergency LAR in April 2022 (ML22120A087) associated with the replacement of Unit No. 1 PSW Pump A. The LAR was withdrawn (ML22123A159) after the pump was restored to operable status less than 48 hours5.555556e-4 days 0.0133 hours 7.936508e-5 weeks 1.8264e-5 months prior to the original 30-day CT.

2.4 Regulatory Review 2.4.1 Applicable Regulations The regulations in 10 CFR 50.90 state that whenever a holder of an operating license desires to amend the license, an application for amendment must be filed with the Commission fully describing the changes desired. The regulations at 10 CFR 50.92(a) state that, in determining whether an amendment to a license will be issued, the Commission will be guided by the considerations that govern the issuance of initial licenses to the extent applicable and appropriate. The regulations in 10 CFR 50.40(a) state, in part, that, TSs provide reasonable assurance that the applicant will comply with the regulations and that health and safety of the public will not be endangered. Also, to issue an operating license, of which TSs are a part, the Commission must make the findings of 10 CFR 50.57, Issuance of operating license, including the 10 CFR 50.57(a)(3)(i) finding that there is reasonable assurance that the activities authorized by the operating license can be conducted without endangering the health and safety of the public.

The regulations at 10 CFR 50.36(c)(2) require that TSs contain LCOs, which are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the LCO can be met. Typically, the TSs require restoration of equipment in a timeframe commensurate with its safety significance, along with other engineering considerations. The regulations at 10 CFR 50.36(c)(5) state, in part, that administrative controls are the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner.

2.4.2 Applicable Regulatory Guidance Following NRC guidance provides one way for licensees to demonstrate compliance with the NRCs regulations. The NRC staff considered the following guidance, along with industry guidance endorsed by the NRC, during its review of the proposed changes:

Regulatory Guide (RG) 1.200, Revision 2, An Approach for Determining the Technical Adequacy of Probabilistic Risk Assessment Results for Risk-Informed Activities (ML090410014), March 2009; RG 1.174, Revision 3, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Licensing Basis (ML17317A256), January 2018; RG 1.177, Revision 2, Plant-Specific, Risk-Informed Decisionmaking: Technical Specifications (ML20164A034), January 2021; NUREG-1855, Revision 1, Guidance on the Treatment of Uncertainties Associated with PRAs [Probabilistic Risk Assessments] in Risk-Informed Decisionmaking (ML17062A466), March 2017; NUREG-0800, Standard Review Plan for the Review of Safety Analysis Reports for Nuclear Power Plants: LWR [Light-Water Reactor] Edition (SRP), Section 19.2, Review of Risk Information Used to Support Permanent Plant-Specific Changes to the Licensing Basis: General Guidance (ML071700658), June 2007, and Section 16.1, Revision 1, Risk-Informed Decision Making: Technical Specifications (ML070380228), March 2007; Topical Report NEI 06-09-A, Risk-Informed Technical Specifications Initiative 4b, Risk-Managed Technical Specifications (RMTS) Guidelines (ML12286A322), which incorporates the NRC staff SE, dated May 17, 2007 (ML071200238); and TSTF-505, Revision 2, Provide Risk-Informed Extended Completion Times - RITSTF Initiative 4b, dated July 2, 2018 (ML18183A493), and the associated final model SE, dated November 21, 2018 (ML18267A259).

The NRC staff notes that RG 1.200 has been updated to Revision 3 (ML20238B871). However, consistent with Hatch TS 5.5.16, and as discussed in the SE (ML22297A146) for the licensees adoption of TSTF-505, Revision 2, the use of RG 1.200, Revision 2, to demonstrate PRA acceptability (also known as PRA technical adequacy) is acceptable. Therefore, the staff did not apply RG 1.200, Revision 3, in the review of this LAR.

3.0 TECHNICAL EVALUATION

An approach acceptable to the NRC for making risk-informed decisions about proposed TS changes, including both permanent and temporary changes, is to demonstrate that the proposed licensing basis changes meet the five key principles provided in Section C of

RG 1.174, Revision 3, as described in SRP Section 19.2, and the three-tiered approach outlined in Section C of RG 1.177, Revision 2, as described in SRP Section 16.1.

The key principles as described in RG 1.174, Revision 3, are:

1. The proposed licensing basis change meets the current regulations unless it is explicitly related to a requested exemption (i.e., a specific exemption under 10 CFR 50.12).

2. The proposed licensing basis change is consistent with the defense-in-depth philosophy.

3. The proposed licensing basis change maintains sufficient safety margins.

4. When proposed licensing basis changes result in an increase in risk, the increases should be small and consistent with the intent of the Commissions policy statement on safety goals for the operations of nuclear power plants.

5. The impact of the proposed licensing basis change should be monitored using performance measurement strategies.

The three-tiered approach for risk evaluation in RG 1.177, Revision 2, includes:

Tier 1: PRA Capability and Insights; Tier 2: Avoidance of High Risk-Significant Plant Configurations; and Tier 3: Risk-Informed Configuration Risk Management Program (CRMP).

Each of the key principles in RG 1.174 and the tiers in RG 1.177 are addressed in NEI 06-09-A, as discussed in the final model SE issued by the NRC staff for TSTF-505, Revision 2. The information provided in the TSTF-505 model application enclosures is consistent with the information required by Section 4.0, Limitations and Conditions, of the SE that approved the methodology in NEI 06-09-A.

In Section 2.2 of Attachment 1 to the current LAR, the licensee summarizes the new information (i.e., enclosures) provided to justify the proposed changes to the RICT program and identifies information that was not applicable or had been provided previously as part of the LAR to adopt TSTF-505, Revision 2. Therefore, to the extent practical, the NRC staff leveraged the previous review (ML22297A146) for the issuance of Amendment Nos. 319 and 264, which permitted the use of RICTs based on the adoption of TSTF-505, Revision 2, for Hatch Unit Nos. 1 and 2, respectively, to determine if the existing elements of the RICT Program (e.g., PRA models, real-time model, monitoring program) are acceptable for the proposed RICTs.

In Section 2.1 of Attachment 1 to the LAR, the licensee states that the proposed RICTs for TS 3.7.1, Required Action A.1, and TS 3.7.2, Required Action A.1, would be considered variations from the TS changes described in TSTF-505, Revision 2. These variations are not within the original scope of TSTF-505, Revision 2, because that traveler excluded required actions with CTs of 30 days or more. The proposed RICTs would also require exceptions to NEI 06-09-A in TS 5.5.16 because NEI 06-09-A has a deterministic 30-day limit for RICTs (also known as the backstop CT). Therefore, the NRC staff review also focused on the acceptability of allowing more than 30 days and up to a 45-day plant-specific and component-specific backstop for the proposed RICTs.

The NRC staffs evaluation of the licensees proposed changes to the RICT Program against the key safety principles of risk-informed decision-making are discussed next.

3.1 Key Principle 1: Evaluation of Compliance with Current Regulations Paragraph 50.36(c)(2) of 10 CFR states that LCOs are the lowest functional capability or performance levels of equipment required for safe operation of the facility. When an LCO of a nuclear reactor is not met, the licensee shall shut down the reactor or follow any remedial action permitted by the TSs until the condition can be met. The regulations at 10 CFR 50.36 do not specify the timeframe in which remedial actions must be performed. The front stop CTs in the current TSs were typically established using experiential data, risk insights, and engineering judgement.

The NRC staff reviewed the proposed changes to the TSs. The proposed addition of RICTs for TS 3.7.1, Required Action A.1, and TS 3.7.2, Required Action A.1, do not change the required performance levels of equipment specified in the associated LCOs. Only the CTs for the required actions would be modified by inclusion in the RICT Program, such that 10 CFR 50.36(c)(2) would continue to be met.

Paragraph 50.36(c)(5) of 10 CFR identifies administrative controls as the provisions relating to organization and management, procedures, recordkeeping, review and audit, and reporting necessary to assure operation of the facility in a safe manner. The Hatch RICT Program in TS 5.5.16 provides the necessary administrative controls to permit extension of CTs and, thereby, delay reactor shutdown or required actions, if risk is assessed and managed appropriately within specified limits and programmatic requirements. As discussed in the SE for Amendment Nos. 319 and 264, the NRC staff previously found that SNC has identified appropriate administrative controls consistent with NEI TR 06-09-A and 10 CFR 50.36(c)(5). In Section 2.2 of Attachment 1 to the current LAR, SNC states that the PRA model update process, the attributes of the real-time model, program implementation, and the monitoring program were not affected by the proposed changes. Therefore, as the staff previously found, these elements of the RICT Program continue to assure operation of the facility in a safe manner.

All RICTs at Hatch are currently limited to a maximum of 30 days in accordance with NEI 06-09-A and as required by TS 5.5.16. In the current LAR, the licensee proposes to modify TS 5.5.16 to allow a backstop CT of 45 days for only TS 3.7.1, Required Action A.1, and TS 3.7.2, Required Action A.1. The proposed corresponding change to TS Example 1.3-8 would also be necessary to align the explanation of how to use RICTs with the proposed changes to TS 5.5.16. These proposed changes would be an exception to NEI 06-09-A. The acceptability of the proposed 45-day backstop CT for the conditions of one pump inoperable for the RHRSW system and for the PSW system is discussed next for Key Principle 1, and under the evaluations for Key Principles 2, 3, and 4 in Sections 3.2, 3.3, and 3.4, respectively. These changes do not affect Key Principle 5, as discussed in Section 3.5.

3.1.1 Evaluation of 45-day Backstop CT As discussed in RG 1.177, Section C.1.1.3, licensees may request changes to the TSs to reduce unnecessary burdens in complying with current TS requirements, based on the operating history of the plant or industry in general. As one example, RG 1.177 states that the repair time may need to be longer than the CT defined in the TS. Section 2.3 of this SE summarizes the reasons that the licensee provides for requesting the proposed TS change.

These include the historical need to submit multiple emergency LARs to allow a one-time CT extension from 30 days to 45 days to perform pump repair and replacement activities to restore operability.

Section C.2, Element 2: Perform Engineering Analysis, of RG 1.177, states, in part, that:

The staff expects licensees to provide strong technical bases for any TS change.

The technical bases should be rooted in deterministic engineering and system analysis. Licensees should not submit for review TS change requests based on PRA results alone. TS change requests should give proper attention to the integration of considerations, such as conformance to STS [Standard TS],

generic applicability of the requested change if it is different from STS, operational constraints, manufacturers recommendations, and practical considerations for test and maintenance. Standard practices used in setting CTs and SFs [surveillance frequencies] should be followed (e.g., CTs normally are 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months , 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months , 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months , 7 days, 14 days, and so on and SFs normally are once per 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months , 7 days, 1 month, 3 months and so on). Using such standards greatly simplifies implementation, scheduling, monitoring, and auditing. Logical consistency among the requirements should be maintained (e.g., CT requirements for multiple trains out of service should not be longer than that for one of the constituent trains).

The NRC staff reviewed the licensees discussion of operating experience and time estimates to resolve potential issues that may arise while replacing an RHRSW or a PSW pump and/or motor that was provided in Section 2.2 of Enclosure 1 of the LAR. Based on its independent review of the information provided by the licensee, the NRC staff determined that extending the CT up to 45 days would provide a reasonable amount of time to perform maintenance when one pump is inoperable in the RHRSW or PSW Systems. The proposed backstop CT of 45 days is also consistent with a previous NRC approval for a one-time CT extension at Hatch (ML21264A644).

The NRC staff also reviewed the justification provided in Section 2.3 of Enclosure 1 of the LAR for why the 45-day backstop CT for TS 3.7.1, Required Action A.1, and TS 3.7.2, Required Action A.1, is considered by the licensee to be an acceptable modification to the RICT Program.

The licensee stated, in part, that:

The proposed change would allow the Completion Time to be extended to a maximum of a 45-day Completion Time for one pump inoperable in each system.

The actual allowed Completion Time would be based on configuration specific considerations in accordance with the RICT program and would not automatically be extended 45 days. The RICT program also calls for risk management actions, and SNC procedures encourage staying within the front stop (i.e., 30 days) when possible. The proposed 45-day backstop on a RICT extension for one pump inoperable in the RHRSW, and for one pump inoperable in the PSW, would permit extended Completion Times beyond 30 days provided an evaluation shows an acceptable risk level, and would reduce the need for emergency amendment activities so that plant focus can be maintained on restoring operability of the pump.

The NRC staff recognizes that permitting the use of a 45-day backstop CT for the requested TSs is a risk-informed approach, as compared to changing the front stop CT from 30 days to

45 days, because a RICT would still be calculated based on the configuration-specific risk and the other programmatic requirements of the RICT Program would still be applicable during the extended CT. Therefore, the NRC staff also assessed the proposed change against the basis for the 30-day limit in NEI 06-09-A.

Section 3.1.2 of NEI 06-09-A states, in part, that:

The back-stop CT limit of 30 days is judged to be a prudently conservative administrative limit for configuration risk management. Similar to the 90-day limit for a temporary alteration for maintenance without performing a 10 CFR 50.59 evaluation established in NEI 96-07 Guidelines for 10 CFR 50.59 Implementation, the 30-day back-stop CT limits the time that is in a condition that is not consistent with the design basis. The 30-day back-stop CT was established based on the fact that some conventional Technical Specification front-stop CT limits are as long as 30 days, and because many nuclear stations would require up to this time period to complete some required complex corrective maintenance and testing for system function recovery.

The NRC SE approving the methodology in NEI 06-09-A also confirms that the 30-day backstop CT assures that TS equipment is not out of service for extended periods, and is a reasonable upper limit to permit repairs and restoration of equipment to an operable status.

Based on the above, the NRC staff finds that the use of a 45-day backstop CT is acceptable for the conditions of one pump inoperable for the RHRSW System and one pump for the PSW System because the intent of the backstop CT is to provide a reasonable limit that also allows sufficient time for maintenance and testing to restore operability of equipment. The proposed change is also consistent with the guidance in RG 1.177, Section C.2.

3.1.2 Key Principle 1: Conclusion The NRC staff determined that the proposed exception to NEI 06-09-A to allow an RICT backstop of 45 days for the specified TS required actions would provide a reasonable amount of time to allow SNC to perform maintenance on one pump in the RHRSW System or the PSW system. The staff also determined that the required performance levels of equipment specified in the LCOs are not changed. Therefore, the staff finds the proposed changes to TS 5.5.16, TS 3.7.1, and TS 3.7.2 acceptable. In addition, the corresponding proposed change to TS Example 1.3-8 to revise the 30-day maximum phrasing would provide clarity and maintain consistency with the RICT Program and is, therefore, acceptable. The NRC staff determined that, with no other changes to the RICT Program in TS 5.5.16, or its implementation, the requirements of 10 CFR 50.36(c)(5) and 10 CFR 50.36(c)(2) will continue to be met. Therefore, the staff finds that the first key principle of risk-informed decision-making is satisfied.

3.2 Key Principle 2: Evaluation of Defense-in-Depth In RG 1.174, Revision 3, the NRC staff identified the following considerations for evaluation of how a licensing basis change is consistent with the defense-in-depth (DID) philosophy:

Preserve a reasonable balance among the layers of defense; Preserve adequate capability of design features without an overreliance on programmatic activities as compensatory measures;

Preserve system redundancy, independence, and diversity commensurate with the expected frequency and consequences of challenges to the system, including consideration of uncertainty; Preserve adequate defense against potential common-cause failures (CCFs);

Maintain multiple fission product barriers; Preserve sufficient defense against human errors; and Continue to meet the intent of the plants design criteria.

The evaluation of defense-in-depth for the Hatch RICT Program is documented in the SE for Amendment Nos. 319 and 264. In that SE, the NRC staff found that extending the selected CTs with the RICT Program following a loss of redundancy, but maintaining the capability of the system to perform its safety function, is an acceptable reduction in DID during the proposed RICT period provided that the licensee identifies and implements compensatory measures in accordance with the RICT Program during the extended CT. In the current LAR, the licensee is not proposing to change the design of the RHRSW or PSW Systems or the safety analysis acceptance criteria. Therefore, the proposed TS changes do not introduce any new failure modes or change the level of DID inherent in the systems designs.

The NRC staff reviewed the system design information for the RHRSW and PSW Systems provided in Section 2.1 of Enclosure 1 of the LAR and the applicable sections of the Hatch FSAR. This information is summarized in Sections 2.1.2 and 2.1.3 of this SE. The NRC staff also reviewed the risk management action (RMA) examples provided in Enclosure 12 of the LAR, as supplemented by the licensees RAI response dated May 7, 2024. The responses to NRCs RAI question on RMAs (also known as compensatory measures) provided reasonable assurance that RMAs will be implemented to monitor and control risk, including addressing CCF considerations. Additionally, the NRC staff notes that the current Hatch RICT Program already includes the conditions of one pump inoperable in each subsystem (i.e., two of four pumps inoperable) for the RHRSW and PSW Systems (RHRSW System TS 3.7.1, Required Action B.1, and PSW System TS 3.7.2, Required Action C.1). Based on its independent review, the NRC staff finds that, given the level of redundancy in the design of the RHRSW and PSW Systems and the use of RMAs in accordance with the RICT Program, adequate DID would be maintained during an extended CT of up to 45 days for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2.

Based on the above, the NRC staff finds that the licensees proposed changes are consistent with the DID philosophy, satisfy the second key principle of risk-informed decision-making, and is, therefore, acceptable.

3.3 Key Principle 3: Evaluation of Safety Margins Section 2.2.2 of RG 1.177 states, in part, that sufficient safety margins are maintained when:

a. Codes and standards or alternatives approved for use by the NRC are met

b. Safety analysis acceptance criteria in the final safety analysis report are met, or proposed revisions provide sufficient margin to account for analysis and data uncertainties.

The evaluation of safety margins for the Hatch RICT Program is documented in the SE for Amendment Nos. 319 and 264. In that SE, the NRC staff found that the intent of the plant design criteria and design-basis analyses for Hatch remain applicable and unchanged, that

sufficient safety margins would be maintained during the extended CT, and that the proposed changes to the TSs do not include any change in the standards applied or the safety analysis acceptance criteria. The licensee is not proposing in the current LAR to change any quality standard, material, operating specification, or safety analysis acceptance criteria.

The NRC staff evaluated the effect on safety margins when the proposed RICT is applied to extend the CT from 30 days up to a backstop of 45 days for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2. For these conditions, sufficient trains of equipment remain operable to fulfill the TS safety function. Although the licensee would be able to have design-basis equipment out of service longer than the current TSs would allow, any increase in unavailability is expected to be insignificant and is addressed by the consideration of the single-failure criterion in the design-basis analyses. Acceptance criteria for operability of equipment are not changed and, if sufficient trains remain operable to fulfill the TS safety function, the operability of the remaining train(s) ensures that sufficient safety margins are maintained.

Based on the above, the NRC staff finds that the proposed changes to permit the use of RICTs, not exceeding 45 days, for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2 does not change the conclusions from the previous SE approving the RICT Program that safety margins would be maintained. Therefore, the staff finds that the third key principle of risk-informed decision-making would continue to be met and is, therefore, acceptable.

3.4 Key Principle 4: Change in Risk Consistent with the Safety Goal Policy Statement As required by TS 5.5.16, the Hatch RICT Program must be implemented in accordance with NEI 06-09-A. The NRC staff evaluated the proposed changes to add RICTs for TS 3.7.1 and TS 3.7.2 and the modifications to the RICT Program in TS 5.5.16 to ensure that the use of the NEI 06-09-A methodology, with the proposed exceptions, would still be acceptable and that the other programmatic requirements in TS 5.5.16 would continue to be met. As part of this review, the NRC staff evaluated the impact of the proposed changes on the licensees processes and methodologies for determining that the change in risk from the implementation of RICTs will be small and consistent with the intent of the Commissions Safety Goal Policy Statement. In addition, the staff evaluated the licensees proposed changes against the three-tiered approach in RG 1.177 for the licensees evaluation of the risk associated with a proposed CT change. The results of this review are discussed next.

3.4.1 Tier 1: PRA Capability and Insights The first RG 1.177 tier evaluates the impact of the proposed changes on plant operational risk.

The Tier 1 review involves two aspects: (1) scope and acceptability of the PRA models and their application to the proposed changes and (2) a review of the PRA insights and results described in SNCs application.

In the SE for Amendment Nos. 319 and 264, which approved the Hatch RICT Program, the NRC staff concluded, in part, that:

SNC has demonstrated the technical acceptability and scope of its PRA models and alternative methods, including consideration of the impact of seismic events and other external hazards, and that the models can support implementation of the RICT Program for determining extensions to CTs. The licensee has made proper consideration of key assumptions and sources of uncertainty. The risk

metrics are consistent with the approved methodology of NEI TR 06-09-A and the acceptance guidance in RG 1.177 and RG 1.174. The RICT Program will be controlled administratively through plant procedures and training and follows the NRC-approved methodology in NEI TR 06-09-A. Based on the above, the NRC staff concludes that the RICT Program satisfies the fourth key principle stated above and is, therefore, acceptable.

The NRC staff notes that the guidance in RG 1.200, Revision 2, was considered in the staffs review of PRA acceptability for the licensees request to adopt TSTF-505 and implement a RICT program. The NRC staff also notes that the guidance in NUREG-1855, Revision 1, was considered in the staffs review of key assumptions and sources of uncertainty for the licensees request to adopt TSTF-505 and implement a RICT program.

In Section 2.3 of Enclosure 1 of the current LAR, the licensee explains that the current Hatch RICT Program already includes the conditions of one pump inoperable in each subsystem for the RHRSW and PSW Systems. As such, there is no change in the scope of the equipment modeled in the PRA to support the use of the proposed RICTs. The licensee is not proposing to expand the applicability of the RICT Program to other Modes. In accordance with TS 5.5.16.b, A RICT may only be utilized in MODE 1.

As stated in Attachment 1 to the current LAR, the proposed change would not change the design, configuration, or method of operation of the plant. The requirements in TS 5.5.16.e, which describes acceptable risk assessment approaches and methods, would also be unchanged. In Section 2.2 of Attachment 1 to the LAR, the licensee states that the PRA model update process, the attributes of the real-time risk model, program implementation, and the monitoring program would not be affected by the proposed changes, and that changes to the PRA since the previous LAR to adopt TSTF-505 (ML21300A153) were maintenance items and there were no new PRA methods/upgrades. The licensee also states that the proposed changes would not impact other external hazards and that the seismic penalty (i.e., the seismic core damage frequency (CDF) and Large Early Release Frequency (LERF) contribution, which are calculated as discussed in the LAR to adopt TSTF-505, as supplemented (ML21300A153 and ML22230C465)) is applied regardless of the length of the RICT. The licensee stated that there are no new key assumptions or sources of uncertainty introduced since the LAR to adopt TSTF-505.

In Enclosure 5 of the current LAR, the licensee provided the estimated total CDF and LERF for the base PRA models (i.e., Internal Events, Internal Flooding, and Internal Fire), including the seismic penalty, to demonstrate that Hatch continues to meet the 1x10-4/year CDF and the 1x10-5/year LERF criteria of RG 1.174 consistent with the guidance in NEI 06-09-A. The example calculated RICT values in Table E1-4, Example Risk Informed Completion Times for Hatch Unit 1 and Unit 2 Technical Specifications, in Enclosure 1 of the LAR show that the proposed backstop of 45 days would be applicable to the proposed RICTs for TS 3.7.1, Required Action A.1, and TS 3.7.2, Required Action A.1, assuming no other structures, systems and components (SSCs) modeled in the PRA are unavailable. Meeting the risk acceptance guidelines in NEI 06-09-A and RG 1.174 provides reasonable assurance that risk increases are acceptably small.

Based on the above, the NRC staff finds that the proposed changes to permit the use of RICTs not exceeding 45 days for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2 would not affect PRA acceptability, the scope of the PRA models, the assessment of seismic events and other external hazards, the considerations of key assumptions and uncertainty, or

the application of risk metrics in accordance with NEI 06-09-A. The proposed changes would also not affect the PRA update process or attributes of the real-time risk model. The only changes with respect to program implementation would be those required to allow implementation of the proposed RICTs with a 45-day backstop.Based on the above, the NRC staff finds that the conclusions for the Tier 1 assessment from the previous SE for the RICT Program remain applicable and that the intent of the Tier 1 guidance in RG 1.177 continues to be satisfied and is, therefore, acceptable.

3.4.2 Tier 2: Avoidance of High Risk-Significant Plant Configurations RG 1.177 Tier 2 evaluates the capability of the licensee to identify and avoid high risk-significant plant configurations that could result if equipment, in addition to that associated with the proposed change, is taken out of service simultaneously or if other risk-significant operational factors, such as concurrent system or equipment testing, are also involved.

Other than the exception in TS 5.5.16.a to allow a backstop CT of 45 days for the proposed RICTs for TS 3.7.1 and TS 3.7.2, the licensee is not proposing to take any other exceptions to NEI 06-09-A, nor are there any proposed changes to the requirements in paragraphs c. and d.

of TS 5.5.16.

The NRC staff reviewed the information regarding RMAs in Enclosure 12 of the LAR, as supplemented by the licensees RAI response dated May 7, 2024. The examples in 2 include three kinds of RMAs (i.e., actions to increase risk awareness and control, actions to reduce the duration of maintenance activities, and actions to minimize the magnitude of the risk increase). The licensee also explains in the LAR, as supplemented, that RMAs will be implemented, in accordance with current procedures, no later than the time at which the 1x10-6 incremental core damage probability (ICCDP) or the 1x10-7 incremental large early release probability (ICLERP) threshold is reached and under emergent conditions when the instantaneous CDF and instantaneous LERF thresholds are exceeded. This information is consistent with the information previously provided in the licensees LAR to adopt TSTF-505, Revision 2.

The Hatch RICT Program requirements, including ICCDP and ICLERP criteria, are consistent with the Tier 2 assessment in RG 1.177 to avoid high risk-significant configurations, as discussed in the SE for Amendment Nos. 319 and 264. The proposed changes to permit the use of RICTs, not exceeding 45 days, for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2 would not change the RICT Program, as approved, with regard to limits established for entry into a RICT and implementation of RMAs that are consistent with NEI 06-09-A.Based on the above, the NRC staff concludes the intent of the Tier 2 guidance in RG 1.177 would continue to be satisfied and is, therefore, acceptable.

3.4.3 Tier 3: Risk-Informed Configuration Risk Management Program The third RG 1.177 tier stipulates that a licensee should develop a program that ensures that the risk impact of out-of-service equipment is evaluated appropriately prior to performing any maintenance activity. The guidance in NEI 06-09-A addresses the Tier 3 evaluation in RG 1.177 by calling for the assessment of the RICT to be based on the plant configuration of all SSCs that might impact the RICT, including safety-related and non-safety-related SSCs. If a risk-significant plant configuration exists, then NEI 06-09-A via the RICT Program in TS 5.5.16 would require the licensee to implement compensatory measures and RMAs.

Other than the exception in TS 5.5.16.a to allow a backstop CT of 45 days for the proposed RICTs for TS 3.7.1 and TS 3.7.2, the licensee is not proposing any other exceptions to NEI 06-09-A, nor are there any proposed changes to the requirements in paragraphs c. and d.

of TS 5.5.16. The NRC staff reviewed the information regarding RMAs provided in Enclosure 12 of the LAR, as supplemented by the licensees RAI response dated May 7, 2024. The RAI response provides additional information on the use of the CRMP tool and selections of RMAs, including discussion of common cause RMAs and adjustment of CCF events. The examples were consistent with the requirements of the RICT Program and did not add any new requirements.

The Hatch RICT Program requirements are consistent with Tier 3 guidance in RG 1.177 to assess and address risk-significant configurations, as discussed in the SE for Amendment Nos. 319 and 264. The proposed changes to permit the use of RICTs, not exceeding 45 days, for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2 would not change the RICT Program, as approved, regarding Tier 3 requirements. Based on the above, the NRC concludes that the intent of the Tier 3 guidance in RG 1.177 would continue to be satisfied and is, therefore, acceptable.

3.4.4 Key Principle 4: Conclusions The licensee has demonstrated the technical acceptability and scope of its PRA models and alternative methods, including consideration of the impact of seismic events and other external hazards, and that these models and methods can support the proposed modifications to the RICT Program to permit the use of RICTs, not exceeding 45 days, for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2. The risk metrics would remain consistent with the approved methodology of NEI 06-09-A and the acceptance guidelines in RG 1.177 and RG 1.174. Based on the above, the NRC staff concludes that the RICT Program with the proposed modifications would continue to satisfy the fourth key principle of risk-informed decision-making and is, therefore, acceptable.

3.5 Key Principle 5: Evaluation of Performance Measurement Strategies - Implementing and Monitoring Program RG 1.177 and RG 1.174 establish the need for an implementation and monitoring program to ensure that extensions to CTs do not degrade operational safety over time and that no adverse degradation occurs due to unanticipated degradation or common-cause mechanisms. As discussed in the SE for Amendment Nos. 319 and 264, the NRC staff concluded previously that the Hatch RICT Program satisfies the fifth key principle because: (1) the RICT Program will monitor the average annual cumulative risk increase as described in NEI TR 06-09-A, thereby ensuring that the program, as implemented, continues to meet RG 1.174 and RG 1.177 guidance for small risk increases and (2) all affected SSCs are within the Maintenance Rule program, which is used to monitor changes to the reliability and availability of those SSCs.

In Section 2.2 of Attachment 1 to the current LAR, the licensee states that the monitoring program is not affected by the proposed RICTs. In Section 2.3 of Enclosure 1 of the LAR, the licensee explains that the Hatch RICT Program already includes the conditions of one pump inoperable in each subsystem for the RHRSW and PSW Systems (i.e., TS 3.7.1, Required Action B.1, and TS 3.7.2, Required Action C.1, respectively). Table E1-1, Mapping of Technical Specification Conditions to PRA Functions, in Enclosure 1 of the LAR states that the SSCs associated with TS 3.7.1, Condition A, and TS 3.7.2, Condition A, are modeled in the PRA. of the LAR also states that the PRA model has the capability to directly model the

risk impact when using the proposed RICTs. This is consistent with the information previously provided in Enclosure 1 of the LAR to adopt TSTF-505, Revision 2 (ML21300A153). Therefore, the scope of the equipment modeled in the PRA to support the use of the proposed RICTs would be unchanged.

The NRC staff concluded previously that the Hatch RICT Program satisfies the fifth key safety principle of RG 1.177 and RG 1.174. The proposed changes to permit the use of RICTs, not exceeding 45 days, for the condition of one pump inoperable in TS 3.7.1 and in TS 3.7.2 would not change the approved RICT Program with regards to performance monitoring. Based on the above, the NRC staff finds the proposed change to be acceptable.

3.6 TS Layout Changes As part of this amendment, certain layout changes were made to the TS pages for both Hatch units as described below:

1. TS 3.7.1, Condition C, One RHRSW subsystem inoperable for reasons other than Condition A, got moved from TS page 3.7-1 to 3.7-2.

2. TS 3.7.1, Condition F, Required Action and associated Completion Time of Condition E not met and SR 3.7.1.1, got moved from TS page 3.7-2 to 3.7-2a.

These layout changes are editorial and did not result in any technical changes. Therefore, the NRC staff finds these acceptable.

3.7 Technical Conclusion The NRC staff evaluated the changes proposed by the licensee against each of the five key principles in RG 1.174 and the three-tiered approach of RG 1.177. The staff determined that the proposed changes satisfy the key principles of risk-informed decision-making identified in RG 1.174 and the three-tiered approach of RG 1.177. Therefore, the staff finds that the TSs, as modified by the proposed changes, will continue to meet 10 CFR 50.36 and are acceptable.

4.0 STATE CONSULTATION

In accordance with the Commissions regulations, the Georgia State official was notified of the proposed issuance of the amendments on November 06, 2024. The State official confirmed that the State of Georgia had no comments on December 06, 2024.

5.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to the installation or use of facility components located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts and no significant change in the types of any effluents that may be released offsite and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission previously issued a proposed finding that the amendments involve no significant hazards consideration published in the Federal Register on February 20, 2024 (89 FR 12876),

and there has been no public comment on such finding. Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

6.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that: (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) there is reasonable assurance that such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendments will not be inimical to the common defense and security or to the health and safety of the public.

Principal Contributors: D. Gennardo J. Circle D. Scully K. West Date: December 20, 2024

ML24312A367 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/STSB/BC NAME DKalathiveettil KGoldstein SMehta DATE 11/07/2024 11/08/2024 12/13/2024 OFFICE NRR/DRA/APLA/BC NRR/DSS/SCPB/BC NRR/DSS/SNSB/BC NAME RPascarelli MValentin DMurdock DATE 09/25/2024 12/13/2024 12/13/2024 OFFICE OGC-NLO NRR/DORL/LPL2-1/BC NRR/DORL/LPL2-1/PM NAME MChwedczuk MMarkley DKalathiveettil DATE 12/12/2024 12/20/2024 12/20/2024

v t e Letter Sequence Approval
EPID:L-2023-LLA-0169, TSTF-505 (Open)
Initiation Request Acceptance Administration Questions Answers 7 May 2024 Results Approval Other: ML24100A440
MONTHYEAR2024-12-20 [Table View]

ML24312A367

Text

SUBJECT:

Dear Jamie Coleman:

Enclosures:

Attachment:

Attachment:

1.0 INTRODUCTION

2.0 REGULATORY EVALUATION

2.1 Background

3.0 TECHNICAL EVALUATION

4.0 STATE CONSULTATION

5.0 ENVIRONMENTAL CONSIDERATION

6.0 CONCLUSION

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