ML22308A204
| ML22308A204 | |
| Person / Time | |
|---|---|
| Site: | Vogtle, Farley, 05000026, 05000025 |
| Issue date: | 11/18/2022 |
| From: | John Lamb NRC/NRR/DORL/LPL2-1 |
| To: | Gayheart C Southern Nuclear Operating Co |
| References | |
| EPID L-2022-LLA-0148, EPID L-2022-LLA-0149 | |
| Download: ML22308A204 (1) | |
Text
November 18, 2022 Ms. Cheryl A. Gayheart Regulatory Affairs Director Southern Nuclear Operating Co., Inc.
3535 Colonnade Parkway Birmingham, AL 35243
SUBJECT:
JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2; AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 1, 2, 3, AND 4 - SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE: TECHNICAL SPECIFICATION REVISION TO ADOPT WCAP-17661-P-A, IMPROVED RELAXED AXIAL OFFSET CONTROL AND CONSTANT AXIAL OFFSET CONTROL FQ SURVEILLANCE TECHNICAL SPECIFICATIONS (EPID NOS. L-2022-LLA-0148 AND L-2022-LLA-0149)
Dear Ms. Gayheart:
By letter dated October 14, 2022 (Agencywide Documents and Access Management System Accession No. ML22287A174), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for the Joseph M. Farley Nuclear Plant (Farley),
Units 1 and 2, and Vogtle Electric Generating Plant (Vogtle), Units 1, 2, 3, and 4. The proposed LAR would revise technical specifications (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)), to adopt the TS changes described in Appendix A or Appendix D (as applicable) of Westinghouse topical report WCAP-17661-P-A, Revision 1, to address the issues identified in Westinghouse Nuclear Safety Advisory Letter (NSAL) 5, Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions, and NSAL-15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance. The proposed LAR would revise the TSs, to the extent necessary, to adopt several technical specification task force (TSTF) travelers to align the Vogtle, Units 1 and 2, and Farley, Units 1 and 2, TSs with the FQ formulations and required actions of TS 3.2.1B of NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 4.
Additionally, SNC proposes in this LAR to change the Vogtle, Units 1 and 2, and Farley, Units 1 and 2, TSs 5.6.5, and Vogtle, Units 3 and 4, TS 5.6.3, Core Operating Limits Report (COLR),
to include WCAP-17661-P-A, Revision 1, in the list of the NRC approved methodologies used to develop the cycle specific COLR.
The purpose of this letter is to provide the results of the U.S. Nuclear Regulatory Commission (NRC) staffs acceptance review of this LAR. The acceptance review was performed to determine if there is sufficient technical information in scope and depth to allow the NRC staff to complete its detailed technical review. The acceptance review is also intended to identify whether the application has any readily apparent information insufficiencies in its characterization of the regulatory requirements or the licensing basis of the plant.
Consistent with Section 50.90 of Title 10 of the Code of Federal Regulations (10 CFR), an application for an amendment to a license (including the technical specifications) or construction permit must fully describe the changes requested, and following as far as applicable, the form prescribed for original applications. Section 50.34 of 10 CFR addresses the content of technical information required. This section stipulates that the submittal address the design and operating characteristics, unusual or novel design features, and principal safety considerations.
The NRC staff has reviewed your application and concluded that the information delineated in the enclosure to this letter is necessary to enable the NRC staff to make an independent assessment regarding the acceptability of the proposed LAR in terms of regulatory requirements for the protection of public health and safety and the environment.
In order to make the application complete, the NRC staff requests that SNC supplement the application to address the information requested in the enclosure within 13 working days of the date of this letter. This will enable the NRC staff to begin its detailed technical review. If the information responsive to the NRC staffs request is not received by the above date, the application will not be accepted for review pursuant to 10 CFR 2.101, and the NRC will cease its activities associated with the application. If the application is subsequently accepted for review, you will be advised of any further information needed to support the NRC staffs detailed technical review by separate correspondence.
The information requested and associated time frame in this letter were discussed with Amy Chamberlain of your staff on November 17, 2022.
If you have any questions, please contact me at (301) 415-3100 or via email at John.Lamb@nrc.gov.
Sincerely,
/RA John G. Lamb, Sr. Project Manager Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-348, 50-364, 50-424 50-425,52-025, and 52-026
Enclosure:
As stated cc: Listserv
Enclosure SUPPLEMENTAL INFORMATION NEEDED FOR ACCEPTANCE OF REQUESTED LICENSING ACTION RE: TECHNICAL SPECIFICATION REVISION TO ADOPT WCAP-17661-P-A, IMPROVED RELAXED AXIAL OFFSET CONTROL AND CONSTANT AXIAL OFFSET CONTROL FQ SURVEILLANCE TECHNICAL SPECIFICATIONS EPID NOS. L-2022-LLA-0148 AND L-2022-LLA-0149 JOSEPH M. FARLEY NUCLEAR PLANT, UNITS 1 AND 2, VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2, AND VOGTLE ELECTRIC GENERATING PLANT, UNITS 3 AND 4 By letter dated October 14, 2022 (Agencywide Documents and Access Management System Accession No. ML22287A174), Southern Nuclear Operating Company (SNC, the licensee) submitted a license amendment request (LAR) for the Joseph M. Farley Nuclear Plant (Farley),
Units 1 and 2; and Vogtle Electric Generating Plant (Vogtle), Units 1, 2, 3, and 4. The proposed LAR would revise Technical Specifications (TS) 3.2.1, Heat Flux Hot Channel Factor (FQ(Z)),
to adopt the TS changes described in Appendix A or Appendix D (as applicable) of Westinghouse topical report WCAP-17661-P-A, Revision 1, to address the issues identified in Westinghouse Nuclear Safety Advisory Letter (NSAL) 5, Revision 1, Relaxed Axial Offset Control FQ Technical Specification Actions, and NSAL-15-1, Heat Flux Hot Channel Factor Technical Specification Surveillance. The proposed LAR would revise the TSs, to the extent necessary, to adopt several technical specification task force (TSTF) travelers to align the Vogtle, Units 1 and 2, and Farley, Units 1 and 2, TSs with the FQ formulations and required actions of TS 3.2.1B of NUREG-1431, Standard Technical Specifications Westinghouse Plants, Revision 4. Additionally, SNC proposes in this LAR to change the Vogtle, Units 1 and 2, and Farley, Units 1 and 2, TSs 5.6.5, and Vogtle, Units 3 and 4, TS 5.6.3, Core Operating Limits Report (COLR), to include WCAP-17661-P-A, Revision 1, in the list of the NRC approved methodologies used to develop the cycle specific COLR.
Supplemental Information Needed As part of the acceptance review, the U.S. Nuclear Regulatory Commission (NRC) staff compared the proposed TS changes to the model TS changes approved in WCAP-17661-P-A, Revision 1. The NRC staff determined that the changes proposed by SNC are not consistent with the TSs approved by the staff in WCAP-17661-P-A, Revision 1. The proposed NOTE above the TS 3.2.1 Condition A description and Required Action B.2.1 are not consistent with the TSs approved by the NRC staff in WCAP-17661-P-A, Revision 1.
The NRC staff noted SNC provided an explanation and an example precedent for the proposed deviation from WCAP-17661-P-A, Revision 1, in the TSs. However, the NRC staff also noted SNCs explanation does not acknowledge the reasoning for the text of the NOTE as discussed in Section 3.2.1 (starting on pdf page 10 out of 40) and Section 4.2 (starting on page 22 out of
- 40) in the approved version of the WCAP (ADAMS Accession No. ML18298A320 - non-publicly available). The extra phrasing was meant to clarify what should happen upon entry as well as when it should happen. The NRC staff further noted the SNC cited precedent was granted prior to the WCAP approval and recent similar amendments granted after WCAP approval adopted the NOTE as it appears in the approved WCAP. The NRC staff has concerns that omission of the WCAP Note may create ambiguity in the intended meaning and create a potential unintended expansion of authority beyond the WCAP approval, particularly with surveillances as noted in the WCAP Request for Additional Information (RAI) 10 (ADAMS Accession No. ML16291A524) and the NRC staffs Safety Evaluation for the WCAP (ADAMS Accession No. ML18298A320 - non-publicly available; and ADAMS Accession No. ML19225C081 -
non-proprietary WCAP).
SNC is requested to supplement the requests with TS changes that follow those approved in WCAP-17661-P-A, Revision 1.
ML22308A204 OFFICE NRR/DORL/LPL2-1/PM NRR/DORL/LPL2-1/LA NRR/DSS/STSB/BC NRR/DSS/SNSB/BC NAME JLamb KGoldstein (KEntz for)
VCusumano DWoodyatt DATE 11/7/2022 11/7/2022 11/7/2022 11/9/2022 OFFICE NRR/VPO/D NRR/DORL/LPL2-1/BC NRR/DSS/D NRR/DORL/D NAME VHall MMarkley JDonoghue BPham DATE 11/8/2022 11/9/2022 11/15/2022 11/172022 OFFICE NRR/DORL/LPL2-1/PM NAME JLamb DATE 11/18/2022