ML17264A630
| ML17264A630 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 09/21/2017 |
| From: | NRC |
| To: | NRC/NRO/DNRL/LB4 |
| References | |
| Download: ML17264A630 (6) | |
Text
1 Vogtle PEmails From:
Hoellman, Jordan Sent:
Thursday, September 21, 2017 10:34 AM To:
Vogtle PEmails
Subject:
SNC Responses to ICN and UIN Comment Status Sheet for 9/21/2017 Public Meeting Attachments:
2017-09-21 SNC responses to ICN UIN Comment Status Sheet.pdf Please see the attached SNC Responses to ICN and UIN Comment Status Sheet for discussion at the Thursday, September 21, 2017, public meeting.
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SNC Responses to ICN and UIN Comment Status Sheet for 9/21/2017 Public Meeting Sent Date:
9/21/2017 10:33:45 AM Received Date:
9/21/2017 10:33:46 AM From:
Hoellman, Jordan Created By:
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"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>
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HQPWMSMRS03.nrc.gov Files Size Date & Time MESSAGE 148 9/21/2017 10:33:46 AM 2017-09-21 SNC responses to ICN UIN Comment Status Sheet.pdf 285364 Options Priority:
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1 VOGTLE ICN/UIN ISSUES TRACKING SHEET (for 9/21/17 public call)
Date ITEM #
ICN UIN TOPIC ITAAC INDEX #
ISSUE Licensee Comment 6/29 1
ICN RCP Elect.
Pwr for 3 V3 676 Issues resolved waiting for resubmittal.
Resubmittal submitted 09/19/17 (ND 1531)
Date ITEM #
ICN UIN TOPIC ITAAC INDEX #
ISSUE Licensee Comment 6/29 2
Draft UIN Test RCP BKR trip Function V3 64 The 2nd paragraph 1st sentence can be interpreted in two ways, 1) the signal was simulated at the detectors themselves by using a test rig to increase the pressure the detector senses or 2) by inserting a dummy signal at the PMS cabinet, please clarify how the containment pressure signal was simulated.
Comment addressed in UIN dated 6/30/17 (ND-17-1130) ML17186A040 Date ITEM #
ICN UIN TOPIC ITAAC INDEX #
ISSUE Licensee Comment 9/5 3
UIN Calculation of flow resistance V3 & V4 177 178 Please clarify the difference in parameters measured as compared to Demo 4 to calculate flow resistance from the CMT and ACC to the RV.
Demo 4 utilizes Flow rate, pressure and level.
Level is directly measured for both tests.
Flow rate is not measured directly for either test based on plant configuration and no instrumentation connections. The flow rate is a calculated value derived from the system volume change during a measured time frame (gal/min).
This methodology is used for both UINs.
Pressure is measured for the Accumulator test using installed instrumentation.
The pressure for the CMT is not measured directly due to no instrumentation connections. The pressure is a calculated value determined from the level change.
2 Date ITEM #
ICN UIN TOPIC ITAAC INDEX #
ISSUE Licensee Comment 9/5 4
Draft ICN Various ASME Items V3 355 post LAR 17-006 Staff combined comments provided on separate sheet.
See attached Date ITEM #
ICN UIN TOPIC ITAAC INDEX #
ISSUE Licensee Comment 9/5 5
UIN Real or simulated signals into DAS 213 Explain the chosen methodology to utilize the DAS Manual actuation circuit in-place of using a real or simulated signal into DAS. (i.e. plant process signals)
Based on FSAR Table 7.3-1 and the SSD, a manual actuation is a real input signal into the DAS.
Date ITEM #
ICN UIN TOPIC ITAAC INDEX #
ISSUE Licensee Comment 9/11 6
ICN Off-site power analysis V3 672 Third paragraph of the IDB - Clarify why the component(s) with the highest rated load(s) was/were not utilized to determine the ampacity rating of each circuit from the switchyard?
Clarification 09/20/17: this comment refers to the second sentence in the third paragraph Fourth paragraph of the IDB - Clarify why MVAs were not directly calculated since the loads of each switchyard circuit include capacitance and inductance in addition to resistance?
The capacity of each offsite power circuit has a margin greater than 200% to supply the maximum plant loads. None of the current carrying components in those circuits are limited by the plant loads. The capacity of each circuit is limited by the manufacturers rated capacity of the line components, at the maximum expected ambient temperature, since they are located outdoors. The lowest rated component was utilized to define the ampacity of each circuit.
Plant load values were provided by Westinghouse Engineering in MW, based upon a 0.9 pf. The offsite power circuit capacities were provided by Georgia Power in MVA. Plant loads were converted to MVA, at 0.9 pf, to compare circuit capacities to the assumed loads.
3 VOGTLE ICN/UIN ISSUES TRACKING SHEET Staff Comments on Draft ITAAC Closure Notification on ITAAC 2.3.06.02a (Index Number 355)
(Based on Vogtle, Units 3 and 4, LAR 17-006)
- 1. The ITAAC Statement of the draft ITAAC Closure Notification (ICN) is inconsistent with the wording in the ITAAC and should be corrected. For example, DC items 3.a and 3.b are not consistent with App. C wording in LAR 17-006. Accepted. SNC to revise to include verbatim wording per LAR 17-006.
- 2. The ITAAC Determination Basis (IDB) needs to include an affirmative statement that the ASME BPV Code,Section III certified design reports exist for the as-built components and piping identified in Tables 2.3.6-1 and 2.3.6-2 as ASME BPV Code,Section III that meet the requirements of NCA-3550 for the Design Report. Accepted. SNC to add extra language to include the ASME BPV Code,Section III certified Design Reports meet the requirements of NCA-3550.
- 3. The ITAAC Determination Basis in the second paragraph notes several restrictions on the piping design. However, the draft ICN does not indicate that these restrictions were addressed in the design. In addition, these additional restrictions are only mentioned in regards to the Design Reports. The draft ICN should also address these additional restrictions with respect to the Data Reports. Additional considerations are needed regarding this question. Additional restrictions are placed on certain piping systems regarding the functional capability and LBB qualifications. These are not ASME Section III requirements but are regulatory requirements that use ASME Section III equations with acceptance criteria in the regulation. The stress analyses (PLRs) that support the Code Design Reports contain the required functional capability or LBB qualification. So, to close the ITAAC, we will need to have the Code Design Report (for satisfying the ASME Code) and the PLR (for the functional capability and LBB qualification).
Therefore, this comment will be addressed on a system-by-system basis since not all systems will have these restrictions. However, if a system does have these restrictions, the applicable ICN will include the restrictions that were addressed in the design. The ICN will also address these restrictions with respect to the Data Reports.
- 4. The ITAAC Determination Basis repeats the wording of the ITAAC without affirmatively stating which specific licensees activities satisfied the acceptance criteria of the ITAAC. Accepted. SNC to include affirmative statements such as Code Design reports are certified; NDE reports were reviewed and accepted with no unacceptable indications; hydrostatic tests were completed and resulted in no visual leakage from pressure boundary welds.
- 5. The ITAAC Finding Review does not indicate that ITAAC 2.3.06.02a (355) includes 2a (355), 2b (356),
3a (357), 3b (358), 4a (359), 4b (360), 5b (364), and 6 (365) such that any findings related to those ITAAC can be located in previous inspection reports and licensee documents. Accepted. SNC to reword to designate pre-consolidation LAR ITAAC with associated findings.
- 6. The References list should specify the report numbers to allow NRC staff to access those reports.
Accepted. SNC to add specific Design Report numbers.
- 7. Attachment A should be clarified. For example: It is unclear what
- indicates. The purpose of the Report column is unknown. The RNS Suction Line from CVS does not have functional capability requirements per Table 2.3.6-2, but is shown to have a Functional Capability Report per Attachment A.
The components listed on Attachment A do not include the complete set to close out this ITAAC.
Accepted. The
- designates that the entries (Equipment Name, Tag No., ASME Code Section III applicability) was excerpted from COL Appendix C Tables. Since the provided draft was an example only it did not include the entire list of SSCs. The final ICN will include the entire list of components and piping.
- 8. Attachment B referenced on page 4 is not attached to the draft ICN. Accepted. The document provided was a draft of an example ICN. For the final ICN, the Attachment table for piping will be added.
4
- 9. The draft ICN should indicate whether the ASME Code Design Report has been inspected. If inspected and determined to be in compliance with the ASME Code, the ICN should reference this Design Report in Attachment A. Accepted. SNC to reference the Design Report by adding it to the Attachment A.
- 10. Each acceptance criteria should correspond to the specific design commitment and the IDB should clearly state how the inspection, tests, analyses performed demonstrate that the acceptance criteria are fully met. More specifically, the IDB provides no information on the functional capability and LBB methodology. Others reference ASME Code,Section III. Accepted. SNC can expand the IDB to specifically include information on how the ITA demonstrates the AC are fully met and include functional capability and LBB information.
- 11. On Page 3/6, the 2nd paragraph of the IDB seems to be incorrect as written. ASME Code design reports do not verify construction. SNC needs to reorder the sentence. Accepted. SNC to reword this sentence.
- 12. On Page 4/6, 1st paragraph, first line should include a clarification that the hydrostatic tests of the components are vendor hydro tests. The next statement in the same section, which only pertains to the hydrostatic tests of piping, should also include components. As written, the ICN is not acceptable.
Accepted. SNC to expand the wording to indicate component hydros in QADPs were performed at the Manufacturers facilities and that system hydros contain piping hydro tests that include the installed components.
- 13. For the hydro tests, the ICN IDB should affirmatively state that there was no pressure boundary leakage or deformation and for the NDE, it should state that there were no unacceptable indications present. Accepted. SNC can expand the wording to indicate an affirmative statement that a visual inspection was performed to confirm was no pressure boundary leakage following hydro tests and for NDE, that no unacceptable indications were present in pressure boundary welds (deformation?).