ML18107A587

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COL Docs - Staff Feedback on SNC Response to RAI LAR 17-037-1, Question 2
ML18107A587
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 04/17/2018
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NRC
To:
NRC/NRO/DNRL/LB4
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Download: ML18107A587 (2)


Text

1 Vogtle PEmails From:

Habib, Donald Sent:

Tuesday, April 17, 2018 9:50 AM To:

WASPARKM@southernco.com; neil.haggerty@excelservices.com; ptapscot@southernco.com; Chamberlain, Amy Christine Cc:

Vogtle PEmails; Patel, Chandu; Hansing, Nicholas; Lupold, Timothy; Scarbrough, Thomas

Subject:

Staff Feedback on SNC Response to RAI LAR 17-037-1, Question 2 Wes et al. -

At the public meeting on April 12, the staff indicated it would provide additional feedback on SNCs response to RAI LAR 17-037-1, Question 2.

Below is our feedback. Please contact me if you have any questions.

Don Habib Project Manager NRO/DNRL, Licensing Branch 4 O-8D13 301-415-1035 Material in UFSAR Section 3.6.2 is not used to implement ASME Code. These requirements are outside of Code space, but are still considered piping DAC. Section 3.6.2 does involve ASME Code piping, but it also includes B31.1 piping and is extraneous to Code requirements. In order to clarify that piping DAC includes more than just ASME Code compliance and that pipe break is not contained within ASME Code, the staff is interested in the following changes:

In the first paragraph of the response, add or endorsed regulatory guidance after industry standard. This wording is consistent with SNC proposed screening Criteria 2.

In the second point of proposed text to supplement the submittal, add or endorsed regulatory guidance after industry standard and include the e.g., to show that ASME Code is not the only standard or guidance considered for piping DAC. This wording is consistent with SNC proposed screening Criteria 2.

In the fourth point of proposed text to supplement the submittal, consider one of the following changes:

o Refer to item 6 of Tier 1 Section 2.1.2 instead of item 2.b if Tier 2* text from Section 3.6.2 will be used. Frame the discussion around meeting the regulatory guidance for pipe break rather than ASME Code compliance. Item 6 states: Each of the as-built lines identified in Table 2.1.2-2 as designed for leak before break (LBB) meets the LBB criteria, or an evaluation is performed of the protection from the dynamic effects of a rupture of the line. It is this Tier 1 Design Commitment that is supported by the Tier 2* text in 3.6.2, rather than item 2.b.

o Refer to an applicable section of Tier 2* text in UFSAR Section 3.9.3 rather than Section 3.6.2 for the example if item 2.b in Tier 1 will be used. The discussion regarding ASME Code compliance is acceptable with an appropriate example, such as the portion of Section 3.9.3.1.2 that states, The design pressure is used in minimum wall thickness calculations in accordance with the ASME Code.

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257 Mail Envelope Properties (SN4PR0901MB21736031F042C0E30B89E46097B70)

Subject:

Staff Feedback on SNC Response to RAI LAR 17-037-1, Question 2 Sent Date:

4/17/2018 9:49:55 AM Received Date:

4/17/2018 9:50:00 AM From:

Habib, Donald Created By:

Donald.Habib@nrc.gov Recipients:

"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>

Tracking Status: None "Patel, Chandu" <Chandu.Patel@nrc.gov>

Tracking Status: None "Hansing, Nicholas" <Nicholas.Hansing@nrc.gov>

Tracking Status: None "Lupold, Timothy" <Timothy.Lupold@nrc.gov>

Tracking Status: None "Scarbrough, Thomas" <Thomas.Scarbrough@nrc.gov>

Tracking Status: None "WASPARKM@southernco.com" <WASPARKM@southernco.com>

Tracking Status: None "neil.haggerty@excelservices.com" <neil.haggerty@excelservices.com>

Tracking Status: None "ptapscot@southernco.com" <ptapscot@southernco.com>

Tracking Status: None "Chamberlain, Amy Christine" <ACCHAMBE@southernco.com>

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