ML18142B923

COL Docs - Draft RAI Responses for LAR-17-037, Changes to Tier 2* Departure Evaluation Process

ML18142B923
Person / Time
Site:	Vogtle
Issue date:	05/22/2018
From:	NRC
To:	NRC/NRO/DNRL/LB4
References
Download: ML18142B923 (26)

Text

Vogtle PEmails From: Hoellman, Jordan Sent: Tuesday, May 22, 2018 4:03 PM To: Vogtle PEmails

Subject:

Draft RAI Responses for LAR-17-037, Changes to Tier 2* Departure Evaluation Process Attachments: RAI LAR 17-037-5_eRAI 9514_HOIB (Draft to NRC-051718).pdf; RAI LAR 17-037-6_eRAI 9542_LB4 (Draft to NRC-051718).pdf; RAI LAR 17-037-7_eRAI 9544_ARPB (Draft to NRC-051718).pdf; RAI LAR-17-037-8_eRAI 9541_ICE (Draft to NRC-05-21-18).pdf; RAI LAR 17-037-9_eRAI 9524_SRSB (Draft to NRC-051718).pdf Attached are draft responses to RAIs issued by the staff to support their review of LAR-17-037, Changes to Tier 2*

Departure Evaluation Process.

The responses are provided to allow staff review in advance of a future public meeting.

1

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 279 Mail Envelope Properties (SN6PR09MB26081EB4992CED2DE86AA718D5940)

Subject:

Draft RAI Responses for LAR-17-037, Changes to Tier 2* Departure Evaluation Process Sent Date: 5/22/2018 4:02:36 PM Received Date: 5/22/2018 4:02:48 PM From: Hoellman, Jordan Created By: Jordan.Hoellman2@nrc.gov Recipients:

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

Tracking Status: None Post Office: SN6PR09MB2608.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 261 5/22/2018 4:02:48 PM RAI LAR 17-037-5_eRAI 9514_HOIB (Draft to NRC-051718).pdf 835165 RAI LAR 17-037-6_eRAI 9542_LB4 (Draft to NRC-051718).pdf 791858 RAI LAR 17-037-7_eRAI 9544_ARPB (Draft to NRC-051718).pdf 868647 RAI LAR-17-037-8_eRAI 9541_ICE (Draft to NRC-05-21-18).pdf 726734 RAI LAR 17-037-9_eRAI 9524_SRSB (Draft to NRC-051718).pdf 824197 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Southern Nuclear Operating Company ND-18-XXXX Enclosure XX D VEGP)

P) Units 3 and 4 Vogtle Electric Generating Plant (VEGP) r (0 aft 5- R Response to NRC Request for Additional Information ditional Inf rmation (RAI)

I ormation (RA LAR 17-037-5 17 e Regarding LAR-17-037 ding the LA LAR 7--037 Review Revi

-2 spo (LAR (L 17-037S3) 037S3)

(LAR-17-037S3) 01 n

8) se Supplement 3 changes that are added to the original LAR submittal are shown as blue-underlined text; deletions of original LAR text are shown as red strikethrough text.

(This Enclosure consists of xxxx pages, including this cover page.)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-5] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)-17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

Regulatory Basis:

10 CFR 50.34(f)(2)(iii) states:

Provide, for Commission review, a control room design that reflects state-of-the-art human factor principles prior to committing to fabrication or revision of fabricated control room panels and layouts.

Amongst other things, 10 CFR Part 52 Appendix D:

x provides definitions of Tier 1, Tier 2, and Tier 2* as they pertain to the AP1000 design x Section VIII provides a change process for controlling Tierier 2 information 10 CFR 52.79(a)(41) requires applicants to provide an evaluation aluation of the facility against the D

standard review plan (SRP) or discuss how any departuresress from the SRP S provide an acceptable r

e SRP method of complying with regulations that underlie the RP acceptance acce accepta criteria.

(0 aft NUREG-0800, Chapter 18 of the SRP is the e guidance uidance NRC NRC staff uses to ensure that

§ 50.34(f)(2)(iii) is met. Chapter 18 referencess NUREG-0711 NUREG UREG-071 0 which ccontains acceptance criteria 5- R ering related to licensees human factors engineeringng (HFE) programs.

programs ams..

The Vogtle Units 3&4 Updated Final al Safety Analysis Ana A ysis Report (UFSAR),

(U Section 18.2.1.2, 17 e "Regulatory Requirements," states, "The human fa ctors ors engineerin factors enginee engineering process is designed to meet

-2 spo es n proces the human factors engineering design process rrequirements quirements uirements specified spe in NUREG-0711. NUREG-ptance tance ccriteria 0711 contains the SRP acceptance eria fforr an accepta er acceptabl acceptablee human factors design program.

e:

Description of the Issue:

01 n NRC human factors staff has rev ed the reviewed he proce process described in LAR 17-037. The staff agrees

8) se tly ly HFE infor that there is currently info ion informationon identified as Tier 2* that can be adequately controlled using ocess However, the Tier 2 change process. owever, wever, it is unclear un if the process proposed in LAR 17-037 will i

id tify human factors predictably and reliably identify facto information that need not be controlled by the Tier fa cation ation is necessary 2* change process. Clarification neces ne to help the staff make a determination on the LAR.

Question:

Section 3, "Technical Evaluation" (Enclosure 1, Page 10 of 19) of LAR 17-037 provides specific examples of "material changes" that may affect design processes. The examples of material changes and non-material changes are helpful. However, it's not clear that the examples provided will be sufficient for either the licensee or the NRC staff to determine whether a change is material or not, especially when the proposed change is unlike any of the examples given.

Clarifying this process is important because changes to the approved human factors implementation plans (IPs) may have significant effects on the iterative process, including generation of information from testing and interpretation of test results that employs various human factors processes to develop a final HFE design. Altering details that the NRC staff used in approving these implementation plans could, in some cases, invalidate the staff findings on the IPs, and may consequently challenge the staffs ability to rely on the results of HFE testing to

confirm that the main control room HSIs will support safe operation. Moreover, lack of a clear definition of a "material change" or criteria for evaluating changes may be problematic in regard to both licensee and NRC inspections related to human factors inspections, tests, analyses, and acceptance criteria (ITAAC).

Please clarify how a determination will be made regarding changes to the Tier 2* information in the implementation plans using the examples given (which may or may not be applicable to the change being considered), or provide a clear threshold or set of criteria that will be applied to determine if a change is material. For example, one way to clarify this would be to add a statement to Enclosure 1 or the FSAR such as: All proposed changes that are not clearly encompassed by the examples of non-material changes shall be treated as material changes.

SNC Response to RAI Question LAR 17-037-5 The detailed guidance provided for Criterion 2 in Enclosure 1 of ND-17-1726 ND-1 is intended to provide clear guidance to be used when evaluating whether a proposed sed departure depart depa constitutes a material D

change to the affected Tier 2* information. While it would uld be SNC SNCs e expectation that relevant NRC Final Safety Evaluation Reports (FSERs) are reviewed eviewed ewed as papart of a proposed departure r

evaluation and that any alteration of a detail thatt served as the (0 aft conclusion would be considered material, SNC C proposes to cla Criterion 2 to add a bullet that any alteration of a detail u use used th basis for the NRCs safety clarify the detailed guidance for d as the basis for the NRCs safety 5- R determination constitutes a material change.

the sentence reading, A material change ge. Additionally, hange Addition Additionally n editorial change an ge affects a design proce c is made to move process output, or method of 17 e ethod of contro performing a design process, or method con tailed guidance.

under the heading for Criterion 2 detailed guidance.

gui ng g the des controlling design process, so that it is directly

-2 spo 7--037:

Changes to Original LAR-17-037:

01 n Changes to Enclosure 1 Add a fourth sub-bullet et to the bul bullet regarding egarding rding exam examples exa of material changes under Criterion 2 on

8) se Page 10 of 19, and revise the format mat of these examples, ex such that it reads:

cts a design A material change affects esign process proce output, o or method of performing a design process, or method of controlling the process.

e design pro proces x The following are examples amples o material changes:

of m n, or a o The addition, deletion, alteration of a design process step o Reconfiguration of design process steps o Departures from regulatory guidance related to the design process o Alteration of a detail that serves as the basis for acceptance in a Final Safety Evaluation Report (FSER) related to the affected design process

Southern Nuclear Operating Company ND-18-XXXX Enclosure XX D VEGP)

P) Units 3 and 4 Vogtle Electric Generating Plant (VEGP) r (0 aft 5- R Response to NRC Request for Additional Information ditional Inf rmation (RAI)

I ormation (RA LAR 17-037-6 17 e Regarding LAR-17-037 ding the LA LAR 7--037 Review Revi

-2 spo (LAR (L 17-037S3) 037S3)

(LAR-17-037S3) 01 n

8) se Supplement 3 changes that are added to the original LAR submittal are shown as blue-underlined text; deletions of original LAR text are shown as red strikethrough text.

(This Enclosure consists of xxxx pages, including this cover page.)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-6] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)-17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

Question:

10 CFR Part 50, Appendix B requires an applicant for a combined license to include in its final safety analysis report a description of the quality assurance applied to the design, and to be applied to the fabrication, construction, and testing of the structures, systems, and components of the facility and to the managerial and administrative controls to be used to assure safe operation.

The Vogtle UFSAR Section 13.5.1 describes administrative procedures that provide administrative control over activities that are important to safety for tthe operation of the facility.

censee inten of LAR 17-037 provides guidance for how the licensee in intends to implement a D

proposed license condition and exemption that providess an n alternative alterna departure evaluation r

process for Tier 2* information in the Vogtle UFSAR. The e licensee license would w use the guidance to (0 aft mption, ption, which implement the proposed license condition and exemption, whic would involve determining fety significance whether Tier 2* information to be changed has safety significan signi ce commensurate c with Tier 1 and requires prior NRC approval.

5- R The guidance in Enclosure 1 describes how, w, in applying applyin thehe proposed llicense condition criteria 17 e to proposed changes, the licensee would ould determine determ propo p

whether a proposed change requires prior NRC approval. The guidance includes des the specific specif c information spe informat to be considered by the licensee,

-2 spo including, for example:

x What constitutes a deviation viation iation fr m a code from code or stand standard (Criterion 1) x What constitutes a material aterial cha change e (Criteria 2 and 3) x What constitutes 01 n x What design processes ocesses esses wowou be considered would tutes an adverse adve e change adv conside nge (Criterion (Criter (C

b the licensee (Criterion 2) by 4)

8) se x What screens ns and debris de d c quantities are considered in debris screen design criteria (Criterion 4) subs substa The subcriteria listed above are substantive to the licensees eventual determination about equire prior NRC review and approval as Tier 2* information.

equires whether a proposed change requires However, the LAR does not propose changes to the UFSAR or License to include these subcriteria or provide a commitment by the licensee.

The staff requests the licensee to propose revisions to the UFSAR or the proposed license condition, or to provide a commitment, as appropriate, (1) to commit to a procedure that would be used to implement the Tier 2* departure evaluation process and (2) to identify the minimum information from Enclosure 1 that it is committing to in the LAR, or explain why a commitment to such information is not necessary.

SNC Response to RAI Question LAR 17-037-6 SNC plans to provide detailed guidance related to the use of the proposed Criteria to evaluate proposed Tier 2* departures in procedures used to determine if a proposed departure requires prior NRC approval. The guidance material will include, as a minimum, a restatement of the

Criteria contained in the associated license condition and detailed guidance and associated bases provided in Enclosure 1 of ND-17-1726. In response to the RAI provided above, SNC is proposing to add a commitment which would commit SNC to adding to existing procedures detailed guidance related to the application of the qualification criteria contained in the proposed license condition. Changes to the commitment or material affecting the commitment would be addressed through SNCs Commitments Management program.

Changes to Original LAR-17-037:

Changes to Enclosure 1 Add a new paragraph to the Detailed Description before the Licensing Basis Change Descriptions on Page 6 of 19 that reads:

To ensure the proposed qualifying Criteria reliably and predictably differentiate between Tier 2* information with safety significance commensurateensura sura with Tier 1 and other information that does not warrant the same level of control, ntrol, SNC SN is proposing a regulatory D

commitment that would require SNC to develop procedural edural guid g

guidance with a level of detail r

commensurate with the detailed implementation ation n guidance guidan and related bases for the (0 aft proposed Criteria contained in this LAR, including ncluding uding additional additio ad guidance provided by SNC in the supplements to this LAR. The he proposed propose regulatory egula gula commitment would be 5- R implemented prior to the implementation tion n of the license license e amendment amendm approving this LAR.

Add a new paragraph to the Technical Evaluation valuation after afte fter the he paragraph related to the regulatory 17 e orting on Page commitment regarding departure reporting P 144 of 19 that tha rea reads:

-2 spo The proposed regulatoryry commitment ommitm ommitment that hat would require re SNC to provide detailed procedural guidance related elated tto ho h

how ow the he qualifying criteria cr would be applied to proposed Tier 2* departures s ensures that t departures from fro Tier 2* information with a safety 01 n significance commensurate mmensurate ensurate with w Tier 1 will w require requ prior NRC approval.

Changes to Enclosure sure 8 Change the introductory

8) se ory paragraph pa raph aph on Page The following table identifies P

dentifies the statements in this submittal 2 of 2 to read:

th regulatory commitments in this document. Any other bmittal represent repr r intended or planned actions. They are provided for nd are information purposes and a not considered to be regulatory commitments.

Add a new regulatory commitment to the table on Page 2 of 2 as follows:

REGULATORY COMMITMENT DUE DATE / EVENT Develop procedural guidance that contains a description of the Implemented prior to the qualifying criteria contained in License Condition 2.D(13) and the implementation of the supporting detailed guidance and bases contained in the license amendment Technical Evaluation section of the approved LAR-17-037, approving this LAR

including additional guidance provided by SNC in the supplements to the LAR.

D r

(0 aft 5- R 17 e

-2 spo 01 n

8) se

Southern Nuclear Operating Company ND-18-XXXX Enclosure XX D VEGP)

P) Units 3 and 4 Vogtle Electric Generating Plant (VEGP) r (0 aft 5- R Response to NRC Request for Additional Information ditional Inf rmation (RAI)

I ormation (RA LAR 17-037-7 17 e Regarding LAR-17-037 ding the LA LAR 7--037 Review Revi

-2 spo (LAR (L 17-037S3) 037S3)

(LAR-17-037S3) 01 n

8) se Supplement 3 changes that are added to the original LAR submittal are shown as blue-underlined text; deletions of original LAR text are shown as red strikethrough text.

(This Enclosure consists of five pages, including this cover page.)

ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-7] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)-17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

Question:

As noted in SNCs license amendment request (LAR) (ML17355A416), SECY-17-0075, Planned Improvements in Design Certification Tiered Information Designations, (ML16196A321) describes how the purpose of the Tier 2* designation is to control certain information which the staff has determined to have safety significance commensurate with that of Tier 1 information.

NRCs letter dated January 25, 2018, which accepted the LAR for review (ML18019A362), stated cation do not clearly differentiate that the process criteria and guidance described in the application nsurate rate w between Tier 2* information with safety significance commensurate with Tier 1, and any Tier 2*

D ontrol rol. For example, information which does not warrant the same level of control. ex Criteria 2 and 3 e how controls address a material change, but do not clearly describe con on those changes ensure r

no modified without prior NRC information with safety significance commensurate with Tier 1 is not (0 aft review and approval.

Another example is the guidance for Criteria a 1, 2, and an 3,3 which includes inc statements that the 5- R process is intended to permit changes to achieve is not clear how SNC intends to determine rmine eve consistency consist cons ency ine that a Tier cy within the th document. However, it T er 2* change is appropriate to achieve 17 e formation outside consistency, when changing other information outs e the scope o scop of Tier 2* is more appropriate.

For example, if a discrepancy betweentween Tier 1 and Tier 2 2* is identified, changing Tier 2* is

-2 spo appropriate if Tier 1 is correct. How Ho ver, if Tier However, Tie 2** is correct, correct then th a Tier 1 change is needed.

Furthermore, Enclosure 5 identifies entifies th ategories of Tie the categories Tier 2* information the licensee plans to 01 n ocess. However, screen by the proposed process. H Ho ver, er, Enclosure nc 5 does not identify what portions of Tier 2*

errs to contain information it considers contai information conta formation matio that th has safety significance commensurate with Tier 1.

8) se Additionally, page 8 of the LAR was applied to the existing Tier R states ththat S significan signific ier 2* material.

m mate SNC performed an analysis of Tier 2* matters against afety significance.

several criteria, including safety However, it is not clear to the staff how this criteria ro Therefore, SNC is requested to provide a discussion of how the criteria described in the proposed amendment reliably and predictably differentiate between Tier 2* information with safety significance commensurate with Tier 1 and other information which does not warrant the same level of control.

SNC Response to RAI Question LAR 17-037-7 The purpose of the evaluation process used to develop the new criteria was to provide assurance that safety-significant changes to existing Tier 2* information would screen in for prior NRC review and approval. While a determination of safety significance was part of the process used to develop the criteria, SNC determined that a detailed analysis of all Tier 2* information in order to differentiate it into safety significance commensurate with Tier 1 information and Tier 2*

Page 2 of 5

ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3) information which does not warrant Tier 1 level control was not appropriate or even straightforward given the variability and inherent lack of specificity with which Tier 1 level information is defined.

The evaluation process used a multi-faceted approach to analyze broad categories of Tier 2*

information listed in 10 CFR Part 52, Appendix D, Paragraphs VIII.B.6.b and VIII.B.6.c. SNC reviewed available Commission Policy papers such as SECY-96-077, Certification of Two Evolutionary Designs, April 15, 1996 [ADAMS Accession No. ML003708129] and SECY 0075, Planned Improvements in Design Certification Tiered Information Designations, [ADAMS Accession Number ML16196A321] to better understand the bases behind the selection of Tier 1 information. SNC also reviewed existing certified Tier 1 DCDs to better understand the content and level of detail that should be contained in a Tier 1 DCD.

To support the analysis SNC used the introduction to the AP1000 000 Design P1000 D Control Document, D

Revision 19 [ADAMS Accession Number ML11171A303], which hich contains contain an index of AP1000 cont Tier 2 information requiring NRC approval for change (i.e.,

e., Tier 2*), to ccorrelate Tier 2* items listed r

in 10 CFR Part 52, Appendix D to applicable sectionsons of the Vogtle Vog V Electric Generating Plant (0 aft cument ment (DCD).

(VEGP) 3 and 4 Plant-specific Design Control Document (DC Each referenced section of the sessed VEGP 3 and 4 Plant-specific DCD was then assessed sed usin using th the ste steps described below.

x 5- R Is the Tier 2* information adequately DCD or VEGP 3 and 4 Combined ly addressed ddressed in the VEGP 3 and d License (COL)?

cense (COL a 4 Plant-specific Tier 1 included a review to determine

? This step inclu 17 e tandards, and the degree to which codes, standards, a design design sign and qualification qualif q processes, are relied upon for ITAAC acceptance criteria, but bu nnot the VEGP 3 and 4 Plant-specific ott specified in th

-2 spo Tier 1 DCD.

x Would changes in the e Tier 2*

2 information f

form ation be adequately adequ ade addressed by other applicable regulations, e.g., 100 CFR 50.46?

50.46 01 n x Would a change to the Tier 2* 2 information formation ormatio have safety-significance commensurate with a change to Tierr 1 information?

informati informat

8) se x Would a change han hange to the th Tier er 2* information inform informatio consistently and reliably require prior NRC approval using ng the evaluation e uationtion process pro defined d in 10 CFR Part 52, Appendix D, paragraph VIII.B.5?

Following the evaluation process cess described descr de above, SNC made the following conclusions:

x First, a set of Tier 2* information is already adequately addressed in Tier 1 and thus a change to this Tier 2* information, which would involve a change to the associated Tier 1 information, would require prior NRC approval. Therefore, neither an evaluation of safety-significance nor new evaluation criteria were considered necessary to provide assurance that changes would receive prior NRC approval.

x Second, for another set of Tier 2* information it was concluded that a change to this information would not have safety-significance commensurate with a change to Tier 1 information. Thus, new evaluation criteria were not considered necessary for this set of Tier 2* information.

x Third, it was determined that a change to a third set of Tier 2* information would require a prior NRC approval under 10 CFR Part 52, Appendix D, paragraph VIII.B.5 or another regulation in a consistent and reliable manner. Thus, it was concluded that the evaluation criteria currently provided in 10 CFR Part 52, Appendix D, VIII.B.5.b or VIII.B.5.c are Page 3 of 5

ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3) adequate to reliably and consistently address changes to this information and new evaluation criteria to address changes to this information were not necessary.

For those instances where a change to the Tier 2* information was considered safety-significant and a prior NRC approval would not reliably and consistently be triggered through either the Tier 1 change control processes, the evaluation process under 10 CFR Part 52, paragraph VIII.B.5, or through another regulation, SNC performed a more in-depth review of the information to develop new evaluation criteria. The purpose of the new evaluation criteria is to provide assurance that safety-significant changes to this non-qualifying Tier 2* information would reliably and consistently require prior NRC review and approval.

Based on the above analysis, a set of new evaluation criteria was developed that would be used to screen for the critical safety aspects of these Tier 2* matters to de determine whether a proposed departure from Tier 2* could qualify to be evaluated under the he departu depar departure evaluation process for D

Tier 2 departures outlined in paragraph VIII.B.5. These new ewwe evaluation valuat criteria are provided in of LAR-17-037.

Regarding Enclosure 5, it was not intended that this his enclosure enclos identify what portions of Tier 2*

(0 information were considered to contain information tion ination with Tier 1. As stated earlier, while a determination n that has ha safety on of safety s

afety afet significance commensurate significan was part of the process significance 5- R used to develop the criteria, SNC determined ned that a detailed ty significance order to identify what portions had safety deta de ed analysis of ignificance commensurate commensurate mensurate with o all Tier 2* information in w Tier 1 information was 17 e not necessary or appropriate. Enclosureure 5 only provides provides a summary p summ o of the results of the evaluation process described above.

-2 spo AR R-17 17-0 will of the original LAR-17-037 w bee revised vised as shown sh below to incorporate the above ed to develop clarification of the process used dev p the new evaluation evalu eva criteria.

01 n Changes to Originall LAR-LAR -17 7-03 LAR-17-037:

8) se sure 1:

Changes to Enclosure 1:

Revise the first two paragraphs aphs phs on Page Pag 8 of 19 of the original LAR-17-037 to read as follows:

alysis of the Tier 2* matters listed in 10 CFR Part 52, Appendix D, SNC performed an analysis B 6 and B.6.c. The analysis examined each item in terms of the Section VIII paragraphs B.6.b following criteria:

x Is the Tier 2* information adequately addressed in the VEGP 3 and 4 Plant-specific Tier 1 DCD or VEGP 3 and 4 Combined License (COL)? This step included a review to determine the degree to which codes, standards, and design and qualification processes, are relied upon for ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1 DCD.

x Would changes in the Tier 2* information be adequately addressed by other applicable regulations, e.g., 10 CFR 50.46?

x Would a change to the Tier 2* information have safety-significance commensurate with a change to Tier 1 information?

Page 4 of 5

ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3) x Would a change to the Tier 2* information consistently and reliably require prior NRC approval using the evaluation process defined in 10 CFR Part 52, Appendix D, paragraph VIII.B.5?

x Degree to which the Tier 2* information is not addressed in the following but meets Tier 1 inclusion criteria:

o VEGP 3 and 4 Plant-specific Tier 1 Design Control Document (DCD), or o VEGP 3 and 4 Combined License (COL), or o Applicable regulations, e.g., 10 CFR 50.46 x Degree to which Codes, standards, and design and qualification process, are relied upon for ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1 DCD x Safety-significance x Degree to which 10 CFR Part 52, Appendix D, Sectio Section VIII.B.5 would effectively D

evaluate a Tier 2* departure r

Following the evaluation process described above,ove, SNC made m the following conclusions (0 aft regarding 11 of the 24 Tier 2* matters listed ed in n 10 CFR CF Part P 52, Appendix D,Section VIII paragraphs B.6.b and B.6.c:

x 5- R First, a set of Tier 2* information thus a change to this Tier mation n is alread already alrea y adequately a er 2** information, informatio informa , which hich would ad addressed in Tier 1 and wou involve i a change to the 17 e associated Tier 1 information, neither an evaluation ormation, would wo require n of safety-significance safety safety-sig equire prior prio NRC nificance nor n new NR approval. Therefore, ne evaluation criteria were

-2 spo considered necessary essa to essar o provide provide assurance p ssurance that tha changes would receive prior NRC approval. al.

x Second, for or another se set off Tier 2* info informa information it was concluded that a change to 01 n this information rmation ation would to Tierr 1 informati wou not information. Thus, ot have safety-significance safety sa s, new eval ev commensurate with a change evaluation criteria were not considered necessary

8) se for this his set of TTier 2** informatio information.

x Third, it was determined termined ermined that a change to a third set of Tier 2* information would require a prior or NRC approvapp approval under 10 CFR Part 52, Appendix D, paragraph VIII.B.5 or another nother regula re regulation g in a consistent and reliable manner. Thus, it was concluded that at the evaluation ev criteria currently provided in 10 CFR Part 52, Appendix D, VIII.B.5.b III.B.5 B or VIII.B.5.c are adequate to reliably and consistently address changes to this information and new evaluation criteria to address changes to this information were not necessary.

Based on the results of the analysis, 13 of the 24 Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c were determined to be adequately covered by existing Tier 1 information, covered by another regulation or the combined license, or did not rise to the level of Tier 1 safety significance. The remaining 131 of the 24 Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c were selected for development of additional screening criteria that would determine whether an associated Tier 2* departure qualifies for the departure evaluation process outlined in 10 CFR Part 52, Appendix D, Section VIII.B.5. A summary of the analysis is provided in Enclosure 5. The selected matters are:

Page 5 of 5

Southern Nuclear Operating Company ND-18-0xxx Enclosure X Dra ant nt (VEG Vogtle Electric Generating Plant (VEGP) U nits 3 and 4 Units (0 ft 5- re 21 sp Response to NRC Req Request Additional e est for A Ad itional Information (RAI) 17-037-8 al Infor Informa

-2 on Regarding Regardin the LAR-17-037 e LAR-17 LAR 17-037 Review R

01 se ((LAR-17-037S3)

(LAR -17 7-037 03 8)

Supplement 3 changes to the original LAR text are shown as blue-underlined text; deletions of original LAR text are shown as red strikethrough text.

(This Enclosure consists of four pages, including this cover page.)

ND-18-0xxx Enclosure X Response to NRC RAI LAR-17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-8] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

RAI Question LAR 17-037-8 10 CFR Part 52, Appendix D, Section VIII.B.6.b states, in part, that an applicant who references this appendix may not depart from the Tier 2* matters without prior NRC approval. In the LAR 037 submittal, Page 9 of Enclosure 1 states that Criterion 2 was developed as a screening criterion as a result of the analysis performed that was related to Tier 2* matters, which include, among other things, instrumentation and control (I&C) system design processes, methods, and standards. As mentioned in the LAR 17-037 submittal, the proposed Criterion 2 is to be used to screen material changes to the design processes for the followingng two tw I&C systems:

x x

D Diverse Actuation System (DAS)

Protection and Safety Monitoring System (PMS) ra The Vogtle Units 3 and 4 UFSAR designates only the he follow following technical echnical or o topical reports, as a (0 ft whole, as Tier 2* items for I&C:

x 5- re WCAP-17201-P, AC160 High Speed ed d Link Communication Staff Position 9, 12, 13, and 15, Rev. 0 Com Co munication unication Com C

Compliance to DI&C-ISG-04 x

21 sp WCAP-15927, Design Process ss for AP1000 AP1000 Common AP ommon Q Safety Sa Systems, Rev. 2

-2 on x WCAP-17179, AP1000 00 Component 0 Compo Com ent Interface en I terface Module Technical Report, Rev. 2 rface Modu x WCAP-16097-P-A, A, Common Qualified Common Q fied Platform, ified Platform Rev. 0 x WCAP-16096-NP-A, 01 se Software Program Manual NP--A, Soft Softw Manu for Common Q Systems, Rev. 01A Ma Question 1 8)

Although the Component Interface nterface terface Modu WCAP-17 WCAP under the PMS description, WCAP-17179 M

Module (CIM) design process is briefly discussed in Tier 1 states that the CIM interfaces with the PMS and other systems, indicating that it is separate se from the PMS. In addition, the CIM design process is different from that for the PMS. The licensee is requested to identify the CIM design processes as among those considered under Criterion 2 by explicitly listing them as examples under that criterion, or explain why this is unnecessary.

SNC Response to RAI Question 1 Because the CIM provides the priority logic between the PMS and other systems, CIM is often addressed in association with PMS, and in fact, the CIM is addressed in Tier 1 Section 2.5.2, Protection and Safety Monitoring System. So, for simplicity, the guidance and bases provided in Enclosure 1 to SNC letter ND-17-1726 (LAR-17-037) did not specifically call-out the CIM separate from the discussion provided for the PMS. However, SNC concurs that the CIM could be addressed in a separate bases discussion, similar to that provided for other elements of Tier 2* information covered by Criterion 2 of the proposed License Condition. It is worth noting that there is only a minimal, high-level discussion of the CIM development information Page 2 of 4

ND-18-0xxx Enclosure X Response to NRC RAI LAR-17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3) in Tier 2* document WCAP-17179, and there is a very low likelihood that this information will be changing at this point in the plants design/construction. Because the evaluation of changes to the design process applicable to PMS and the CIM would follow a similar approach, the basis for an evaluation of changes to the CIM design process would be consistent with that already provided for changes to the PMS design process in ND-17-1726, Enclosure 1.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-8, Question 1:

Changes to Enclosure 1:

Add the following to the detailed description and bases for Criterion 2 on pages 10 and 11 of 19:

Criterion 2 (Design Processes) Bases:

DCD are: D The design processes addressed in the VEGP 3 and ra nd d 4 Plant-sp Plant Plant-specific Tier 1 DCD and for VEG 3 and 4 plant-specific Tier 2 which some Tier 2* information is contained in the VEGP x

(0 ft Diverse Actuation System (Plant-specific Tier 2 DCD, Chapter 7);

specific Tier T 1 DCD, Section Sec on 2.5.1; Plant-specific x

5- re oring Protection and Safety Monitoringing System Syste (Plant-specific Plant-specific Tier 2 DCD,, Chapter 7);

Plant-specific Plant specif Tier Tie 1 DCD, Section 2.5.2; x

21 sp specific Tier 2 DCD, CD, D Chapter hapter 7

(

(Pla Component Interface Module (Plant-specific 7);

specific pecific Tier Tie 1 DCD, Section 2.5.2; Plant-

-2 on x Human Factors s Engineering Enginee Engin ng (Plant-specific ng (P ant nt--specific Tier T 1 DCD, Section 3.2; Plant-specific Tier 2 DCD, Chapter 18);

hapter 18)

While paragraph 01 se Diverse Actuation ion System (DAS) raph B.5.b a

( S))

allowss changes to design de processes without prior NRC approval at the design provided that 8) desig function a

criterion does not allow unction is not n more ch m

any material change onitoring System onito Protection and Safety Monitoring S than minimally adversely affected, this new to a design process.

(PMS)

UFSAR Tier 2* information relarrelated ela to PMS is contained in Westinghouse WCAP reports that are incorporated by reference into the UFSAR. For the PMS, departures related to a design process as described in Westinghouse WCAPs may not be easily evaluated against the eight criteria of paragraph B.5.b; therefore, some departures may not receive prior NRC approval as required. The application of proposed Criterion 2 assures that any material departure related to PMS design processes receives prior NRC approval.

Component Interface Module (CIM)

UFSAR Tier 2* information related to the CIM is contained in WCAP-17179-P (Proprietary) and WCAP-17179-NP (Non-Proprietary), which are incorporated by reference into the UFSAR. For the CIM, departures related to a design process as described in WCAP-17179-P/NP may not be easily evaluated against the eight criteria of paragraph B.5.b; therefore, some departures may not receive prior NRC approval as required. The application of proposed Criterion 2 assures that any material departure related to the CIM design processes receives prior NRC approval.

Page 3 of 4

ND-18-0xxx Enclosure X Response to NRC RAI LAR-17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

Question 2 The design process for the DAS is covered in Tier 1 Section 2.5.1. The staff is not aware of any Tier 2* information governing the DAS design process. However, the staff notices that there is a discussion in the LAR on changes to the DAS design process. The licensee is requested to clarify how changes to the DAS design process will receive prior NRC approval.

In particular, identify the DAS design process information that is designated as Tier 2*

information.

SNC Response to RAI Question 2 D

Tier 2* incorporated by reference document, WCAP-17179, ra 17179, Module Technical Report, addresses aspects of DAS relate Specifically, Section 2.9 discusses the application 7179, AP1000 AP AP1 Component Interface related tto tthe DAS design process.

on of the various va ousus aspects as of diversity (i.e.,

(0 ft ns, s, signals, diversity in design, equipment, function, humans, signal and and d software) software in the design of the CIM and DAS.

follows: 5- re d to DAS is Additionally, Tier 2* information related i found f und in UFSAR UFS Subsection 7.7.1.11, as 21 sp nc n of the di

[The manual actuation function erse actuat diverse actuation io ssystem is implemented by hard-

-2 on ated ted in the wiring the controls located th main m ntrol room directly control dire d to the final loads in a way that completely bypassess the he normal norma path h through the t protection pro and safety monitoring system 01 se cabinets, and thee diverse erse actuation actu act n system sy sys tem automatic autom aut logic.]*

A material changege regarding the hard-wiring hard wiring aspect asp a of the design as described in this Tier 2*

8) ction 7.7.1.

UFSAR Subsection 7.7.1.1 directly associated with the further evaluation under the xt would b 7.7.1.11 text aspec of proposed design process aspect Lice be scr roposed License Licens e design features featur fe e requirements requir requirem screened as a Tier 2* change, but may not trip the Condition 2.D.(13)(a)2, because this text is more of the system, rather than the design process. A of 10 CFR Part 52, Appendix D, paragraph B.5 term would then be performed to determine if the change would require prior NRC approval of the change as a result of the responses to the paragraph B.5.b and B.5.c questions.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-8, Question 2:

None.

Page 4 of 4

Southern Nuclear Operating Company ND-18-0xxx Enclosure X Vogtle Electric Generating Plant (VEGP) Units 3 and 4 D

r Response to NRC Request for Additional (0 aft onal Regarding the LAR Information (RAI) 17-037-9 al Inform Informati LAR-17-037 R-17 Review 17--037 Re view ew 5- R (LAR-17-037S3)

LAR--17 17--037 037S )

17 e

-2 spo 01 n

8) se Supplement 3 changes to the original orig origi LAR text are shown as blue-underlined text; deletions of original LAR text are shown as red strikethrough text.

(This Enclosure consists of eight pages, including this cover page.)

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following were questions provided by the NRC Staff [Request for Additional Information (RAI) [LAR 17-037-9] regarding the review of Southern Nuclear Operating Company (SNC)

License Amendment Request (LAR)17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

RAI Introduction The scope of Tier 2* information of the AP1000 certified design is defined in 10 CFR Part 52 Appendix D Sections VIII.B.6.b and VIII.B.6.c, which state that changes to Tier 2* will be treated as a request for a license amendment and require staff review and approval prior to implementation. SECY-17-0075, Planned Improvements in Design Certification Tiered Information Designations, (ADAMS Accession No. ML16196A321) states that Tier 2*

information has safety significance commensurate with that of Tier 1 information and would have received the Tier 1 designation, except that NRC decided ed to provide prov pro more flexibility for this D

nsideratio associated with the final type of information. Per the SECY and the statements of consideration rule for Part 52 (72 FR 49352, Licenses, Certifications and d Approvals Approv f Nuclear Power Plants, for r

p.49365, August 28, 2007), the purpose of the Tier 2** designation esignation is to control certain (0 aft information which the staff has determined to have e safety afety significance sig signific commensurate with that ficance, ance, the Tier of Tier 1 information. Consistent with this significance, Tie 2 2* cchange process ensures that ner (e.g.

the information is controlled in a similar manner e.g. changes chang c s to such information require prior 5- R staff review and approval).

Question 1 17 e

-2 spo of LAR-17-037 contains ontains ntains the t e proposed p

pro osed revision revisio to COL license condition 2.D which includes a new condition. This is new condition co on governs the desired departures from plant-specific ion 01 n DCD Tier 2* information and nd states that t SNC wo would be exempt from the requirements of endix D, Pa 10 CFR Part 52, Appendix Par aphss II.F and VIII.B.6 Paragraphs V that invoke the Tier 2* change process. Among the he provisions provision of the new condition conditi con is that the exemption from the current

8) se Tier 2* change processess would wou apply wo pply ply except exce for departures from Tier 2* information that would al cchange

. . . Result in a material ge to the fu fuel ccriteria evaluation process . . .

ctric ric Generat Section 5.6.3 of Vogtle Electric Gene Generating Plant (VEGP) Units 3 and 4 Technical Specifications ment for provides the reporting requirement fo the Core Operating Limits Report (COLR).

aly Section 5.6.3(b) provides the analytical methods used to determine the core operating limits and states that these methods shall be those previously reviewed and approved by the NRC.

WCAP-12488-P-A, Fuel Criteria Evaluation Process, is not included in the methods listed in Section 5.6.3(b) of technical specifications; however, it is not clear to the staff whether WCAP-12488-P-A is integral to any of the listed methodologies.

Please confirm that WCAP-12488-P-A is not referenced within any of the approved methodologies listed in Technical Specification Section 5.6.3(b) or provide justification that would demonstrate that the proposed departure process as presented in LAR-17-037 couldnt lead to a change in a methodology as listed in the COLR without requiring NRC approval.

SNC Response to RAI Question 1 2 of 8

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

The proposed changes to the Tier 2* evaluation process described in LAR 17-037 do not affect the Technical Specifications change control process requirements specified in 10 CFR Part 52, Appendix D, VIII.B.5.a or the specific Technical Specifications requirements in Section 5.6.3 for changes to analytical methods used to determine the core operating limits in the Core Operating Limits Report (COLR). Any changes to the documents listed in Technical Specifications Section 5.6.3.b require prior NRC approval. If WCAP-12488-P-A were referenced in any of these documents, changes to WCAP-12488-P-A would also require a change in the document that references it and thus require prior NRC approval. Nevertheless, a review of the references listed in Technical Specifications 5.6.3(b) was performed and confirmed that WCAP-12488-P-A is not referenced in any of the Technical Specifications COLR reference documents.

Therefore, the proposed departure process as presented in LAR-17-037 could not lead to a ating llimits (i.e., the documents change in analytical methods used to determine the core operating taining ng prior listed in Technical Specifications Section 5.6.3.b) without obtaining prio pr NRC approval.

D Changes to Original LAR-17-037 in response to RAI LAR AR--17 17-037 0 9 Question 1 LAR-17-037-9, None Question 2 r

(0 aft 5- R Item (1) of 10 CFR Part 52 Appendix D,, Section ection VI VIII.B VIII.B.6.b 6.b covers th the m maximum rod average fuel 17 e he methods contained burnup. Additionally, the validity of the co tained ained in referenced re refere topical report pproval for WCAP-12488-P-A and the staffs approval fo this th topical report re a based upon the are

-2 spo burnup-dependent empirical fuel el performance pe ormance orma odels models. of LAR-17-037 37 contains the th proposed roposed revision revisio to COL license condition 2.D which rev 01 n includes a new condition. n. This new condition ndition dition governs gov the desired departures from plant-specific DCD Tier 2* informationtion and states stat that hat SNC would wou be exempt from the requirements of

8) se ppendix D, P 10 CFR Part 52, Appendix agraphs II.F and VIII.B.6 that invoke the Tier 2* change Paragraphs process. The exemption ption from fro the fr hee current curren Tier 2* change process would apply except for departures from Tier 2** information in mation ation that, Result Re in a material change to the . . . maximum fuel rod average burn-up limits . . .. How However However, the staff notes that Enclosure 1 of LAR-17-037 whic states provides guidance (Criterion 3) which s that [a] material change is any change that would have an effect on maximum fuel el rod average burn-up limits. The staff is concerned that the wording in Enclosure 3 does not reflect the guidance provided in Enclosure 1 and could lead a screener to interpret that some changes to rod average burn-up limits could be made without requiring prior staff review and approval.

Please revise Enclosure 3 to clarify whether any changes to maximum fuel rod average burn-up limits are excluded from this departure.

SNC Response to RAI Question 2 Proposed Criterion 3 in Enclosure 3 of the original LAR 17-037 will be revised to require prior NRC approval for any changes to maximum fuel rod average burn-up limits.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 2 3 of 8

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

Changes to Enclosure 1:

Change the detailed guidance for Criterion 3 on Page 11 of 19 to read as follow:

x A material change is Any change to the that would have an effect on maximum fuel rod average burn-up limits requires prior NRC approval.

Changes to Enclosure 3:

Revise Criterion 3 as follows:

3. Result in a material change to the fuel criteria evaluation io process, the fuel principal design requirements, or nuclear design of fuel and reactiv activ control system,; or result reactivity in any change to the maximum fuel rod average burn-up burn--up limits, limi or lim D

(Additional changes, not shown here, are made to Criterion erion on 3 in respo re response to Question 6 below.)

r Similar conforming changes are also applicable to Enclosures closures 1, 44, and 5 of the original LAR-(0 aft 17-037.

Question 3 5- R 17 e of LAR-17-037 providess detailed guidance anges and what are not considered material changes guida gu nce an would ce for Criterion would therefore theref ite 3 and contains examples of n require prior NRC review not

-2 spo min mi r corrections and approval. The list includes minor correct onss to drawings co drawin and figures (e.g., correcting mislabeled components)." It iss unclea unclea to unclear o the t e staff what dra d

drawings and figures this refers to since ovided ded in FSA the Tier 2* information provided FS ections 4.2, FSAR Sections 4.2 4.3, 4 and 4.4 does not include any drawings or figures.

01 n

8) se license to clarify The staff requests the licensee clarify which Tier Ti 2* drawings and figures the guidance is ct the Criterion referring to, or correct C rion n 3 guidance gui to only refer to relevant examples specific to the er Tier 2* information governed by Criterion 33.

stion 3 SNC Response to RAI Question The reference in the Criterion 3 detailed guidance to minor corrections to drawings and figures was inappropriate, since there are no applicable figures or drawings in the UFSAR that are Tier 2*. Enclosure 1 of the original LAR-17-037 will be revised to remove this reference.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 3 Changes to Enclosure 1:

Revise the detailed guidance for Criterion 3 on Pages 10 and 11 of 19 as follows:

The following examples are not material changes:

o Editorial Changes 4 of 8

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) o Clarifications to improve reader understanding o Correction of inconsistencies within the document which are clearly discernible (e.g., between sections) o Minor corrections to drawings and figures (e.g., correcting mislabeled components) o Changes that do not change the meaning or substance of information presented (e.g., reformatting or removing detail)

Question 4 In Enclosure 1, the detailed guidance for Criterion 3 contains examples of what are not considered material changes. The list includes "[c]hanges that do nonot change the meaning or ving detail) substance of information present (e.g., reformatting or removing detai detail)." The staff disagrees D

aning that removing detail does not necessarily change the meaning ng or sub substa substance of information.

r e in Enclosure The staff requests the licensee to revise the guidance Enclosu 1 to clearly indicate when (0 aft removing detail would not require NRC approval.

SNC Response to RAI Question 4 5- R The intent of the referenced guidance was to exclude exclud from rom m the definition definitio defin of a material change 17 e those changes that are similar to those se described describe in NRC-endorsed NRC--endorsed NRC endo guidance NEI 98-03, Saf Revision 1, Guidelines for Updating Final Safety Report R

Analysis Reports, Section A4, Simplifying

-2 spo Updated FSAR Information. This his N NEI guidanc gu guidance e describes escribes cert ccertain changes to Part 50 nuclear nformation ormatio contained plant UFSARs that simplify information contained ined in the UFSAR UFS U to improve its focus, clarity and emoving oving excessive maintainability, such as removing exce ve e detail, obsolete obsole bs information, or redundant 01 n uidance ance state information. The NEI guidance hat at because states that becau these the changes are not the result of changes dures they do to the plant or procedures d notot require quire evaluation eva evalua under 10 CFR 50.59. While plants

8) se licensed under 10 CFR Part 5 52 aree not no n t permitted permitt to make any changes to the plant-specific DCD Tier 2 informationon (i.e.

(i.e FSAR)

AR) wit (i.e., UFSAR) without pperforming the evaluations required by 10 CFR Part 52, Appendix D (foror AP1000 A 000 plants),

plants) Section Se VIII.B.5, this NEI guidance was considered pplication plication of the applicable in defining the application th term material change in the context of this proposed evaluation process. s To clarify this section of the Criterion 3 guidance, Enclosure 1 to the original LAR-17-037 will be revised to add a reference to NEI 98-03 regarding removing detail.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 4 Changes to Enclosure 1:

Revise the detailed guidance for Criterion 3 on Pages 10 and 11 of 19 as follows (includes changes made in response to Question 3 of this RAI):

The following examples are not material changes:

o Editorial Changes 5 of 8

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) o Clarifications to improve reader understanding o Correction of inconsistencies within the document which are clearly discernible (e.g., between sections) o Minor corrections to drawings and figures (e.g., correcting mislabeled components) o Changes that do not change the meaning or substance of information presented (e.g., reformatting or removing detail as described in NEI 98-03, Revision 1, Guidelines for Updating Final Safety Analysis Reports, Section A4 [ADAMS Accession Number ML003779028]).

Question 5 of LAR-17-037 provides guidance for Criterion 3 to help d di distinguish which changes D

could be made without requiring prior staff review and approval.

proval.

val. The gu guidance includes the statement [a] material change to a design would be anyy change that t has an adverse effect on a r

design function." The staff notes that no definition is provided clarify what types of changes vided to cla (0 aft would be considered "adverse." Additionally, it is unclear clear if the th teterm design function refers to the design criteria presented in WCAP-12488, or iff a different differe definition efin was intended.

5- R The staff requests the licensee to provide a definition efinition for f adverse verse and design function to adverse clarify the guidance provided in relation to Criterion 3 iin Enclosure nclosure 1 and an assist the reader in 17 e determining if a particular change to a Tier 2* item ite would would be considered con conside material, thereby requiring prior staff review and approval.

roval.

-2 spo SNC Response to RAI Question stion tion 5 01 n The application of the terms erms ms advers adverse andnd design desig function fun as used in the guidance discussions in Enclosure sure 1 of the original ginall LAR-17-037 LAR LAR-17 7-03 is derived from the use of the same terms

8) se in NRC-endorsed guidance NEI N 96-07, NE Revision 1, Guidelines For 10 CFR 50.59 6--07, Revisio er to foo Implementation (refer e 6 on Pa footnote Page 12 of 19 in Enclosure 1 of the original LAR 17-037).

This NEI guidance provides vid an n extensive disdiscussion regarding how to evaluate whether a change adversely affects a design fufunction. The term design function is defined in NEI 96-07 functio as follows (from Section 3.3 of NEI 96-07):

9 96 Design functions are UFSAR-described design bases functions and other SSC functions described in the UFSAR that support or impact design bases functions.

Implicitly included within the meaning of design function are the conditions under which intended functions are required to be performed, such as equipment response times, process conditions, equipment qualification and single failure.

Design bases functions are functions performed by systems, structures and components (SSCs) that are (1) required by, or otherwise necessary to comply with, regulations, license conditions, orders or technical specifications, or (2) credited in licensee safety analyses to meet NRC requirements The use of the term design function in the guidance was not intended to directly refer to the design criteria presented in WCAP-12488.

6 of 8

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

While it is not the intent of the LAR guidance to include the volume of the information contained in NEI 96-07 regarding the application of these terms, Enclosure 1 of the original LAR-17-037 will be revised to expand the reference to NEI 96-07 to clarify the use of the terms adverse and design function.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 5 Changes to Enclosure 1:

Revise footnote 6 on Page 12 of 19 to read as follows:

The use of the terms adverse and design function n as used in the guidance D

discussions is derived from the use of the same terms ermss in NEI 96-07, 96 Revision 1, Guidelines For 10 CFR 50.59 Implementation [ADAMS DAMS Ac Acces Accession Number r

ML003771157]. This NEI guidance provides (0 aft evaluate whether a change adversely affects function is defined in NEI 96-07, Section s ann extensive extensiv d discussion regarding how to ects a design function.

on 3.3.

func The term design 5- R 17 e Question 6

-2 spo The staff reviewed the proposed departure d parture evaluation eval ation process ev proce outlined o in LAR-17-037, including the Reviewers Aids in Enclosure ure 4 aand Enclosure dE Enclosure e 5.

5 The he staff sta notes that there are no proposed screening criteria for changes es to Tier 2*

2 information formation rmation associated associ ass with small-break loss-of-coolant accident (LOCA) analysis s method ethodolog ol methodology. Due to th the uniq uniqueness of the AP1000 design the staff 01 n determined the use of the e NOTRU NOTRUMP code n Chapter 15 Tier 2* information in 1 (two de to be acceptable, wo paragraphs ragra acc in part, because of the identified in Sections 15.6.5.4B.2.2 and 15.6.5.4B.2.3).

8) se oce NEI 96-07 ocess Under the 50.59 process 07 allows chan changes to methodology input parameters; however, er 2* information the staff considers Tier i mation associated as associa with NOTRUMP homogeneous sensitivity model and critical heat flux assessment du during accumulator injection to be safety significant and ethodology thodolog as approved for the AP1000. Therefore, the staff an integral aspect of the methodology maintains that any changes to o tha information would involve a departure from a method of that inf evaluation described in the FSAR AR R and a require prior NRC review and approval. Had Tier 2* not existed at the time of approval of the AP1000 design, the information related to the NOTRUMP methodology would have either been designated Tier 1 or a change to the approved topical report would have been necessary.

The staff requests that additional screening criteria be included in the Tier 2* departure evaluation process that captures the critical safety aspect of the Tier 2* information for small-break LOCA analysis methodology, and identify that any changes (material or otherwise) to those Tier 2* items must undergo NRC review and approval as a change to the methodology.

SNC Response to RAI Question 6 7 of 8

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

Proposed Criterion 3 will be revised as follows to capture the critical safety aspect of the Tier 2*

information for small break LOCA analysis methodology.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 6 Changes to Enclosure 1:

Add the following new paragraph at the end of the bases discussion for Criterion 3 on Page 12 of 19:

Due to the uniqueness of the AP1000 design, the use of the NOTRUMP code is considered acceptable, in part, because of the identified Tier 2* information in Chapter 15 (two paragraphs in Subsections 15.6.5.4B.2.2 and 15.6.5.4B.2.3).

5.6.5. The Tier 2*

information associated with NOTRUMP homogeneous us sensitivity sensitivit ensitiv model and critical heat D

flux assessment during accumulator injection is considered onsidered idered to be safety-significant and an integral aspect of the methodology as approved vedd for for the AP1000.

AP Therefore, any r

changes to that information would involve a departure arture from fr a method of evaluation (0 aft described in the FSAR and require prior NRC RC review and approval.

5- R Changes to Enclosure 3:

Revise Criterion 3 as follows (includes changes made ma in response esponse to RAI LAR-17-037-9 Question 2):

17 e

-2 spo

3. Result in a material chan change cha e to the fuel evaluation uel criteria evalu ev process, the fuel principal design requirements,ts, or nuclear ents, nu ar design of fue and reactivity control system,; or result fuel a in any change to the maxim maximum fuel rod avera average burn-up limits; or result in any Subsections 01 n change to small mall all break LOCA ons 15.6.5.4 L

15.6.5.4B.2.2 A analysis meth methodology described in UFSAR 2 or 15.6.5.4B.2.3; 15.6.

15.6.5.4B. or 037.

Changes to Enclosure 5:

8) se Similar conforming changes hange are hanges e also lso applicable app applicab to Enclosures 1 and 4 of the original LAR Revise the table entry for small-break loss-of-coolant accident (LOCA) analysis methodology on Page 3 of 6 to read as follows:

6 Small-break loss-of- No Yes 10 CFR 50.46 and N/A Result in any coolant accident adequately change to small break (LOCA) analysis addressed by LOCA analysis methodology. paragraph VIII.B5 methodology described Safety significance in UFSAR Subsections 15.6.5.4B.2.2 or 15.6.5.4B.2.3.

8 of 8