ML18149A371
| ML18149A371 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/29/2018 |
| From: | NRC |
| To: | NRC/NRO/DNRL/LB4 |
| References | |
| Download: ML18149A371 (6) | |
Text
1 Vogtle PEmails From:
Gleaves, Bill Sent:
Tuesday, May 29, 2018 8:23 AM To:
Vogtle PEmails Cc:
Hoellman, Jordan
Subject:
FW: Draft RAI No. 2 - LAR-17-024 Attachments:
Vogtle LAR-17-024 Draft RAI No. 2, 3Qs.docx Attached is email transmitting draft RAI No. 2 from NRC to SNC on LAR-17-024 for entry into public ADAMS.
Billy William (Billy) Gleaves Senior Project Manager Licensing Branch 4 Office OWFN 8H17 US NRC, Office of New Reactors The contents of this message may be sensitive. If this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Do not disseminate this message without the permission of the author. Communications by this author are not binding on The Commission.
From: Hoellman, Jordan Sent: Thursday, May 24, 2018 12:29 PM To: Henderson, Ryan Donald <RDHENDER@SOUTHERNCO.COM>
Cc: Haggerty, Neil <X2NHAGGE@SOUTHERNCO.COM>; Patel, Chandu <Chandu.Patel@nrc.gov>; Kallan, Paul
<Paul.Kallan@nrc.gov>; Gleaves, Bill <Bill.Gleaves@nrc.gov>; Sparkman, Wesley A. <WASPARKM@southernco.com>
Subject:
Draft RAI No. 2 - LAR-17-024 Hi Ryan -
Attached is draft RAI No. 2 related to Vogtle Units 3 and 4 LAR 17-024. There is one other RAI that will be sent separately.
If you would like to schedule a clarification call to discuss this RAI, please let us know. Otherwise, we will issue this RAI as final.
Thank you, Jordan Jordan Hoellman Project Manager NRO / DNRL / LB4 U.S. Nuclear Regulatory Commission office: OWFN 08-C18 phone: (301) 415-5481 email: Jordan.Hoellman2@nrc.gov
Hearing Identifier:
Vogtle_COL_Docs_Public Email Number:
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FW: Draft RAI No. 2 - LAR-17-024 Sent Date:
5/29/2018 8:22:49 AM Received Date:
5/29/2018 8:22:53 AM From:
Gleaves, Bill Created By:
Bill.Gleaves@nrc.gov Recipients:
"Hoellman, Jordan" <Jordan.Hoellman2@nrc.gov>
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CY1PR09MB0908.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1539 5/29/2018 8:22:53 AM Vogtle LAR-17-024 Draft RAI No. 2, 3Qs.docx 27101 Options Priority:
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1 DRAFT Request for Additional Information #2 Vogtle 3 & 4 LAR-17-024 Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes Issue Date: 05/XX/2018 Operating Company: Southern Nuclear Operating Co.
Docket No.52-025 and 52-026 Application Section: Technical Specifications This request for additional information relates to SNCs application for license amendment request (LAR)17-024, titled, Technical Specification Updates for Reactivity Controls and other Miscellaneous Changes, dated July 28, 2017 (ML17209A755) as supplemented January 23 and March 23, 2018 (ML17209A755 and ML18082B370, respectively). By this request, the staff is informing SNC that it requires additional information in order to complete its review.
Title 10, Energy, of the Code of Federal Regulations (10 CFR) Section 50.90, Application for amendment of license, construction permit or early site permit, requires, in part, that a license amendment fully describe the changes desired. However, the information within the technical evaluation presented in Item L07 of LAR-17-024 is insufficient for the staff to reach a conclusion on the application. After considering multiple relevant sources of information provided in previously docketed material that the application did not reference in the technical evaluation, the staff reasoned that the information provided in the technical evaluation overlapped the multiple functions being described in the evaluation.
Based on Chapter 7, Instrumentation and Controls, of the licensees updated final safety and analysis report (UFSAR) and WCAP-16675-P, AP1000 Protection and Safety Monitoring System Architecture Technical Report, Revision 5, as modified in Appendix 7A.8, (Reference 19 in Section 7.1.7, References, in Chapter 7 of the licensees UFSAR), the staff believes it better understands the licensees request related to Item L07. Accordingly, the staff requires additional information to complete its review of the LAR and requests SNC to confirm the information stated below or correct that information.
SNC proposes to alter the nomenclature, or naming convention associated with the description of the devices utilized to manually trip the reactor. The following is the staffs understanding of the current operation of the switch devices and the effect of the proposed Technical Specification (TS) change:
The REQUIRED CHANNELS column of TS Table 3.3.5-1, Reactor Trip System Manual Actuation, currently requires 2 channels for the Manual Reactor Trip function (Function 1 in the table) and 2 channels for the Safeguards Actuation Input from Engineered Safety Features Actuation System - Manual function (Function 2 in the table). This means that 2 channels, comprised of the given switch in each channel and the associated undervoltage and shunt trip mechanisms, are required to be operable for each of these functions, as noted by the number 2 in the REQUIRED CHANNELS column. If one of the two channels is inoperable, the plant must enter the associated limiting condition for operation (LCO) to restore the inoperable channel to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> in accordance with LCO 3.3.5.
2 Additionally, the REQUIRED CHANNELS column for Function 4 of TS Table 3.3.5-1, Core Makeup Tank Actuation Input from Engineered Safety Features Actuation System - Manual, currently requires 2 switch sets to be operable. If one switch set is inoperable, it must be restored to operable status within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> per the criteria within LCO 3.3.5.
Question 1 - Related to Function 1 within TS Table 3.3.5-1 Item L07 proposes to change the language in the REQUIRED CHANNELS column for Functions 1 and Function 2 from 2 to 2 switches to more accurately define the 2 devices that are required to be operable. Per Section 7.2.1.1.11, Manual Reactor Trip, of the licensees UFSAR, Revision 6, the manual reactor trip function consists of two controls in the main control room (MCR), either of which trips all eight of the reactor trip switchgear breakers. Additionally, within that section it states that the contacts for these controls are wired in series and are therefore redundant, as described in the technical evaluation of Item L07 of the LAR. The staff notes that SNC is not requesting approval of any change to the design of the systems that perform the functions governed by TS Table 3.3.5-1 for the FSAR analysis of those functions.
However, based upon a review of the TS definitions and the TS bases the staff understands the licensees request is not simply editorial in nature or to provide additional clarity. TS 1.1, Definitions, states that a TADOT shall consist of operating the trip actuating device and verifying the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. Also, the TS Bases associated with SR 3.3.5.1 state that the test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers. Based upon the information provided in the application, however, the staff is unable to reach a conclusion related to the requested change.
The staff requests that SNC provide additional information that either confirms or corrects the staffs understanding of the licensees request regarding Function 1 stated above, including the staffs understanding of the operation of the Reactor Trip System Manual Actuation function via the Manual Reactor Trip function (Function 1 in TS Table 3.3.5-1).
Question 2 - Related to Function 2 within TS Table 3.3.5-1 In Section 3.4.1, Manual System-Level Control, of WCAP-16675-P, AP1000 Protection and Safety Monitoring System Architecture Technical Report, Revision 5, as modified in Appendix 7A.8, (Reference 19 in Section 7.1.7, References in Chapter 7 of the licensees UFSAR), it states, in part, PMS Manual ESF System-Level Actuations from the MCR - The normal mechanism to actuate the ESF system is to use dedicated switches located in the MCR. The switches are located on the PDSP [Primary Dedicated Safety Panel] and the Secondary Dedicated Safety Panel (SDSP). Additionally, Section 7.3.1.1 of Chapter 7, Instrumentation and Controls, within Revision 6 of the licensees UFSAR it states, in part, Condition 5 [Manual initiation] consists of two momentary controls. Manual actuation of either of the two controls will trip the reactor and generate a safeguards actuation signal. Based upon the information cited above, there are two redundant, manual initiation switches for the safeguards actuation signal, one located on the primary dedicated safety panel (PDSP) and the other on the SDSP. Either of these switches will initiate a manual reactor trip concurrent with a manual safeguards actuation.
3 However, based upon a review of the TS definitions and the TS bases the staff understands the licensees request is not simply editorial in nature or to provide additional clarity. TS 1.1, Definitions, states that a TADOT shall consist of operating the trip actuating device and verifying the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. Also, the TS Bases associated with SR 3.3.5.1 state that the test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers. Based upon the information provided in the application, however, the staff is unable to reach a conclusion related to the requested change.
The staff requests SNC provide additional information that either confirms or corrects the staffs understanding of the licensees request regarding Function 2 stated above, including the validity of the staffs understanding of the operation of the Reactor Trip System Manual Actuation function via the Safeguards Actuation Input from Engineered Safety Feature Actuation System
- Manual function (Function 2 in TS Table 3.3.5-1).
Question 3 - Related to Function 4 within TS Table 3.3.5-1 For Function 4 of TS Table 3.3.5-1, LAR-17-024 Item L07 proposes to change the language in the REQUIRED CHANNELS column from 2 switch sets to 2 switches. Section 7.3.1.2.3, Core Makeup Tank Injection, in Chapter 7, Instrumentation and Controls, within Revision 6 of the licensees UFSAR, states, in part, Condition 5 [Manual initiation] consists of two momentary controls. Manual actuation of either of the two controls will align the core makeup tanks for injection. Additionally, on Sheet 12 of 21 of Figure 7.2-1, Functional Diagram Core Makeup Tank Actuation, it depicts the manual activation of the core makeup tank being carried out via an or gate, such that either of the two switches will initiate the requested functionality, in this case that being a manual reactor trip. Also on Sheet 12 of 21, the Manual CMT Actuation logic directs the reader to Note 2, which reads, Manual Actuation of either of the momentary controls will actuate all divisions of the core makeup tanks and trip all reactor coolant pumps.
In addition, the Institute of Electrical and Electronic Engineers Standards (page 1035 of Institute of Electrical and Electronic Engineers, IEEE 100, The Authoritative Dictionary of IEEE Standards Terms, Seventh Edition, 2000) defines a set as A unit or units and necessary assemblies, subassemblies and basic parts connected or associated together to perform an operational function. Accordingly, the term switch set, as used in Table 3.3.5-1, refers to all the equipment in a required channel, including the undervoltage and shunt trip mechanisms.
Additionally, based upon the information provided above, as either of the two switches are capable of performing the requested operation independently and do not rely on each other to perform or complete that operation, the staffs understanding is that the phrase switch sets would not apply to the equipment relied upon to actuate Function 4 in TS Table 3.3.5-1.
However, based upon a review of the TS definitions and the TS bases the staff understands the licensees request is not simply editorial in nature or to provide additional clarity. TS 1.1, Definitions, states that a TADOT shall consist of operating the trip actuating device and verifying the OPERABILITY of all devices in the channel required for trip actuating device OPERABILITY. Also, the TS Bases associated with SR 3.3.5.1 state that the test shall independently verify the OPERABILITY of the undervoltage and shunt trip mechanisms for the Manual Reactor Trip Function for the Reactor Trip Breakers. Based upon the information provided in the application, however, the staff is unable to reach a conclusion related to the requested change.
The staff requests that SNC provide additional information that either confirms or corrects the staffs understanding of the licensees request regarding Function 4 stated above, including the
4 validity of the staffs understanding of the operation of the Reactor Trip System Manual Actuation function via the Core Makeup Tank Actuation Input from Engineered Safety Feature Actuation System - Manual function (Function 4 in TS Table 3.3.5-1).