ML18173A321

COL Docs - LAR-17-037 - Draft Reviewer'S Aid - Roll-up of Original LAR Plus Supplements

ML18173A321
Person / Time
Site:	Vogtle
Issue date:	06/22/2018
From:	NRC
To:	NRC/NRO/DNRL/LB4
References
Download: ML18173A321 (56)

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Vogtle PEmails From: Habib, Donald Sent: Friday, June 22, 2018 5:00 PM To: Vogtle PEmails

Subject:

LAR-17-037 - Draft Reviewer's Aid - Roll-up of Original LAR plus supplements Attachments: LAR-17-037_Roll-up of Changes in S1 - S3_NRC Copy.pdf From: Haggerty, Neil [1]

Sent: Friday, June 22, 2018 4:17 PM To: Habib, Donald <Donald.Habib@nrc.gov>

Cc: Sparkman, Wesley A. <WASPARKM@southernco.com>; Redd, Jason P. <JPREDD@southernco.com>; Hicks, Thomas E. <X2TEHICK@southernco.com>; Amundson, Theodore Edwin <X2TAMUNS@southernco.com>

Subject:

[External_Sender] LAR-17-037 - Draft Reviewer's Aid - Roll-up of Original LAR plus supplements

Don, On December 21, 2017, SNC submitted LAR-17-037, which included a total of eight Enclosures providing the LAR, Exemption Request, licensing basis markups, commitments, and various reviewers aids. NRC has provided nine RAIs, of which SNC has submitted responses to eight RAIs in three supplements (S1, S2 & S3). The RAI responses also included marked up text to be incorporated into the eight Enclosures in the original LAR. As we discussed over the past few weeks, the NRC staff reviewers have requested an aid to help provide a comprehensive understanding of how all of the markups in the RAI responses will be shown in the LAR (and other Enclosures).

In response to the Staffs request, we have prepared an aid to facilitate the reviewers understanding of how the changes are rolled up into the original 8 enclosures. The attached Reviewers Aid shows the incorporation of the changes provided in the 3 supplements submitted to date, using typical Track Changes font (blue, underlined font for inserted text; red, strike-out font for deleted text). In addition, Comments are provided in the right-hand margin describing the origin of each change (i.e., SNC letter number, Enclosure, page number and the number of the RAI resulting in the change).

Note that during the preparation of this Reviewers Aid, it was determined that some additional changes (beyond those specifically identified in the RAI responses) were required to completely and accurately depict the changes described in the RAI response. The comments pointing to these changes identify the changes as conforming changes and refer to the RAI response to which they conform. Also, note that the responses to three RAIs [#3 (MCB), #4 (SCVB), and #9 (SRSB)] will result in changes to Enclosure 4, which provides a flow diagram depicting the proposed departure evaluation process. This version of the Reviewers Aid only identifies that the flow diagram, and does not show the actual changes, because it is anticipated that additional changes will be needed when the response to the last RAI (RAI LAR-17-037-2 from SEB) is submitted and agreed upon.

It is not anticipated that this Reviewers Aid will be revised again until it is provided in final form as updated (as appropriate) enclosures to the next, and final, supplement, LAR-17-037S4.

Please provide this document to the Staff reviewers to facilitate their review of the LAR. This document does not contain SUNSI, and may be made available to the Public in ADAMS. There is no 1

new technical information in this Reviewers Aid that has not already been provided to the NRC Staff in the RAI responses in S1 - S3.

Please contact me if you have any questions regarding this message or its contents.

Thank you, Neil Haggerty Neil Haggerty l Southern Nuclear Operating Company Nuclear Development Regulatory Affairs - VEGP 3&4 Licensing SNC-Inverness: 205.992.7047 l office: 301.874.8537 l mobile: 240.566.2442 x2nhagge@southernco.com neil.haggerty@excelservices.com This e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and may contain proprietary and confidential information. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.

2

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 307 Mail Envelope Properties (BY1PR09MB0935E56FA358EB8DA3D75FDC97750)

Subject:

LAR-17-037 - Draft Reviewer's Aid - Roll-up of Original LAR plus supplements Sent Date: 6/22/2018 4:59:36 PM Received Date: 6/22/2018 4:59:44 PM From: Habib, Donald Created By: Donald.Habib@nrc.gov Recipients:

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

Tracking Status: None Post Office: BY1PR09MB0935.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 3982 6/22/2018 4:59:44 PM LAR-17-037_Roll-up of Changes in S1 - S3_NRC Copy.pdf 1436347 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

Southern Nuclear Operating Company ND-18-0000 Enclosure 1U Rev D Vogtle Electric Generating Plant (VEGP)

P) Units nits 3 and 4 ie ra Updated Request for License Amendment:

se Amendment Changes to Tier 2* Departure Evaluation Evaluati Process w ft (LAR-17-037)

LAR--17-037)

LAR er

's Ai d

(This Enclosure consists of 23 24 pages, including this cover page.)

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION

3. TECHNICAL EVALUATION

4. REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria R

4.2. Precedent 4.3. Significant Hazards Consideration 5.

4.4.

ev D Conclusions ENVIRONMENTAL CONSIDERATIONS ie ra

6. REFERENCES w ft er

's Ai d

Page 2 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) hereby requests an amendment to Combined License (COL) Nos. NPF-91 and NPF-92 for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, respectively.

1.

SUMMARY

DESCRIPTION Under the current departure evaluation process applicable to Tier 2* information described in 10 CFR Part 52, Appendix D, Paragraph VIII.B, SNC must seek prior NRC approval through a License Amendment Request (LAR) for any proposed change to Tier 2* information, even if SNC R

can demonstrate that the change results in no more than a minimal impact to safety or improves safety. As the NRC staff has recently recognized in SECY-17-0075, 5, Planned Pl Improvements in Design Certification Tiered Information Designations, [ADAMS ADAMS Accession Number ML16196A321], One specific lesson is that some information has been designateddes d as Tier 2*

ev D when other regulatory tools could have been used instead to o ensure ure a facility is safely s designed, constructed and operated. This results in licensees submitting bmitting license amendment amen requests uests (LARs) on topics that may not involve safety significant facility changes. This ty changes. T is consistent ent with SNCs experience with the Tier 2* departure evaluationluation process. In n order o to mitigate itigate the ie ra regulatory inefficiency associated with this issue,e, SNC NC proposes proposes a ssite-specificc permanent exemption and license amendment that would use new w screening criteria crite to determine mine whether a proposed Tier 2* departure would qualify to o utilize the Tier 2 de departure evaluation valuation ion process.

Qualifying Tier 2* departures would be evaluated aluated under the existing exist ex Tier 2 departure re evaluation ev w ft process. Non-qualifying Tier 2* departures es would continue to require prior or NRC C approval. Thus, Thus any safety-significant Tier 2* departure would uld require pr prior prio NRC approval.

proval. A diagram of the proposed process is shown in Enclosure 4.

2.

er DETAILED DESCRIPTION

's The NRC issued the first Part 52 licenses to SNC VEGP P Unitss 3 and 4 in Febr February 2012. Changes to the licensing bases for those licenses are governed,ed, in part, by 10 rned, 0 CFR CF Part 52, Appendix D, Paragraph VIII.B. This portion of the regulations tions specifies the chcchange process for Tier 2 information and Tier 2* information and requires ires NRCRC approval for all departures from Tier 2*

Ai information.

However, recent Design Certification applications lications do not no contain Tier 2* information, in part because the level of detail contained er 1 information will encompass information that might ed in Tier d

be designated as Tier 2*, and thee existing Tier 2 change cha process requires prior NRC approval of safety-significant departures. SNC is proposing changes cha ch to the VEGP Units 3 and 4 licensing bases regarding Tier 2* change ange processes process to makema them functionally similar to the processes currently under developmentt between Korea Hydro Hy H and Nuclear Power (KHNP) and the NRC as part of the Advanced Power Reactor eactor 1400 (A eacto (APR1400) design certification application.

SNC acknowledges that the Commission miss employed a Tier 2* designation to capture certain significant AP1000 design information existing in Tier 2 that the Commission did not want changed without prior approval (see 71 Fed. Reg. 4474 (Jan. 27, 2006)). In SECY-17-0075, the NRC discussed the reasons for designating some Tier 2 information as Tier 2* and indicated Page 3 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) that Tier 2* information is intended to have substantial safety significance, commensurate with information designated as Tier 1. However, SECY-17-0075 suggests that the Tier 2* scope identified in previous design certifications, such as AP1000, may be broader than necessary, and includes information more appropriately designated as Tier 2; e.g., background information and other information of minimal safety significance. Furthermore, SNCs experience has demonstrated that not every change to information designated as Tier 2* has an impact on the safety-significant nature, if any, of the information. As such, SNC proposes to invoke a process functionally consistent with departure evaluation processes applied by current applicants for the certification of designs that contain no Tier 2* information but have significant safety-related information contained in the Tier 1 design control document (DCD). Specifically, SNC proposes a site-specific amendment that would allow qualifying departures from Tier 2* information to be evaluated under the existing departure evaluation process for Tier 2 departures 52, Appendix D, Paragraphs VIII.B.5.a through VIII.B.5.e. Qualifying information would be determined by applying screening criteria to with Tier 1 information would be non-qualifying Tier 2* departures ying prior NRC review and approval in accordance with 10 CFR Part 52, Append VIII.B.6. Qualifying Tier 2* departures would be evaluated de ng de o propose 2* information. Departures from Tier 2* information that involve safety significance commensurate signific artures and would Ai in 10 CFR Part departures from Tier 2*

proposed d departures from Tier fety significanc d

continue to require uld con uir Appendix D, Paragraph uated under the exis agraph existing Tier 2 departure existin eparture ture evaluation process. Thus, any safety-significant Tier 2** departures wou would require prior NRC w

approval.

Rev NRC approval through a LAR. Application Y-17 ere 17--0075, SNC has id Consistent with the NRCs findings in SECY-17-0075, re not departures from Tier 2* information that were no safety-significant, safety proposed departures would have concluded with a determ not safety-significant and could therefore have 10 CFR Part 52, Appendix D, Paragraph VIII.B.5.

ty--significan determi e been processed pr pro everal examples of identified several significa but nonetheless on of the Tier 2 dep etheless required uation departure evaluation equir prior n process to thes ass a departure parture consis t

these oposed change was determination that the proposed consiste with consistent ie x A figure in SNCs licensing basis included a Note specifying ying the design desig basis b size and spacing of shear studs in the structural modules. However, ver, a change to the Note was needed for consistency with design basis calculations ns that were prev ulations previously revised and pre w

incorporated into the AP1000 generic DCD. D.. To resolve this inconsistency, inc the figure needed to be changed to make the Note consistent sistent with the design d

des e basis and clarify that spacing may be changed to satisfy the applicable able codes and standards.

s The change had er the effect of enhancing safety by reflecting flecting the philosophy of adherence with the he design phil specific codes and standards invoked oked byy the licen licensing licensing basis.

b ba Nevertheless, because the Note was designated as Tier 2*,, priorr NRC approval approva was w required.1

's x During construction, it wass discovered vered that the t ttolerances for basemat thickness would potentially not ensure a level floor. The positive pos po tolerance needed to be expanded to improve the probability lity of a level surface on which to construct the Nuclear Island structures. An engineering neering evaluation demonstrated d that the change in tolerance was 1

SNC letter ND-12-0101, Request for License ce cen Amendment: Containment Internal Structural Module Shear Stud Size and Spacing (LAR-12-001), dated February 14, 2012 [ADAMS Accession No. ML12047A067]

and SNC letter ND-12-1399, Revised Request for License Amendment: Structural Modules Shear Stud Size and Spacing (LAR-12-001S), dated March 12, 2012 [ADAMS Accession No. ML12074A180].

Page 4 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) within the code allowance and the strength of the basemat would be maintained; however, because the tolerance was designated as Tier 2*, prior NRC approval was required. 2 x In a document incorporated by reference (IBRd) into the Updated Final Safety Analysis Report (UFSAR) and designated as Tier 2*, SNC had to obtain prior NRC approval to make a clarification that the phrase ISV Facility included identical facilities located both at Westinghouse and Vogtle, rather than just Westinghouse. Another change to this Tier 2* document requiring prior NRC permission was needed to add two questions to a survey given to students after simulator drills.3 Because the IBRd document is designated as Tier 2*, prior NRC approval was required.

R x Several editorial changes, such as typing, clerical, spelling, and consistency changes, hrough ou were required to Tier 2* information to achieve consistency throughout the licensing basis.

These changes affected nothing in the physical layout of the plant plan nor in the design pl ev D function of the plant. Safety is enhanced by these kinds ds of changes change because b electronic searches of the licensing basis become more accurate. urate. For example, a typographical c inconsistency in an acronym would impede an electronic nic search for tha ectronic that acronym,, as it sis containing would not yield the portion of the licensing basis ntaining the inco in inconsistency; editorial rial changes were needed to resolve this issue.4 ie ra These examples demonstrate that although Tierr 2* information ormation was intended in to have substantial safety significance, commensurate with information nformation designated as Tier 1, some Tier 2*

ant.

nt. This license ame departures are not, in fact, safety-significant. amend amendment requestest would ld allow al SNC w ft to apply screening criteria to departures s from Tier 2** information inform etermine ine whether such to determine suc departures qualify to be evaluated under the e Tier 2 departure departur part on process.

evaluation ces er A Tier 2* departure would qualify to be evaluated d under unde the Tier 2 departure ure evaluation process unless the proposed departure would:

1. Involve design methodology or construction materials als that deviate from a code c or standard

's credited in the plant-specific DCD for establishing design g the criteria for the des d or construction of a structure, system, or component (SSC) important mportant to safety, safety

2. Result in a material change to a design process ss described in tth the plant-specific DCD that is used to implement an industry standard dard or endorsed regulatory regul regu guidance, 2

Ai SNC letter ND-12-0670, Request forr License e Amendme Amendment: Nuclear N Island Basemat Thickness Tolerance d

(LAR-12-003), dated April 6, 2012 [ADAMS ADAMS Accession No. No ML12100A185],

M as supplemented by SNC letter ND-12-0809, Request for License nse Amendment - Supplemental Supp Information: Nuclear Island Basemat Thickness Tolerance (LAR-12-003),

003 , dated 2-003) ated April 12, 2012 2 [ADAMS Accession No. ML12104A323], and revised by SNC letter ND-12-0990, 990, Request for Lic License Amendment: Nuclear Island Basemat Thickness Tolerance (LAR-12-003R) Revised, d, dated dat May 7, 2012 [ADAMS Accession No. ML12130A468].

3 SNC letter ND-13-0348, Requestt for License Lic Amendment: Revision to AP1000 Human Factors Engineering Integrated System Validation tion Plan I GEH-320 (LAR-13-001), dated February 15, 2013

[ADAMS Accession No. ML13050A214].

4 SNC letter ND-14-1045, Request for License Amendment: Tier 2* Editorial and Consistency Changes (LAR-13-033), dated July 30, 2014 [ADAMS Accession No. ML14211A666].

Page 5 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

3. Result in a material change to the fuel criteria evaluation process, the fuel principal design requirements, or nuclear design of fuel and reactivity control system, ; result in any change to the or maximum fuel rod average burn-up limits, ; or result in any change to the small Commented [HN1]: Conforming change in response to RAI break LOCA analysis methodology described in UFSAR Subsections 15.6.5.4B.2.2 or LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 4).

15.6.5.4B.2.3; or Commented [HN2]: Response to RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 8).

4. Adversely affect the containment debris limits or debris screen design criteria., or Commented [HN3]:

HN3 Conforming change in response to RAI LAR-17-037-3 (MCB)

MCB) in LAR 17-037S2 (ND-18-0608,

5. Result in a change to the RCP type (canned motor design). Enclosure 11, pg.. 3).

Commented mented [HN

[HN4]: Response Respo to RAI LAR-17-037-4 If the screening criteria are all answered no, the proposed change would be considered a (SCVB)

B) in LAR L 17-037S2 (ND-1 17 (ND-18-0608, Enclosure 12, pg. 7).

R Qualifying Change and would be processed in accordance with the Tier 2 departure evaluation B.5.a through VIII.B.5.e (See process specified in 10 CFR Part 52, Appendix D, Paragraphs VIII.B.5.a NOTE: The e marked text in N ND-18-0608 used the word and but it was subsequently subseque determined that or was more for a proposed process diagram). appropriate.

ev D Commented [HN[HN5]: Response to RAI LAR-17-037-3 (MCB) rsightt of the proposed To provide the NRC the opportunity to provide additional oversight propose revision to the n LAR 17-037S2 (ND-18-0608, Enclosure 11, pg. 3).

in ment that would require SNC Tier 2* departure process, SNC is proposing a regulatory commitment NC to tting a license amen annotate Tier 2* departures implemented without submitting amendm amendment requestt within departure reports submitted in accordance with 10 CFRFR Partrt 52, Appendix D, paragraphs phs X.B.1 ie ra and X.B.3.b. The proposed regulatory commitment ent is shown in Enclosure Enclos Enclo hiss proposed

8. This regulatory commitment would be implemented coincident ent with the imp implementation n of the he license amendment approving this LAR, and would d be applicable ttoo Tier 2* departures tures identified in departure reports submitted subsequent to the implementation of this license e amendment.

dme w ft To ensure the proposed qualifying Criteria reliably and predictably pr differentiate ate between Tier Tie 2*

information with safety significance commensurate urate with Tier T 1 and other information ormation that does doe not warrant the same level of control, SNC is proposingsing a regulatory r commitment ment that would require er SNC to develop, implement, and maintain procedural ro guidance ce with a level of detail commensurate with the detailed implementation guidance and related ed bases for the proposed Criteria contained in this LAR, including additional guidance provided ded by SNC in the supplements to this LAR. The proposed regulatory commitment would ould be implemented implem prior to the

's implementation of the license amendment approving this LAR. Commented [HN6]: Response to RAI LAR-17-037-6 (LB4) in LAR-17-037S3 (ND-18-0646, Enclosure 14, pg. 3).

Ai Licensing Basis Change Descriptions:

Proposed d Licensing ensing Basis Ch C

Changes COL License Condition ion on Description of the Proposed Change D

Des 2.D.(13) d Adds new license licensee is Part 52 lic condition 2.D.(13) to document that the i exempt from the requirements of 10 CFR 52, Appendix D, Paragraphs II.F, VIII.B.5, and VIII.B.6 subject to the conditions and limitations set forth VIII.B in Section 2.D.(13) of this license and to specify the plant-specific licensing requirements for the Tier 2*

Page 6 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) departure evaluation process. The elements of this process are provided in sub-paragraphs (a) and (b).

2.D.(13)(a) Adds a new license condition sub-paragraph that defines the Tier 2* departure regulations from which SNC is exempt except when any of four screening criteria are met.

2.D.(13)(b) Adds a new license condition sub-paragraph that allows Tier 2* departures to be evaluated under the provisions of 10 CFR Part 52, Appendix D, Section VIII.B.5 provided R

the conditions of the license condition are met.

UFSAR pages with a The footer is modified to stipulate pulate tha that prior NRC approval footer regarding Tier 2* of departures from Tier 2** information informatio may m be required in ev D information accordance with the e departure eparture evaluation evalu process specified in License e Condition tion 2.D.(13).

ie ra

3. TECHNICAL EVALUATION o VEGP Units 3 and The NRC issued the first Part 52 licenses to an 4 iin Februaryy 2012. Changes Ch to w ft re the licensing bases for those licenses aree governed, in part, by b 10 CFR Part 52, Appendix Appen D, ations specifies the departure Paragraph VIII.B. This portion of the regulations e and change proces process for f

Tier 2 information and Tier 2* information andnd requires NRC N oval for approval or all departures from Tier 2* information.

er SNC acknowledges that the Commission employed a Tier 2* designation significant AP1000 design information existing in Tier 2 that not be changed without prior approval (see 71 Fed.

ignation to cap at the Commission ed. Reg. 4474 (Jan.(Ja de capture certain Commission determined dete should 27, 2006)). In

's SECY-17-0075, the NRC discussed the reasons forr designating gnating some T Tier 2 information as Ti Tier 2* and indicated that Tier 2* information is intended ended to have substantial substan sub safety significance, commensurate with information designated as Tier 1. However, SECY-17-0075SE SEC suggests that the Tier 2* scope identified in previous design n certifications, fications, such aas AP1000, may be broader Ai than necessary, and includes information tion more appropriately designated as Tier 2; e appropr appropriat e.g., background information and other information tion of minimal safety nformation s significance. Furthermore, SNCs experience has demonstrated that not every eve change chang to information designated as Tier 2*

has an impact on the safety-significant ant nature, ture, if any, nature any of the h information. As such, SNC proposes d

to invoke a process functionally consistent onsistent with departure departur evaluation processes applied by current depar applicants for the certification of designs that contain contai no Tier 2* information. Specifically, SNC conta proposes a site-specific amendment endment that would use us new screening criteria to determine whether a proposed Tier 2* departure re would qualify to utilize the Tier 2 departure evaluation process.

Qualifying Tier 2* departures would be evaluated evalu under the existing Tier 2 departure evaluation process specified in 10 CFR Part 52, Appendix Appe A D, Paragraphs VIII.B.5.a through VIII.B.5.e. Non-qualifying Tier 2* departures would continue co con to require prior NRC approval in accordance with 10 CFR Part 52, Appendix D, Paragraph VIII.B.6. Thus, any safety-significant Tier 2* departure would require prior NRC approval.

Page 7 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

SECY-17-0075 provides the historical basis and origins for designating information as Tier 2*.

Citing the history of the development of Tier 2*, SECY-17-0075 explains that Tier 2* was intended to have the same safety significance as Tier 1 information. In addition, SECY-17-0075 references SECY-96-0775 which also provides insight to the origins and requirements of Tier 2* information.

Specifically, SECY-96-077 states, Also, many codes, standards, and design processes, which were not specified in Tier 1, that are acceptable for meeting [inspections, tests, analyses, and acceptance criteria] ITAAC were specified in Tier 2. The result of these actions is that certain significant information only exists in Tier 2 and the NRC does not want this significant information to be changed without prior NRC approval. To address the issues identified in SECY-96-077, SNC performed an analysis of the Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c. The analysis examined each item in terms of the R

following criteria:

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

x Would changes in the Tier 2* information be adequately equately addressed addres by otherr applicable ie ra regulations, e.g., 10 CFR 50.46?

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

w ft x Would the evaluation process defined ed in 10 CFR Part P 52, Appendix D, paragraph VII VIII.B.5 consistently and reliably require prior NRC approva approval of a change to the Tier 2* info information?

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

o VEGP 3 and 4 Plant-specific Tier 1 Design Control Document ocument (DCD),

(DCD) or o VEGP 3 and 4 Combined License (COL), or

's o Applicable regulations, e.g., 10 CFR 50.46 x Degree to which Codes, standards, and design gn and qualification qualificatio process, are relied upon for ITAAC acceptance criteria, but not specified d in the VEGP 3 and 4 Plant-specific Tier 1 DCD Ai x Safety-significance x Degree to which 10 CFR Part 52, Appendixndix D, Section Sec VIII.B.5 would effectively evaluate a Tier 2* departure d

Following the evaluation process ess described above, abov SNC made the following conclusions regarding 11 of the 24 Tier 2* matters listed in 10 1 CFR Part 52, Appendix D,Section VIII paragraphs B.6.b and B.6.c::

• First, a set of Tier 2* information nformation is already alre addressed in Tier 1 and thus a change to this Tier 2* information, which h would wo involve a change to the associated Tier 1 information, would require prior NRC approval.

prov Therefore, neither an evaluation of safety-significance 5

SECY-96-077, Certification of Two Evolutionary Designs, April 15, 1996 (ADAMS Accession No. ML003708129)

Page 8 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) nor new evaluation criteria were considered necessary to provide assurance that changes would receive prior NRC approval.

• 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.

• 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 R

criteria currently provided in 10 CFR Part 52, Appendix D, VIII.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.

ev D Based on the results of the analysis, 12 of the 24 Tier 2* matters tters listed in 10 1 CFR Part 52, Appendix D,Section VIII paragraphs B.6.b and B.6.c were determined ermined to be ade adequately covered by existing Tier 1 information, covered by another regulation n or the combined combin license, or did not rise to the level of Tier 1 safety significance. The remaininging 1213 12 3 of the 24 Tier 2* matters atters liste listed ie ra Commented [HN7]: Response to RAI LAR-17-037-7 (ARPB) in LAR 17-037S3 (ND-18-0646, Enclosure 15, pgs. 6 in 10 CFR Part 52, Appendix D, Section VIII paragraphs raphs B.6.b and B.6.c were selected elected forr & 7) development of additional screening criteria that hat would determine w whether an associated iated Tier 2* Commented [HN8]: Response to RAI LAR-17-037-9 departure qualifies for the departure evaluation ation process outlined outline in 10 CFR Part 52, Appendix App D, (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 8).

w ft Section VIII.B.5. A summary of the analysis ysis is provided in EEnclosure 5. The e selected m matters are:

er x Maximum fuel rod average burn-up x Fuel principal design requirements x Fuel criteria evaluation process x Reactor coolant pump type.

's x Small-break loss-of-coolant accident (LOCA) analysis alysis methodology methodolo Commented [HN9]: Response to RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 8).

x Screen design criteria x Design Summary of Critical Sections x American Concrete Institute (ACI) 318, ACI 349, Am American National Standards Ai Institute/American Institute of Steel Construction onstruction (ANSI/AISC)-690, (ANS and American Iron and Steel Institute (AISI), Specification on for the Design Desig of Cold Formed Steel Structural Members, Part 1 and 2, 1996 Edition dition and 2000 Supplement x Nuclear design of fuel and reactivity ctivity control contr system, except burn-up limit d

x Instrumentation and control system design processes, methods, and standards x Piping design acceptance eptance criteria x Human factors engineering ngineering x Steel composite structural ructural module details d

Based on the results of the analysis, ysis, 13 of the 24 Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b 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 11 of the 24 Tier 2* matters listed in Page 9 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) 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:

x Maximum fuel rod average burn-up x Fuel principal design requirements x Fuel criteria evaluation process x Screen design criteria x Design Summary of Critical Sections R

x American Concrete Institute (ACI) 318, ACI 349, American National Standards Institute/American Institute of Steel Construction (ANSI/AISC)-690, SC) 69 and American Iron and Steel Institute (AISI), Specification for the Design of Cold Fo Formed Steel Structural ev D Members, Part 1 and 2, 1996 Edition and 2000 Supplement ent x Nuclear design of fuel and reactivity control system, except pt burn-up burn p limit x Instrumentation and control system design processes, methods, and an standards x Piping design acceptance criteria ie ra x Human factors engineering x Steel composite structural module details Commented [HN10]: Response to RAI LAR-17-037-3 (MCB) in LAR 17-037S2 (ND-18-0608, Enclosure 11, pg. 3).

A set of criteria was then developed that would ould be used to determine dete determi the critical cal safety ety aspects a of w ft the above matters to determine whether a proposed departur departure from Tierr 2* could ould qualify to be evaluated under the departure evaluation process for Tier Tie 2 departures ures outlined in Section Se Sect t be evaluated VIII.B.5. A proposed Tier 2* departure would not qualify to ated under Section VIII.B.5, VII VI er if it:

1. Involves design methodology or construction materials rials thatt deviate from a code or ablishing standard credited in the plant-specific DCD for establishing ng the criteria fo f the design or for construction of a structure, system, or component nt (SSC)

SC) important to sa safety,

's

2. Results in a material change to a design process ess described in the pla plant-specific DCD that is used to implement an industry standard or endorsed regulatory regulato guidance, iteria evaluation process,

3. Results in a material change to the fuel criteria proces proce the fuel principal design requirements, or nuclear design of fuel uel and reactivity control cont system, or; result in any Ai change to the maximum fuel rod average erage burn-up burn--up limits, limits, or; or result in any change to the Commented [HN11]: Conforming change in response to small break LOCA analysis methodology y described in U UFSAR Subsections 15.6.5.4B.2.2 RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 4).

or 15.6.5.4B.2.3; or Commented [HN12]: Response to RAI LAR-17-037-9

4. Adversely affects the containment debris limits lim or debris screen design criteria., or (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 8).

d 4.5. Result in a changee to the RCP type (canned (c motor design).

Commented [HN13]: Response to RAI LAR-17-037-4 (SCVB) in LAR 17-037S2 (ND-18-0608, Enclosure 12, pg. 7).

Criterion 1 represents screening ning criteria that were developed d as a result of the analysis performed NOTE: The marked text in ND-18-0608 used the word and wing Tier 2* matters:

that was related to the following matters but it was subsequently determined that or was more appropriate.

x Design Summary of Critical al Sections Section Se Commented [HN14]: Response to RAI LAR-17-037-3 (MCB) in LAR 17-037S2 (ND-18-0608, Enclosure 11, pg. 3).

x American Concrete Institute te (ACI) 318, ACI 349, American National Standards Institute/American Institute of Steel Construction (ANSI/AISC)-690, and American Iron Page 10 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) and Steel Institute (AISI), Specification for the Design of Cold Formed Steel Structural Members, Part 1 and 2, 1996 Edition and 2000 Supplement x Steel composite structural module details Criterion 2 represents screening criteria that were developed as a result of the analysis performed that was related to the following Tier 2* matters:

x Instrumentation and control system design processes, methods, and standards x Piping design acceptance criteria x Human factors engineering R

Criterion 3 represents screening criteria that were developed as a result of the analysis performed that was related to the following Tier 2* matters:

ev D x Maximum fuel rod average burn-up x Fuel principal design requirements x Fuel criteria evaluation process x stem, except burn-up Nuclear design of fuel and reactivity control system, burn-burn -up lim limit ie ra oped as a result of Criterion 4 represents screening criteria that were developed o the analysis siss performed that was related to the following Tier 2* matter:

x Screen design criteria w ft be used to perform the evaluations:

er uation criteria, the To ensure consistent application of the evaluation Criterion 1 (Codes and Standards) detailed guidance:

th following g detailed ed guidance would x Use of a code or standard not approved by the NRC is a deviation from a ccode or standard.

wo

's x Use of a later edition of a code or standard than an thee edition approved approv approve by the NRC is a deviation from a code or standard.

x Use of an equivalent code or standard is a deviation viation from a code cod or standard.

x Changes to design output using the approved ved standards and a codes (e.g., structural ded the standard dimensions) are not deviations provided tandard or code co limit is met.

Ai x Editorial and grammatical corrections ons are re not deviations.

deviation eviations s

x Corrections required to achieve e consistency sistency within the document are not deviations.

d Page 11 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

Criterion 1 (Codes and Standards) Bases:

It is noted that some, but not all, codes and standards credited in the plant-specific DCD for the design or construction of the AP1000 are referenced in the VEGP Plant-specific Tier 1 DCD.

Therefore, this screening criterion assures that Tier 2* departures involving deviations from codes and standards will be submitted for prior NRC approval. It should be noted that the detailed guidance examples for Criterion 1 are more conservative than criteria that would be applied to a departure evaluated under the requirements of 10 CFR Part 52, Appendix D, Section VIII paragraph B.5 because the proposed criteria require prior NRC approval for deviations from codes and standards while regulatory guidance related to the application of paragraph B.5 allows some flexibility when evaluating deviations from codes and standards.

R Criterion 2 (Design Processes) detailed guidance:

A material change affects a design process output, or method of performing ev D method of controlling the design process.

x The following are examples of material changes:

o The addition, deletion, or alteration of a design o Reconfiguration of design process steps o Departures from regulatory guidance related n process ated to performin a design process, or cess step o the design process pro proc Commented [HN15 17-037-5 17 13, pg. 3).

3

[HN15]: Reformatted by response to RAI LAR-7-5 (HOIB) in LAR-17-037S3 (ND-18-0646, Enclosure ie ra o Alteration of a detail that serves as the basis sis for acceptance in an NRC Final Safety Evaluation Report (FSER) related too the affected design process p Commented [HN16]: Response to RAI LAR-17-037-5 (HOIB) in LAR-17-037S3 (ND-18-0646, Enclosure 13, pg. 3).

x The following examples are not material aterial changes:

changes w ft o Editorial changes o Clarifications to improve readerer understanding understandi understand o Correction of inconsistencies withinthin the document which are clearly disc dis discernible er (e.g., between sections) o Minor corrections to figures (e.g., correcting mislabeledd items) Commented [HN17]: Conforming change to response to o Changes that do not change the meaning orr substance stance of information informa inform presented RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 5).

(e.g., reformatting or removing detail as describeded in NEI 9898-03, Revision 1,

's Guidelines for Updating Final Safety Analysis lysis Reports, Section S A4 [ADAMS NOTE: This change was addressed for inclusion under Criterion 3; however, it was subsequently identified that Accession Number ML003779028]) identical text also needed to be inserted in this location for Criterion 2.

Criterion 2 (Design Processes) Bases: Commented [HN18]: Conforming change to response to Ai The design processes addressed in the VEGP EGP 3 and d 4 Plant-specific Plant-Plant -spe s Tier 1 DCD and for which RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, he VEGP some Tier 2* information is contained in the GP 3 and 4 plant-specific plan Tier 2 DCD are: Enclosure 17, pg. 6).

NOTE: This change was addressed for inclusion under x Plant-specific specific Tier 1 DC Diverse Actuation System (Plant-specific DCD, Section 2.5.1; Plant-specific Tier 2 Criterion 3; however, it was subsequently identified that DCD, Chapter 7); identical text also needed to be inserted in this location for d

Criterion 2.

x Protection and Safety y Monitoring System (Plant-specific

( Tier 1 DCD, Section 2.5.2; Plant-specific Tier 2 DCD DCD, Chapter hapter 7);

x Component Interface ce Module (Plant-s (Plant-specific Tier 1 DCD, Section 2.5.2; Plant-specific Tier 2 DCD, Chapter 7); ); Commented [HN19]: Response to RAI LAR-17-037-8 (ICE) x Piping design acceptance e criteria crite (multiple system sections in the plant-specific Tier 1; in LAR-17-037S3 (ND-18-0646, Enclosure 16, pg. 3).

plant-specific Tier 2 DCD, Subsections ubs 3.6.2 and 3.9.3); Commented [HN20]: Supplement to response to RAI LAR-x Human Factors Engineering (Plant-specific Tier 1 DCD, Section 3.2; Plant-specific Tier 2 17-037-1 (MEB) in LAR-17-037S2 (ND-18-0608, Enclosure 10, pg. 4).

DCD, Chapter 18);

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ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

Diverse Actuation System (DAS)

While paragraph B.5.b allows changes to design processes without prior NRC approval provided that the design function is not more than minimally adversely6 affected, this new Commented [HN21]: Response to RAI LAR-17-037-9 criterion does not allow any material change to a design process. (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 7).

NOTE: The response to the RAI said that this footnote would Protection and Safety Monitoring System (PMS) be moved to the first occurrence of the word adverse in Enclosure 1, but it was subsequently determined that the UFSAR Tier 2* information related to PMS is contained in Westinghouse WCAP reports that phrase adversely ely aaffected occurred first, and that this are incorporated by reference into the UFSAR. For the PMS, departures related to a design footnote should be ins inserted in this location.

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 R

related to PMS design processes receives prior NRC approval.

Component Interface Module (CIM) ev D UFSAR Tier 2* information related to the CIM is contained in n WCAP-17179-P WCAP-1 (Proprietary) and WCAP-17179-NP (Non-Proprietary), which are incorporated orporated 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 criteri of paragraph B.5.b; 5.b; therefore, some departures may not receive prior NRCC approval as required.

re The application applicatio ie ra of proposed Criterion 2 assures that any material al departure related rela to the CIM design processes receives prior NRC approval. Commented [HN22]: Response to RAI LAR-17-037-8 (ICE) in LAR-17-037S3 (ND-18-0646, Enclosure 16, pg. 4).

Piping Design Acceptance Criteria (DAC)

AC) w ft This UFSAR Tier 2* text describes a design proce process for piping design gn that is use used to implement an industry standard (e.g., ASME SME Code) or endorsed regulatory tory guidance. For example, as explained in UFSAR Section on 3.6.2.1.1, 3.6.2. this text defines efines the process pro for er determining pipe break locations in piping designed sign and constructed ted to the require requirements for Class 1 piping in the ASME Code,Section III, Division 1. Departures rtures rela related to this design process may not be easily evaluated against the eight criteriaa of paragraph B.5.b; therefore, some departures may not receive prior NRC approval as required. T The application of

's proposed Criterion 2 assures that any material departure e related to piping pipin DAC receives prior NRC approval. Commented [HN23]: Supplement to response to RAI LAR-17-037-1 (MEB) in LAR-17-037S2 (ND-18-0608, Enclosure 10, pg. 4).

Human Factors Engineering (HFE)

Ai The UFSAR Tier 2* information related to HFE is contained in the Westinghouse documents that are incorporated by reference into to the UFSAR. For HFE, HF departures related to a design process as described in Westinghouse ouse documents may ma not be easily evaluated against the b; therefore, eight criteria of paragraph B.5.b; erefore, some de departures may not receive prior NRC d

approval as required. The application of proposed propose Criterion 2 assures that any material propo departure related to HFE design esign processes receives receiv ece prior NRC approval.

6 The use of the terms adverse/adversely rsely y aand design function, as used in the guidance discussions, is derived from the use of the same terms rm in NEI 96-07, Revision 1, Guidelines For 10 CFR 50.59 rm Implementation [ADAMS Accession Number ML003771157]. This NEI guidance provides an extensive discussion regarding how to evaluate whether a change adversely affects a design function. The term design function is defined in NEI 96-07, Section 3.3.

Page 13 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

Criterion 3 (Nuclear Fuel) detailed guidance:

x A material change is any change in a method of evaluation or calculation. Note that WCAP-12488, Westinghouse Fuel Criteria Evaluation Process provides the fuel criteria evaluation process. This WCAP topical report describes the process and criteria that applies to changes in existing fuel designs that will not require NRC review and approval as long as these criteria are satisfied. Changes made in accordance with this WCAP are not considered material changes to the fuel criteria evaluation process, the fuel principal design requirements, the maximum fuel rod average burn-up limits, or the nuclear design of fuel and reactivity control system. The proposed Tier 2* screening and evaluation process criterion would not permit material changes to the WCAP-12488.

x A material change to a design would be any change that has an adverse effect on a design R

function.

x A material change is any change that would have an effect onAny Any change c to the maximum fuel rod average burn-up limits requires prior NRC approval.val. Commented [HN24

[HN24]: Response to RAI LAR-17-037-9 ev D (SRSB) in LAR-17 LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 4).

x The following examples are not material changes:

o Editorial Changes o Clarifications to improve reader understanding nding o Correction of inconsistencies within the he document ument which are a clearly discernible scernible nible (e.g., between sections) ie ra o Minor corrections to drawings and d figures (e.g.,

(e.g correcting mislabeled components) Commented [HN25]: Response to RAI LAR-17-037-9 o Changes that do not change e the meaning or ssubst substance of information ormationon presented p (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 5).

w ft (e.g., reformatting or removing oving detail ovin detai as desc described in NEI 98-03, 03, Revision Rev 1, Guidelines for Updating Final Safety An Analysis Reports, Section ection A4 [ADAMS

[ADA Accession Number ML003779028]) 028]) Commented [HN26]: Response to RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 6).

er Criterion 3 (Nuclear Fuel) Bases:

The VEGP 3 and 4 Plant-specific Tier 1 DCD does not contain n information ation related relate to nuclear fuel.

Proposed Criterion 3 would provide assurance that material al departures artures from Tier Ti 2* information related to the fuel criteria evaluation process, the fuel principal al design requirements, incipal requirem requ the nuclear

's design of fuel and reactivity control system, or the maximum imum fuel rod average burn-up limits would receive prior NRC approval. It should be noted that thehe proposed Criter Criterion 3 is more conservative than criteria that would be applied to a departure e evaluated uated under 10 CFR C Part 52, Appendix D,Section VIII Paragraph B.5 because proposed ed Criterion erion 3 does notno apply the no more than Ai minimal standard. In addition, Criterion 3 does not allow chang to methods of evaluation.

llow changes Due to the uniqueness of the AP1000 design, sign, the use of o the NOTRUMP code is considered acceptable, in part, because of the identified ed Tier 2* information inform in Chapter 15 (two paragraphs in Subsections 15.6.5.4B.2.2 and 15.6.5.4B.2.3). The Tier 2* information associated with d

NOTRUMP homogeneous sensitivitysitivity model and critical criti heat flux assessment during accumulator injection is considered to be safety-significant sa significant and an an integral aspect of the methodology as approved for the AP1000. Therefore, any chan changes to that information would involve a departure from a method of evaluation described escrib in the FSAR and require prior NRC review and approval. Commented [HN27]: Response to RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 9).

Criterion 4 (Debris Screen) detailed guidance:

Page 14 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) x An adverse change is any change that would be considered a non-conservative change of a debris value established in the UFSAR.

x An adverse change would be any change that changes any element of the evaluations used to determine the design of the debris screens.

x Containment resident debris limit is defined in UFSAR Subsection 6.3.2.2.7.1 (item 12).

x Fibrous debris limit is defined in UFSAR Subsection 6.3.2.2.7.1 (item 12). Commented [HN28]: Response to RAI LAR-17-037-4 (SCVB) in LAR 17-037S2 (ND-18-0608, Enclosure 12, pg. 3).

x The criteria apply to departures affecting the In-Containment Refueling Water Storage Tank (IRWST) Screens and the Containment Recirculation Screens. Commented [HN29]:

N29] Response to RAI LAR-17-037-4 037S2 (ND-18-0608, Enclosure 12, pg. 5).

(SCVB) in LAR 17-037S2 Application of the criteria related to debris values is demonstrated by the following examples:

R Example 1:

Following a refueling outage, a review of the containment ent closeout closeo inspection results ev D reveals that the calculated total amount of resident containment nment debris is 135 pounds. An engineering analysis determines that the screens would still till be able to m meet their safety function. Consequently, a change is proposed to raise aise the limit iin the UFSAR to 135 pounds.

ie ra The proposed departure would be evaluated against gainst all four proposed pr Qualifying ng Criteria, and when evaluated against Qualifyingg Criterion 4, the evaluation eval would determine termine that the proposed departure is considered ed an adverse effect effec on containment debrisbris limits li and w ft would require prior NRC approvalval before b implementation.

mplement The condition ndition would wou be considered adverse because any relaxation of the t limit (increase in n value) would be considered adverse.

er Example 2:

A design change is proposed that improves the effectiveness tiveness of the screens. The engineering evaluation, using the methodology described ribed in the UFSAR, UF demonstrates

's that the fibrous debris limit could be raised to10 o10 pounds. As a result, res it is proposed to raise the limit in the UFSAR to 10 pounds.

The proposed departure would be evaluated against all a l four proposed Qualifying Criteria, Ai and when evaluated against Qualifying Criterion 4, the evaluation would determine that the proposed departure is considered an n adverse effect effec on the containment debris limits and require prior NRC approval before implem implementation. The condition would be considered adverse because anyy relaxation of the limit (increase in value) would be d

considered adverse.

Example 3:

A design change to the conta containment screens is proposed which would alter the size of the screens slightly. An engineering neeri evaluation determines the screens would continue to meet their design function iiff the fibrous debris limit were set at 6.0 pounds.

Consequently, it is proposed to revise the UFSAR to change the limit from 6.6 pounds to 6.0 pounds.

Page 15 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

The proposed departure would be evaluated against all four proposed Qualifying Criteria, and when evaluated against Qualifying Criterion 4, the evaluation would determine that the proposed debris limit departure is not considered an adverse effect on the containment debris limits and would not require prior NRC approval before implementation. The condition would not be considered adverse because the revised limit is more restrictive and continues to ensure the screens meet their design function. However, the proposed departure and associated screen design change would also be evaluated against the criteria of 10 CFR Part 52, Appendix D, paragraph VIII.B.5 and it may be determined that prior NRC approval is required. Commented [HN30]:

N30]: Response R to RAI LAR-17-037-4 (SCVB) in LAR 17-037S2 (N (ND-18-0608, Enclosure 12, pgs. 4 -

5).

Application of the criteria related to debris screens is demonstrated by the following examples:

Example 1:

Rev D A design change is proposed to relocate a stairwell inside contains fibrous material) is located 40 inside diameters is a continuation of the pipe axis. Per UFSAR Subsection e containment.

containme ventilat ers from the break bsection 6.3.2.2.7.1, 6.3.2 An evaluation of the potential impacts of the design change reveals that the stairwell is credited as an intervening structure in the LOCA pipe break analysis, s, and a ventilation filter (which bre along an axis that the ZOI in th hat the ie ra absence of intervening components, supports, s, structures, or other objects ts includes insulation in a cylindrical area extending out a distance equal tto 45 inside diameters meters from the break along an axis that is a continuation nuation of the pipe pip axis and up to 5 insidede diameters in the radial direction from the axis. The 5 inside diameter diamet limit in the radial direction irect from w ft the pipe axis continues to be met.. An engineering engineerin evaluation and testing esting demons demonstrate that the non-qualifying insulation material terial will not be adversely affected ed by the assumed assu pipe break. As a result, a change is proposed to revise the UFSAR SAR ZOI limit from 45 er inside diameters to 40 inside diameters in this this area.

The proposed departure would be evaluated against all four proposed roposed Q Qualifying Criteria, and when evaluated against Qualifying Criterion 4, the evaluation woul would determine that the proposed departure is considered an adverse effect on the debris d screen design

's criteria and require prior NRC approval before e implementation. Th The condition would be considered adverse because any relaxation of the ZOI distance (decrease in value) would be considered adverse.

Ai Example 2:

A design change is proposed thatt would add a structure in the lower regions of the containment. The impact of the change wouldwo be that the maximum post-design basis d

accident (DBA) LOCA floodup oodup water level would wo be raised to plant elevation 111.0 feet.

Per UFSAR Subsection n 6.3.2.2.7.1, the maximum max post-DBA LOCA floodup water level is plant elevation 110.2 2 feet. Additional analysis analy reveals that no non-qualifying insulation is located below 111.0 feet. As a result, resu a change is proposed to revise the UFSAR maximum post-DBA LOCA CA floodup fl value to 111.0 feet.

The proposed departure would ould be evaluated against all four proposed Qualifying Criteria, and when evaluated against Qualifying Criterion 4, the evaluation would determine that the proposed departure is not considered an adverse effect on the containment debris screen design criteria and would not require prior NRC approval before implementation.

Page 16 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

The condition would not be considered adverse because the revised post-DBA LOCA floodup water level is more restrictive and continues to ensure fibrous insulation material will not be introduced following a DBA LOCA. However, the proposed departure and associated design change would also be evaluated against the criteria of 10 CFR Part 52, Appendix D, paragraph VIII.B.5, and this evaluation may determine that prior NRC approval is required. Commented [HN31]: Response to RAI LAR-17-037-4 (SCVB) in LAR 17-037S2 (ND-18-0608, Enclosure 12, pgs. 6 -

7).

Criterion 4 (Debris Screens) Bases:

It is noted that the VEGP 3 and 4 Plant-specific Tier 1 DCD does not contain design description information related to debris screens, but detailed design information is extensively covered in ITAAC (Table 2.2.3-4), which will no longer be part of the licensing basis after the 10 CFR R

52.103(g) finding. Screening Criterion 4 provides assurance that departures from Tier 2*

information that adversely affect debris screen design criteria wouldd receive receiv prior NRC approval.

rec It should be noted that proposed Criterion 4 is more conservative ive than ccriteria that would be tive ev D applied to a departure evaluated under 10 CFR Part 52, Appendix ndixx D, Section Sectio VIII V paragraph B.5 because the proposed criterion does not allow any adverse e change nge 7 versus rsus the no more than ha minimal8 standard used in paragraph B.5.b.

Criterion 5 (Reactor Coolant Pump Type) detailed guidance:

ie ra Tier 2* information regarding RCP type is contained in UFSAR Subsection Subse 5.4.1.2.2, Design Desig Description. Any departure from the design of the RCP that would not utilize the canned nned motorr design would meet Criterion 5 and the departure parture would not qualify qua for evaluation under der w ft paragraph B.5.b.

Criterion 5 (Reactor Coolant Pump Type) Bases es er The VEGP 3 and 4 Plant-specific Tier 1 DCD does not contain information mation related to tthe canned motor design attributes of the RCP. Proposed Criterion 5 would d provide assurance that departures from Tier 2* information related to RCP type would receive ceive prior NRC approval. Commented [HN32]: Response to RAI LAR-17-037-3 (MCB) in LAR 17-037S2 (ND-18-0608, Enclosure 11, pg. 4).

's Because the screening criteria would provide assurancence that at departures from Tier 2* matters that are safety-significant and would meet criteria for inclusion clusio in a Tier 1 design nclusion de control document, would require prior NRC approval, the underlying g intent nt of the he Tier 2* designation d is maintained.

Ai Should a proposed Tier 2* departure meet any of the e four criteria crite outlined above, then it would not qualify for application of the Tier 2 departure e evaluation eparture evaluatio process proc and would require prior NRC approval.

d Should a Tier 2* departure qualifyualify forr evaluation evaluatio under 10 CFR Part 52, Appendix D, Section VIII.B.5, and be determined mined to involve involve more than a minimal safety significance, it would invol continue to require prior NRC approval approv through hrough the analysis in Section VIII.B.5.b through VIII.B.5.e for the reasons outlined tlined below.

7 Adverse effects are described in NEI-96-07, 6 0 Guidelines for 10 CFR 50.59 Implementation, Revision 1

[ADAMS Accession Number ML003771157]

8 The no more than minimal standard is described in NEI-96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1 [ADAMS Accession Number ML003771157]

Page 17 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

Applicable codes and standards are designated in the plant-specific Tier 2 DCD portion of the VEGP Units 3 and 4 Updated Final Safety Analysis Report (UFSAR). Departures from the plant-specific Tier 2 DCD are controlled by 10 CFR Part 52, Appendix D, Section VIII.B.5.

Regulatory guidance for the evaluation of departures from the UFSAR is contained in NEI 96-07, Guidelines for 10 CFR 50.59 Implementation, Revision 1, and NEI 96-07, Appendix C, Guideline for Implementation of Change Processes for New Nuclear Power Plants Licensed Under 10 CFR Part 52, Revision 0. NEI 96-07, Sections 4.3.1 and 4.3.2 state in part, Although this criterion allows minimal increases, licensees must still meet applicable regulatory requirements and other acceptance criteria to which they are committed (such as contained in regulatory guides and nationally recognized industry consensus standards; e.g., the ASME B&PV Code and IEEE standards). Further, departures from the design, fabrication, construction, testing and R

performance standards as outlined in the General Design Criteria (Appendix pe A to Part 50) are not compatible with a no more than minimal increase standard B Because safety-significant Bec departures from codes and standards would require prior NRC C approval, approva the expectation for ev D safety-significant information changes related to codes and standards tandards to require re prior NRC approval continues to be met.

Regulatory assurance related to design processes is assured ssured d through the in inclusion of keyy design incl ign processes in the VEGP Units 3 and 4 Plant-specific er 1 DCD because cific Tier becau 10 CFR R Part 52, ie ra Section VIII, paragraph B.5.a requires that Tier 2 departures Tier 1 information rtures involving T tion receive mation prior NRC approval. The key design processes included ed in the VEGP 3 and 4 Plant-specific ecific Tier 1 nt-specific DCD that have information designated as Tier er 2* in the VEGP 3 and an 4 plant-specific Tie 2 DCD specificc Tier D are related to the Diverse Actuation System tem (DAS), Protection stem Protectio and Safety oring System ty Monitoring w ft (PMS), piping design acceptance criteria, and HHuman uman F Factors ac actors Engineering ng (HFE).

(HFE)

FE).. Commented [HN33]: Supplement to response to RAI LAR-17-037-1 (MEB) in LAR-17-037S2 (ND-18-0608, Enclosure 10, pg. 5).

VEGP 3 and 4 Plant-specific Tier 1 DCD, Section ction 2.5.1 2.5.1, Diverse Actuation ion System, System cocontains cont a er description as to how the associated hardware and d software soft is to be designed ed during the following life cycle stages:

a) Development phase for hardware and any software e

's b) System test phase c) Installation phase Details of the design process are verified in n associated sociated inspections, inspectio inspecti tests, analyses, and acceptance criteria (ITAAC).

Ai VEGP 3 and 4 Tier 1 Plant -specific DCD,, Section contains a description of the requirements ements software during the following life cycle on 2.5.2, Protection Pr Protect ts for the development ycle stages.

ge develo devel and Safety Monitoring System, of associated hardware and d

a) Design requirements phase, may be referred to as conceptual or project definition phase (Complete) b) System definition phase ase c) Hardware and software development deve phase, consisting of hardware and software design and implementation d) System integration and test phase pha e) Installation phase Page 18 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

Additional requirements listed for software design, testing and maintenance include:

a) Software management including documentation requirements, standards, review requirements, and procedures for problem reporting and corrective action.

b) Software configuration management including historical records of software and control of software changes.

c) Verification and validation including requirements for reviewer independence.

Details of the design process are verified in associated inspections, tests, analyses, and acceptance criteria (ITAAC).

R Various system ITAAC in the plant-specific Tier 1 DCD address piping design. For example, plant-specific Tier 1 Section 2.1.2, Reactor Coolant System, item 6 reads as follows:

Each of the as-built lines identified in Table 2.1.2-2 as designed gned for leak before break ev D (LBB) meets the LBB criteria, or an evaluation is performed d of the protection protect from the dynamic effects of a rupture of the line.

The Tier 2* text in plant-specific Tier 2 DCD Subsections 3.6.2 and 3.9.3 define d the processes sses ie ra (i.e., piping design acceptance criteria) necessary to implement mplement the Tie Tier 1 requirement.

ment. These processes define, for example, how to determine pipe break locations for ASME Code Class 1, 2 and 3 piping systems. Commented [HN34]: Supplement to response to RAI LAR-17-037-1 (MEB) in LAR-17-037S2 (ND-18-0608, Enclosure 10, pg. 5).

w ft Tier 1 DCD, Section 3.2, Human Factors Engineering, Engi Engineering , contains a description on of the proces process to be used when designing the operation and control ontrol centers system s

syst (OCS). The design descrip description descripti for the HFE program states in part, The AP1000 000 human-system human-sy human- s interface HSI) will be developed face (HSI) devel and implemented based upon a human factors engineering (HFE) ors eng HFE) program. Figu Figure 3.2-1 Figur er illustrates the HFE program elements. The HSI scope cop includess the design of the operation ope o pe and control centers system (OCS) and each of the HSI resources. ces. Forr the purposes purp of the HFE program, the OCS includes the main control room (MCR), R), thee remote shutd shutdown workstation shutdo (RSW), the local control stations, and the associated workstations rkstations tions for or each oof these th centers. The

's HSI resources include the wall panel information system, em, alarm system, plant plan information system (nonsafety-related displays), qualified safety-related edd displays, and soft so a and dedicated controls.

Minimum inventories of controls, displays, and visual alerts are spec specified as part of the HSI for specif the MCR and the RSW Ai Because departures from Tier 1 information ion require uire prior NRC approval a via a license amendment request and an exemption request, andd involved olved Tier 2 depar departures require prior NRC approval via dep a license amendment, the expectation on for safety-significant safety-significan information changes related to design safety-d processes to require NRC prior approval continues tto b be met.

The regulatory commitment which would require SNCSN to annotate Tier 2* departures implemented without submitting a license amendment reques request within departure reports submitted in accordance with 10 CFR Part 52, Appendixx D, paragraphs paragraph X.B.1 and X.B.3.b provides additional assurance that the revised departure process s will be implemented i correctly.

The proposed regulatory commitment that would require SNC to develop, implement, and maintain detailed procedural guidance related to how the qualifying criteria would be applied to proposed Tier 2* departures ensures that departures from Tier 2* information with a safety Page 19 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) significance commensurate with Tier 1 will require prior NRC approval. This procedural guidance will be maintained in accordance with SNCs Commitments Management Program for as long as the license condition remains in effect. Commented [HN35]: Response to RAI LAR-17-037-6 (LB4) in LAR-17-037S3 (ND-18-0646, Enclosure 14, pg. 3).

As a result, the proposed change would continue to meet NRC requirements and expectations regarding designation of safety-significant Tier 2 information as Tier 2* and would require NRC review and approval of departures from Tier 2* information that meet the safety significance standard.

The proposed changes do not affect any function or feature used for the prevention or mitigation of accidents or their safety analyses. No safety-related structure, system, component (SSC) or R

function is involved. The proposed changes neither involve nor interface with any SSC accident valuat a

initiator or initiating sequence of events related to the accidents evaluated in the UFSAR, and tion.

therefore, do not have an adverse effect on any SSC design function.

ev D The proposed changes do not affect the radiological source e terms ms (i.e., amounts amoun and types of elease durations) used in the accident radioactive materials released, their release rates, and release ident analyses. The equipment involved in these proposed d changes nges does not af related affect safety-related equipment or any fission product barrier. No system or design gn function or equipment eq ualification qualification ie ra is adversely affected by the proposed changes. The he changes nges do not resu result in a new failure ailure mode, malfunction, or sequence of events that could adversely ely affect a radi rad aterial barrier or radioactive material safety-related equipment. The proposed changes anges nges do not allow for a new fission on product oduct release path, result in a new fission product barrier failure mode, or create crea a new sequence quence of events eve that w ft lures lures.

would result in significant fuel cladding failures.

ect SSCs that This license amendment request does not affect tha are used to contain, th ntain, control, channel, cha er adioact monitor, process or release radioactive or non-radioactive als. The types and quantities materials. qua of en release path iss adversely affected expected effluents are not changed, and no effluent affec by the proposed changes. Therefore, radioactive and non-radioactiveve material al effluents effluent are ar not affected by the proposed changes.

's Plant radiation zones (as described in UFSAR Section n 12.3),

), controls under 10 CFR Part 20, and expected amounts and types of radioactive materials s are not affected by the proposed changes.

als xposures ures do not chang Therefore, individual and cumulative radiation exposures change.

Ai The change activity has no adverse impactt on the emergency mergency plan pla p or the physical security plan implementation, because there are no changes hangess to physical access acc ac to credited equipment inside the Nuclear Island (including containment ment orr the auxiliary building) buil bu and no adverse impact to plant y plant operations or se personnels ability to respond to any security event.

d

4. UATION REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria Require Requir 10 CFR 52.98(f) requiress NRC app approval for any modification to, addition to, or deletion from the terms and conditions ions of a combined license (COL). The proposed change involves the addition of a new COL License Condition 2.D.(13) to specify the regulatory process for evaluating departures from Plant-specific Tier 2* matters and Tier 2 information that involves a change to or departure from Tier 2* information, Paragraphs Page 20 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

VIII.B.5 and VIII.B.6 subject to the conditions and limitations set forth in new License Condition 2.D.(13). Therefore, NRC approval is required prior to making the plant-specific proposed change in this license amendment request.

4.2 Precedent None.

4.3 Significant Hazards Consideration The requested license amendment would amend, for Southern Nuclear Operating R

Companys (SNCs) Vogtle Electric Generating Plant (VEGP) Units 3 and 4, Combined t departure evaluation License (COL) Numbers NPF-91 (Unit 3) and NPF-92 (Unit 4), the process for qualifying departures from Tier 2* information.

ev D An evaluation to determine whether a significant hazards ardss consideration considerat is involved with the proposed amendment was completed by focusing ing on the three standards standa stand set forth th in 10 CFR 50.92, Issuance of amendment, as discussed cussedd below:

belo 4.3.1 Does the proposed amendmentt involve significant increase olve a significa signifi ase in the ie ra probability or consequences off an accident previously previous evaluated?

ccident previou ed?

Response: No.

w ft The proposed changes would uld add a license licens condition co that at would uld allow use ofo th the ocess for Tie Tier 2 departure evaluation process 2 departures, Tier 2* res, whereere such depart departures nimal impact would not have more than a minimal imp im ety. Changing to safety. hanging the crit ccriteria by er form which departures from Tier 2* information are evaluatedated to determine determin if NRC approval is required does not affect the plant itself.

self. Changing hanging tthese ccriteria does not affect prevention and mitigation of abnormal rmal events, e.g., e. accidents, anticipated operational occurrences, earthquakes, hquakes, es, floods and turbine tu missiles, or

's their safety or design analyses. No safety-related elated structure, afety-related structure, system, component (SSC) or function is adversely affected.

d. The changes neither ed. neithe n involve nor interface with any SSC accident initiator or initiating tiating sequence of events, and thus, the probabilities of the accidents evaluated ated in the Updated Upd Final Safety Analysis Ai Report (UFSAR) are not affected.

cted. Because ause the changes cchan do not involve any safety-related SSC or function used to o mitigate an accident, ac the consequences of the accidents evaluated in the FSAR are not affected.

he UFSAR affe a

Therefore, the proposed posed amendment does doe not involve a significant increase in the d

probability or consequences nsequences of an accident acci acc previously evaluated.

4.3.2 Does the proposed amendment create the possibility of a new or different roposed amendme amendmen kind of accident accident previously evaluated?

nt from any ac acc Response: No.

The proposed changes would add a license condition that would allow use of the Tier 2 departure evaluation process for Tier 2* departures, where such departures Page 21 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) would not have more than a minimal impact to safety. The changes do not affect the safety-related equipment itself, nor do they affect equipment which, if it failed, could initiate an accident or a failure of a fission product barrier. No analysis is adversely affected. No system or design function or equipment qualification is adversely affected by the changes. This activity does not allow for a new fission product release path, result in a new fission product barrier failure mode, or create a new sequence of events that would result in significant fuel cladding failures. In addition, the changes do not result in a new failure mode, malfunction or sequence of events that could affect safety or safety-related equipment.

Therefore, the proposed amendment does not create the possibility of a new or R

different kind of accident from any accident previously evaluated.

4.3.3 ificant re Does the proposed amendment involve a significant red reduction in a margin ev D of safety.

Response: No.

The proposed changes would add a license cense condition that would wo w allow use off the ie ra Tier 2 departure evaluation process for Tier er 2* departures, departures where suchh departures mal impact would not have more than a minimal pact to safety.

safety.

The proposed change is not ott a modification, addition additi ad to, or removal emoval of any a plant w ft SSCs. Furthermore, the proposed roposed amendment is not a change ange to procedures procedu or method of control of the nuclear lear plant or any an plant p SSCs.s. Thee only impact of this t

activity is the application of the he current TTier 2 departure rture evaluation proce process to er Tier 2* departures.

Therefore, the proposed amendment does nott involve a significant significa rereduction in a margin of safety.

's Based on the above, it is concluded that the proposedosed amendment amendmen does not involve a significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of no significant hazards azards consideration is justified.

Ai 4.4 Conclusions In conclusion, based on the considerations erations discussed discusse above, (1) there is reasonable discu assurance that the health and d safety ety of the public w will not be endangered by operation in the proposed manner, (2) 2) such activities will be conducted in compliance with the d

Commissions regulations, ns, and (3) the issuance issuanc of the amendment will not be inimical to issuan the common defense e and security or to the health and safety of the public. Pursuant to 10 CFR 50.92, the requested chan change does not involve a Significant Hazards Consideration.

Page 22 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4)

5. ENVIRONMENTAL CONSIDERATIONS The proposed changes would add a license condition that would allow use of the Tier 2 departure evaluation process for Tier 2* departures, where such departures would not have more than a minimal impact to safety.

A review has determined that the proposed license condition requires an amendment to the COLs; however, a review of the anticipated construction and operational effects of the proposed amendment and exemption has determined that it meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:

R (i) There is no significant hazards consideration.

As documented above, an evaluation was completed to o determine determi determ whether or not a significant hazards consideration is involved by focusing g on the three thre standards set forth ev D in 10 CFR 50.92, Issuance of amendment. The Significant nificant Hazards Hazard Consideration determined that (1) the proposed amendment does es not involve nvolve a significant signific increase se in the probability or consequences of an accidentt previously iously evaluated; evaluat oposed (2) the proposed amendment does not create the possibility of a new or different kind of accidentt from any ie ra accident previously evaluated; and (3) the e proposed posed amendment amendm amendme does not ot involve involve in ve a significant reduction in a margin of safety.

ty. Therefore, erefore, it is con concluded thatt the proposed co cant hazards consideration amendment does not involve a significant considera tandards set under the standards forth in 10 CFR 50.92(c), and accordingly, a finding findin find of no significant cant hazards w ft consideration is justified.

(ii) sign sig There is no significant change in the types or significant ease in the amounts of increase o any er effluents that may be released offsite.

The proposed changes would add a license condition ition that at establishes establis a departure evaluation process to determine whether site-specific fic departures Tier 2* information partures from Tie Ti would have more than a minimal impact to safety. y. Thehe proposed changes ch chan are unrelated

's to any aspect of plant construction or operation that would introduce any a change to effluent types (e.g., effluents containing chemicals orr biocides, sanitary system ssyst effluents, and other effluents), or affect any plant radiological non-radiological al or non non--radiological e effluent release quantities.

Furthermore, the proposed changes do o not affect effluentt release path or diminish the fect any effluen Ai functionality of any design or operational al features that a ational are credited with controlling the release of effluents during plant operation.on. Therefore, it is concluded that the requested amendment does not involve a significant nificant change c hange in i the types or a significant increase in the amounts of any effluents released offsite.

s that may be rele d

(iii) There is no significant increase in individual or o cumulative occupational radiation exposure.

The proposed changess would add a llicense condition that would allow use of the Tier 2 departure evaluation process cess for Tier T 2* departures, where such departures would not have more than a minimal impact mpa to safety. Plant radiation zones (addressed in UFSAR mpac Section 12.3) are not affected, and controls under 10 CFR Part 20 preclude a significant increase in occupational radiation exposure. Therefore, the requested amendment does Page 23 of 2324

ND-18-0000 U Updated Request for License Amendment: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S4) not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above review of the requested amendment, it has been determined that anticipated construction and operational effects of the requested amendment do not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Therefore, pursuant to 10 CFR 51.22(b), an environmental impact statement or environmental assessment of the proposed amendment and exemption is not required.

6. REFERENCES None. Rev D ie ra w ft er

's Ai d

Page 24 of 2324

Southern Nuclear Operating Company ND-18-0000 Enclosure 2U Rev D Vogtle Electric Generating Plant (VEGP)

EGP) Units nits 3 and 4 ie ra w ft Updated Exemption xemption Request:

Reques Changes to Tier 2* Departure Evaluat Evaluation Process Eva (LAR-17-037S4) 7-037S4 037S4))

ss er

's Ai d

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

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4) 1.0 Purpose Southern Nuclear Operating Company (SNC), the licensee for Vogtle Electric Generating Plant (VEGP) Units 3 and 4, requests a permanent exemption from certain provisions of 10 CFR Part 52, Appendix D, Design Certification Rule for AP1000 Design, to allow plant-specific departures from Tier 2* matters, and from Tier 2 information that involves a change to or departure from Tier 2* matters, identified in 10 CFR Part 52, Appendix D, Section VIII.B.6, without prior NRC approval for qualifying Tier 2* departures.

Under the current departure evaluation process applicable to Tier 2* information, SNC must seek prior NRC approval through a License Amendment Request (LAR) for any R

proposed change to Tier 2* information, even if SNC can demonstrate that the change results in no more than a minimal impact to safety or improvess safety. ssafe As stated in SECY-17-0075, Planned Improvements in Design Certification tification Tiered Information ev D Designations, [ADAMS Accession Number ML16196A321] A321]

21] OneOne spesspecific lesson is that some information has been designated as Tier 2* when en other her regulatory toolst could have been used instead to ensure a facility is safely designed, signed,, constructed and operated. This results in licensees submitting license amendment nt requests quests (LARs)

LARs)) on

((LARs o topics that may not involve safety significant facility changes. Thus, although lthough the Tie Tier 2* designation nation and ie ra associated departure evaluation processs was intended to require req NRC approval for safety-significant information, in practice, ce, the Tie departure evaluation Tier 2* departu rocess has on process resulted in LARs for departures that are not safety-significant.

safety-signific safety ifi This is consistent nsistent with SNCs experience with the Tier 2* departure evaluation process.

p In order to mitigate miti the w ft regulatory inefficiency associated with this issue, SNC proposes p a site-specific specific permanent permanen perma exemption and license amendmentt that would apply a the existing g Tier 2 departure depa depart evaluation process to some proposed Tier er 2* departures depa and Tier 2 departures departure that tha involve i

er a change to or departure from Tier 2* information, matio provided d the proposedposed Tier 2* d departure does not meet any of the proposed screening criteria eria whichhich would excl exclude Tier 2*

exc departures of high safety significance. Application n of the he Tier 2 departure depa departu evaluation process and the proposed screening criteria would ould ensure sure that any safety-significant

's departures from Tier 2* information would continue inue to require prior NRC N approval, while departures that would improve safety or would ld result in no more mor tha than a minimal impact to safety could proceed as a departure without ut prior NRC approval.

approva The specific provisions of Appendix D from which hic SNC requests requ an exemption are:

x Ai Section II, Definitions, paragraph raph F:

Paragraph II.F provides the definition Tier 2* as the portion of the Tier 2 information finition of T d

designated as such in n the generic Design Control C Document (DCD), which is subject to the change process cess in Section VIII.B.6 VIII.B. of Appendix D. The requested exemption would allow qualifying ifying Tier 2* departures depa departure based on new screening criteria to be subject to the change process cess in Section VIII.B.5 V of Appendix D.Section VIII, Processes for Changes and Departures, tures, Subse tures Subsection B, paragraph 5.a:

Paragraph VIII.B.5.a provides vid the basis for which licensees may depart from Tier 2 vide information without NRC approval. The departure may be taken provided the departure does not involve Tier 1 information, Tier 2* information, or the TS, or requires Page 2 of 9

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4) a license amendment under paragraphs B.5.b or B.5.c of 10 CFR 52, Appendix D, Section VIII. The requested exemption would allow departures from Tier 2 information that involve Tier 2* information not meeting any of the new screening criteria provided the departure did not involve a departure from Tier 1 information, the TS, or require a license amendment under Section 2.D.(13) of the license.

x Section VIII, Processes for Changes and Departures, Subsection B, Tier 2 Information, paragraph 6.b (VIII.B.6.b):

Paragraph VIII.B.6.b requires a licensee who references 10 CFR Part 52, Appendix D to obtain NRC approval prior to departing from the eight identified categories of Tier 2*

R matters. (SNC was previously granted an exemption from Criterion (4), regarding Fire Areas [ADAMS Accession Number ML15191A128].) The e requested re requ exemption would VIII.B for qualifying Tier 2*

allow application of the Tier 2 change process outlined in VIII.B.5 ev D ories departures for the remaining seven identified categorieses of Tier 2* matters, based on new screening criteria. The requested exemption ption does not change cha the list of categories of Tier 2* matters provided in B.6.b.

x Section VIII, Processes for Changes and Departures, res, Subse Subsection ction B, Tier 2 Information, nformation, ie ra paragraph 6.c (VIII.B.6.c):

ragraph VIII.B.6.b Paragraph VIII.B.6.c refers to paragraph VIII.B.6 for thet departure ure process ocess which rences ences 10 CFR Part requires a licensee who references Par 52, 5 Appendix ix D to obtain obta NRC w ft m the 16 approval prior to departing from 16 identified tified ca categories of Tier 2* matters matter s that th wiwill revert to Tier 2 status after thehe plant first acachieves full power.

er. The reque reques requested rocesss outlined in VIII.B.5 exemption would allow application of the Tier 2 change process VI VIII.B for er qualifying Tier 2* departures based on new screening ning criteria.

teria. The re requested exemption does not change the list off categoriess of Tier 2* matters provided p in paragraph B.6.c.

's cal and This request for exemption provides the technical nd regulatory b bas basis to demonstrate that 10 CFR 52.7 and §50.12 requirements are re met with regards to the Tier 2* departure ve.

evaluation process changes identified above.

Ai 2.0 Background The Licensee is the holderr of Combined License Licens Licen Nos. NPF-91 and NPF-92, which d

nd operation of two Westinghouse authorize construction and W Electric Company AP1000 nuclear plants, nameded Vogtle Electric Generating Ge G Plant (VEGP) Units 3 and 4, respectively.

st Part 52 licens The NRC issued the first licen licenses to SNCs VEGP Units 3 and 4 in February 2012.

Changes to the licensing g bas bases fofor those licenses are governed, in part, by 10 CFR grap VIII.B. This portion of the regulations specifies the graph Part 52, Appendix D, Paragraph change process for Tier 2* information and requires NRC approval for all departures from Tier 2* information.

Page 3 of 9

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4)

SNC was the first applicant to receive 10 CFR Part 52 licenses and begin construction under the 10 CFR Part 52 regulatory processes. Prior to the associated construction experience, the impact of departures to Tier 2* information during construction could not be entirely understood. Experience has shown that more departures are needed than were initially expected.

SNC has identified several examples of departures from Tier 2* information that were not safety-significant, but nonetheless required prior NRC approval through a LAR.

Application of the Tier 2 departure evaluation process to these proposed departures would have concluded with a determination that the proposed change was not safety-significant and could therefore have been processed as a departure not requiring prior NRC approval R

consistent with 10 CFR Part 52, Appendix D, Section VIII paragraphs B.5.b and B.5.c.

Specific details of the examples supporting this request forr exemption e

exem are provided in Section 2 of the associated License Amendment Requestt provided iin Enclosure 1 of this ev D letter.

SNC acknowledges that the Commission employed oyed a Tier 2* designation designa to capture apture certain significant AP1000 design information existing ng in Tier 2 that theth Commission sion did not want changed without prior approval (see ee 71 Fed. ed. Reg. 4474 (Jan. 27, 2006)). In ie ra SECY-17-0075, the NRC discussed the reasons easons for designating some Tier 2 information as Tier 2* and indicated that Tier 2* information ation is intended nformation ntended to have substantial ntial safety ubstantial significance, commensurate with information rmation designated as Tier 1. However, er, SECY owever, SECY SE -17 7-0075 suggests that the Tier 2* scopepe identified in previous ope previou previ design certifications, ons, such as w ft AP1000, may be broader than necessary, ecessary, and includes includ information appropriately tion more appropriatel appropr designated as Tier 2; e.g., background nd information and a other information formation on of minimal safety sa significance. Furthermore, SNCs experience rience has demonstrated ated that hat not every chachange c to er information designated as Tier 2* has an impact mpac on the safety-significant ificant nature, if any, of fety-significant the information. As such, SNC proposes to invoke a process rocess functionally functiona consistent con with departure evaluation processes applied by current nt applicants plicants for the ccertification of designs that contain no Tier 2* information. Specifically, fically, SNC is requesting requesti a site-specific request

's amendment that would allow qualifying departures om Tier 2* information res from informa inform to be evaluated under the existing departure evaluation processess for Tier 2 departures departur in 10 CFR Part 52, depa Appendix D, Paragraphs VIII.B.5.a through h VIII.B.5.e.

II.B.5.e. Qualification Qualifica Qualificati of Tier 2* changes for the Tier 2 departure process would be determinedtermined by applying app screening criteria to proposed changes to Tier 2* information ion in order exclu changes to Tier 2* information der to exclude Ai that involve safety significance e commensurate mmensurate wit with Tier 1 information. Such non-qualifying Tier 2* changes es would ould continue to require prior NRC approval in accordance with 10 CFR Partt 52, Appendix D, Paragraph Para VIII.B.6. Implementation of the proposed license condition permanent n requires a permanen perma exemption from the current provisions d

of 10 CFR Part 52, Appendix pendix D, to allow pla plant-specific departures from Tier 2* matters, plan and from Tier 2 information mation that involves a change to or departure from Tier 2* matters, identified in 10 CFR Part 52, 2, Appendix D, Paragraph VIII.B.6, without prior NRC approval.

Page 4 of 9

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4) 3.0 Technical Justification of Acceptability The departure evaluation process proposed by SNC would apply screening criteria to proposed Tier 2* departures to determine if the departure would qualify to be evaluated using the Tier 2 departure evaluation criteria in 10 CFR Part 52, Appendix D, Paragraphs VIII.B.5.a through VIII.B.5.e to identify those departures that require prior NRC approval.

Tier 2* departures that do not qualify because they meet one or more of the screening criteria would continue to be submitted for prior NRC approval in accordance with 10 CFR Part 52, Appendix D, Paragraph VIII.B.6.

The new departure evaluation process for Tier 2* departures that do not meet any of the R

proposed new screening criteria would be the same as existing processes governing Tier 2 information. In general, current regulations allow Tier 2 information info to be changed if a departure evaluation determines that the change only results in a minimal increase ev D in the frequency or severity of an adverse event. Regulations ons governing ations govern Tier 2 departures are contained in 10 CFR Part 52, Appendix D, Paragraph aph VIII.B.5, I.B.5, and a provide the departure evaluation method used to determine if Tier 2 departures require re prior NRC approval. SNC proposes to use this same departure re evaluation process eparture p pro for qualifying ualifying ng Tier 2* departures that do not meet any of thee new screening criteria.

creening criteri criteria ie ra The requested exemption would only allow a change to the departure screening ening and evaluation process for Tier 2* departures ures and would not actually actu implement ment any changes to the design, construction, or operation ation of the plant. The proposed p change hange does oes not n affect w ft any function or feature used for thee prevention and mitigation mit of accidents ents or their safety s

analyses. No safety-related structure, e, system, component comp com (SSC)

C) or function unction is involved.

involv involve er The requested exemption would accomplish plish the th goal of focusing ocusing licensee and rregulator resources on the more safety-significant change a activities es by expanding the sc scope of the existing departure evaluation process in 10 CFR Part 52, Appendix D, parag paragraph VIII.B.5, pa for Tier 2 departures to apply to qualifying Tier 2* departures ures and Tier 2 departures that

's involve departures from qualifying Tier 2* matters. s. The proposed atters. propose propo exemption and amendment also address issues discussed in n the NRCs Part Part 52 Implementation Self-Assessment Review Report (July 2013) [ADAMS AMS Accession No.

ADAMS N ML13196A403], SECY-17-0075, Planned Improvements in Design sign Certification ertification Tiered Information Designations

[ADAMS Accession Number ML16196A321], 96A321)), and SECY-96-077, SECY SECY-9 Certification of Two Ai Evolutionary Designs, April 15, 1996 96 [ADAMS Accession No. ML003708129].

DAMS Accessio Detailed technical justification n supporting pporting this request req re for exemption is provided in Section 3 of the associated License se Amendment Amendm t Request Amendmen R in Enclosure 1 of this letter.

4.0 d

Justification of Exemption mption 10 CFR 52.7 governs the he granting gr grantin Part 52, with consideration governed gove of exemptions from the requirements of 10 CFR by the requirements of 10 CFR 50.12. Since SNC has identified a need to deviate from 10 CFR Part 52, Appendix D regulations as discussed in Enclosure 1 of the accompanying License Amendment Request, an exemption from the regulations is needed.

Page 5 of 9

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4) 10 CFR 52.7 and §50.12 state that the NRC may grant exemptions from the requirements of the regulations provided four conditions are met: 1) the exemption is authorized by law

[§50.12(a)(1)]; 2) the exemption will not present an undue risk to the health and safety of the public [§50.12(a)(1)]; 3) the exemption is consistent with the common defense and security [§50.12(a)(1)]; and 4) special circumstances are present [§50.12(a)(2)].

The requested exemption satisfies the criteria for granting specific exemptions, as described below.

1. This exemption is authorized by law R

The NRC has authority under 10 CFR 52.7 and §50.12 to grant exemptions from the requirements of NRC regulations. Specifically, 10 CFR R 50.12

50. and §52.7 state that the NRC may grant exemptions from the requirements nts of of 10 CFR Part 52 upon a proper showing. No law exists that would preclude udee the changes change chan covered by this ev D exemption request. Additionally, granting of the proposed osed exemption exemptio does not result 54, as amended, or th in a violation of the Atomic Energy Act of 1954, ions the Commissions regulations.

ie ra n is authorized Accordingly, this requested exemption uthorized by law, law, as required d by 10 CFR 50.12(a)(1).

2. sent an undue risk to the health and safety This exemption will not present afety of the w ft public departu epar The proposed exemption would allow departures ier 2* information from Tier formation using usin the Tier 2 departure process when those hose departures de doo not meet any of the t new er wo wou screening criteria. The exemption would uthorize ze departures only authorize epartures fro from Tier 2*

information without NRC approval when those departures es are determined de determ to have no more than a minimal impact to safety. Because use the exemption exemptio exemp would allow departures from Tier 2* information without out NRC RC approval onlyo after evaluation

's Conditio and application of Conditi against the screening criteria defined in a new License Condition eria, the Tier 2 departure evaluation criteria,ia, any safety-significant safety safety-signifi sig departures would oval.

continue to require prior NRC approval.

Ai xemption from 10 CFR Therefore, the requested exemption C CF 52, Appendix D,Section II, III, paragraphs paragraph F, and Section VIII, agraphs B.5.a, BB.6.b, and B.6.c would not present th and an undue risk to the health d safety of the public.

pub p

3. The exemption is consistent with the common co defense and security application of the d

The exemption would allow a departu approval only if: a. the change departure from Tier 2* information without prior NRC change is q e new screeni screenin qualified for the revised change process by the equired by existing departure evaluation criteria for Tier 2 equire approval is not required mptio would not alter the design, function, or operation of any mption information. The exemption screening criteria; and b. it were determined that NRC plant equipment that is necessary to maintain a safe and secure status of the plant.

The proposed exemption has no impact on plant security or safeguards procedures, systems, or equipment.

Page 6 of 9

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4)

Therefore, the requested exemption is consistent with the common defense and security.

4. Special circumstances are present 10 CFR 50.12(a)(2) lists six special circumstances for which an exemption may be granted. Only one of these special circumstances need be present before granting an exemption request. In this case, two of the six special circumstances are present, specifically 10 CFR 50.12(a)(2)(ii) and (iii).

4.1 Application would not serve the underlying purpose of the rule 10 CFR 50.12(a)(2)(ii) defines special circumstances purpose of the rule or is not necessary to achieve ces as the regulation in the particular circumstances would not chieve the rule. The rule under consideration is 10 CFR Part 52, specifically Section VIII, the departure evaluation no serve the underlying hieve the underlying u

und Ai a when [a]pplication of d

purpose of 5 Appendix D, ation process. Certain Tier information is identified as Tier 2* to reflectt the potential saf er 2 ance of safety significance the Tier 2* information. The NRC C was specifically concerned con withh certain rtain significant information [that] only sts in Tier 2 [that]

y exists [that the Commission mission ission does R

not want [] to be changed without ut prior NRC approval.

ap 71 1 Fed.d. Reg. at derlying purpose of req 4474. Accordingly, the underlying requiring prior NRC approval for departures from Tier 2* information is to prevent pre preve potentially ally safety-significant safety ety--significant s

changes to plant-specific information without fic DCD Tier 2 informa ut priorr NRC review revie and ev approval. However, compliance mpliance with 10 CFR Part 52, Appendix ppendix D, Sec Section Sect VIII, B.6.a., currently requires res the licensee lice to obtain btain NRC approval approva fo for any change to Tier 2* information - eveneve those havingaving no o more than a minimal impact to safety.

ie Because the exemption would allow departures approval only after evaluation against License Condition and application w

evaluation criteria for Tier 2* departures, would continue to require prior or NRC C approval.

ures from Tier 2 st the screening criteria n of the Tier epa safety sa 2* without NRC crite defined in a new departure er 2 depa screening and epartures,, any safety-significant departures departures er Furthermore, the requestedsted exemption would wou only allow a change to the departure screening and evaluation aluation process for Tier 2* departures and would not actually implement ment any changes to the th design, construction, or operation of the plant. The proposed sed change does doe not affect any function or feature used

's for the prevention ntion and mitigation mitigation of accidents or their safety analyses. No safety-related ed structure, system, ccomponent (SSC) or function is involved.

Therefore, e, application of 10 CFR C 52, Appendix D,Section II, paragraph F, and Section VIII, paragraph paragraphs B.5.a, B.6.b, and B.6.c, in the particular pa discu discusse circumstances discussed in this request, is not necessary to achieve the underlying purpose se of o the rule.

Page 7 of 9

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4) 4.2 Compliance would result in undue hardship 10 CFR 50.12(a)(2)(iii) defines special circumstances as when [c]ompliance would result in undue hardship or other costs that are significantly in excess of those contemplated when the regulation was adopted, or that are significantly in excess of those incurred by others similarly situated. The NRCs goal was to identify only that significant information for which prior approval was required if changes were proposed to be made. It follows then that the NRCs assessment of the compliance obligation for licensees related to the Tier 2*

designation would be limited to those instances involving safety-significant departures from this Tier 2* information.

R The current departure evaluation process hass no mechanism whereby departures that have minimal bearing on the safety-significant ev D information can be made without NRC approval.

corresponding benefit. The requested exemption of focusing licensee and regulator resources change activities by expanding the e scope fety--signifi fety sign proval. Compliance significant costs and delay, both to SNC and to the NRC, mption would Com C

N nature of Tier 2*

wou d accomplish woul rces on the more m

acco imposes without a thee goal safety-significant gnificant e of the existing departure evaluation ant ie ra process in 10 CFR Part 52, Appendix pendix D, VIII.B.5, for Tier T 2 departures Ti res to apply tures to qualifying Tier 2* departures res and Tier 2 departures departur that involve departu olve departures from qualifying Tier 2* matters; thereby minimizing minim mini anyy undueue hardship associated with the current rent requirement for prior pri NRC approval p proval off any change w ft to Tier 2* information, regardless of its safety-significance.

safe safet nce.

Therefore, compliance withth 10 CFR CF Part 52,, Appendix pendix D, Section Se Secti II, er paragraph F, and Section VIII, I, paragraphs par pa B.5.a, B.6.b, 6.b, and B.6.

B.6.c, B.6.c in the particular circumstances discussed in this request, est, would result resu in undue resul hardship.

5.0 Risk Assessment

's A risk assessment was determined to be not applicable to add address the acceptability of this Ai request.

6.0 Precedent Exemptions The NRC has long ensuring that departures d

ng used screenings and evaluations as a regulatory tool; e.g., 10 CFR 50.59. The change prior NRC approval through gh an LAR process for departures from T process for Tier 2 information has been effective at change proc proce es that would result re in more than a minimal impact to safety require LAR. SNC proposes to use the same departure evaluation m Tier Tie 2* information that do not meet any of the criteria specified in new License Condition 2.D.(13). SNCs proposal is consistent with the statement in the NRCs Principles of Good Regulation, Regulatory activities should be consistent with the degree of risk reduction they achieve.

Page 8 of 9

ND-18-0000 U Updated Exemption Request: Changes to Tier 2* Departure Evaluation Process (LAR 037S4) 7.0 Environmental Consideration The Licensee requests a permanent exemption from certain provisions of 10 CFR Part 52, Appendix D, Design Certification Rule for AP1000 Design, to allow the application of screening and the existing Tier 2 departure evaluation process to proposed Tier 2*

departures and departures from Tier 2 information that involves a change to or departure from Tier 2* matters, and that do not meet any of the criteria of new License Condition 2.D.(13). However, the Licensee evaluation of the proposed exemption has determined that the proposed exemption meets the eligibility criteria for categorical exclusion set forth R

in 10 CFR 51.22(c)(9).

Based on the above review of the proposed exemption, the e Licensee License has determined that the proposed activity does not involve (i) a significant antt hazards coconsideration, (ii) a ev D significant change in the types or significant increase in the e amounts of any a effluents that may be released offsite, or (iii) a significant increasencrease e in individual individua or cumulative ative occupational radiation exposure. Accordingly, y, thee proposed exemption ex exem meets ets the eligibility criteria for categorical exclusion set et forth in 10 CFR 51. 51.22(c)(9). Therefore, ie ra pursuant to 10 CFR 51.22(b), an environmental tal impact statement onmental state or environmental nvironmental vironmental assessment of the proposed exemption is not required.

requ Specific details of the environmental all considerations supporting suppo sup this request equest for or exemption ex w ft are provided in Section 5 of the associated License Amendment A nt Request quest provided provided in provid Enclosure 1 of this letter.

8.0 Conclusion er The proposed changes to the COL allow the application ion of screening plication screen criteria to identify

's Tier 2* departures that require prior NRC approval,oval, followed by applic application of the existing appli Tier 2 departure evaluation process to the remaining maining plant-specific emaining plant plant--specific spec Tier 2* departures that do not meet any of the screening criteria defined ed in new License Licens Condition 2.D.(13) and Licen departures from Tier 2 information thatt involveve departures fromfro this same Tier 2* matter.

Ai The exemption request meets the requirements equirements ts of 10 CFR CF 52.7, Specific exemptions and 10 CFR 50.12, Specific exemptions.ns. Specifically, exemption request meets the criteria ecifically, the ex exe of 10 CFR 50.12(a)(1) in that the he request quest is authorized authorize a uthori by law, presents no undue risk to public health and safety, and is consistent with the common defense and security.

d Furthermore, approval of this request does notno result r in a significant decrease in the level of safety, satisfies the underlying purpose of the AP1000 Design Certification Rule, and would not perpetuate e undue hardship to the th Licensee.

9.0 References.

None.

Page 9 of 9

Southern Nuclear Operating Company ND-18-0000 R

Enclosure 3U ev D Vogtle Electric Generating Plant (VEGP)

VEGP)) Units 3 and an 4 ie ra Updated Proposed Changes w ft nges to Licensing Basis (LAR-17-037S4)

R-17 17-037S4 4)

Bas B Documents ments er

's Ai d

Insertions Denoted by Blue Underlin Underline and an Deletions by Red Strikethrough Omitted text is identified by three asterisks ( * * * )

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

ND-18-0000 U Updated Proposed Changes to Licensing Basis Documents (LAR-17-037S4)

Revise Combined License (COL) License Condition 2.D, by adding new condition (13), to address the Tier 2* Change Process, as follows:

D. The license is subject to, and SNC shall comply with, the conditions specified and incorporated below:

(13) Departures from Plant-specific DCD Tier 2* Information (a) SNC is exempt from the requirements of 10 CFR Part 52, Appendix D, Paragraphs II.F and VIII.B.6 that invoke the Tier 2* change process that requires R

prior NRC approval via a license amendment for departures from Tier 2*

information; and Paragraph VIII.B.5.a for Tier 2 information matio that involves a change to, or departure from, Tier 2* information; except for fo departures from ev D Tier 2* information that:

1. Involve design methodology or construction uction materials that deviate d from a code or standard credited in the plant-specific ant-specific ecific DCD for establishing est the he criteria for the design or construction ction off a structure, system, syst sy or component mponent ent (SSC) important to safety, ie ra

2. Result in a material change e to a design process d described in n the plant-plan plant -

specific DCD that is used ed to implement an indu industry standard ard orr endorsed end regulatory guidance, w ft

3. Result in a material change to the fu fuel ccriteria evaluation uationn process, the fuel fue f

principal design requirements, ment orr nuc ments, nu nuclear design n of fuel and reactivity control system, or; result inn any change ch to the maximummum fuel rod ave a

average Commented [HN36]: Response to RAI LAR-17-037-9 er burn-up limits; or result in anyy change c to small break reak LOCA analysis analy (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 4).

methodology described in UFSAR Subsections 15.6.5.4B 15.6.5.4B.2.2 or 15.6.5.4B.2.3, or Commented [HN37]: Response to RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 9).

's

4. Adversely affect the containment debris s limits or debris screen s design Commented [HN38]: Conforming change for response to criteria, or RAI LAR-17-037-4 (SCVB) in LAR 17-037S2 (ND-18-0608, Enclosure 12, pg. 8).

5. Result in a change to the RCP type ype (canne (canned mot motor design).

Commented [HN39]: Response to RAI LAR-17-037-4 (b) The licensee may depart from m the Tierr 2* matters identified ide id in VIII.B.6 b and (SCVB) in LAR 17-037S2 (ND-18-0608, Enclosure 12, pg. 8).

Ai VIII.B.6.c, except as described bed in n License Conditio Condit Condition 2.D.(13)(a), using the NOTE: The marked text in ND-18-0608 used the word and provisions of Paragraph VIII.B.5 for Tier 2 departures.

d depa but it was subsequently determined that or was more appropriate.

Commented [HN40]: Response to RAI LAR-17-037-3 d

(MCB) in LAR 17-037S2 (ND-18-0608, Enclosure 11, pg. 4).

Page 2 of 3

ND-18-0000 U Updated Proposed Changes to Licensing Basis Documents (LAR-17-037S4)

Revise Updated Final Safety Analysis Report page footers that contain a Tier 2* note as follows:

• In accordance with the departure evaluation process specified in License Condition 2.D.(13), NRC Staff approval is may be required prior to implementing a change in this information.

Rev D ie ra w ft er

's Ai d

Page 3 of 3

Southern Nuclear Operating Company ND-18-0000 Enclosure 4U Rev D Vogtle Electric Generating Plant (VEGP)

EGP) Units nits 3 and 4 ie ra w ft Updated d Reviewers Aid Proposed Tier 2* Departure Eval Evaluation Process Evaluati (LAR-17-037S4) 7-037S4 037S4))

ss er

's Ai d

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

ND-18-0000 U Updated Reviewers Aid - Proposed Tier 2* Departure Evaluation Process (LAR-17-037S4)

Proposed Departure Evaluation Process Proposed Tier 2* Commented [HN41]: Add decision box for Qualifying Departure Criterion 5 - RCPs Response to RAI LAR-17-037-3 (MCB) in LAR 17-037S2 (ND-18-0608, Enclosure 11, pg. 4).

Commented [HN42]: Revise decision box for Qualifying Criterion 3 - Fuel el Involve design methodology or construction materials that deviate from a code or standard Yes Qualifying Criterion Response to RAII LAR-17-037-9 LAR-17 (SRSB) in LAR-17-037S3 credited in the plant-specific DCD for 1 (ND-18-0646, Enclosure 17, pgs .4 & 9).

establishing the criteria for the design or R

construction of a structure, system, or Commented mented [HN4

[HN43]: Revise evise decision box for Qualifying component (SSC) important to safety Criterion 4 - Screens No Response to RAI LAR-17-037-4 LA (SCVB) in LAR 17-037S2 (ND 18-0608, Enclos (ND-18-0608, Enclosure 12, pg. 8).

ev D NOTE: The marked mar text in ND-18-0608 used the word and ut it was subsequently determined that or was more but Result in a material change to a design Yes appropriate.

prop process described in the plant-specific DCD Qualifying Criterion ion that is used to implement an industry standard 2 or endorsed regulatory guidance ie ra No w ft Result in a material change to the fuel criteria evaluation process, the fuel principal design er requirements, nuclear design of fuel and reactivity control system, or maximum fuel rod average burn-up limits Qualifying Criterion Qualifyin 3

No Yes

's Submit license Ai Qualifying fying Criterion Yes amendment request Adversely affect the debris screen design 4 (Paragraph VIII.B.6.b criteria or VIII.B.6.c)

No d Go to Appendix D, Paragraph VIII.B.5.a Page 2 of 3

ND-18-0000 U Updated Reviewers Aid - Proposed Tier 2* Departure Evaluation Process (LAR-17-037S4)

Proposed Departure Evaluation Process Go to Appendix D, Paragraph VIII.B.5.a R

Yes Involve Tier 1 or TS (Paragraph VIII.B.5.a) ev D No ie ra w ft More than han minimal impact imp (Paragraph agrap VIII.B.5.b)

Yes er o

No

's Substantial increase Submit license S

Ex-vessel severe Yes es amendment request accident (Paragraph VIII.B.5.e)

(Paragraph VIII.B.5.c) c)

Ai No Document compliance with 10 CFR 50.150 d

Ye Yes Aircraft craft impac assessment a impact affected (Paragraph VIII.B.5.d)

No Implement departure Page 3 of 3

Southern Nuclear Operating Company ND-18-0000 Enclosure 5U Rev D Vogtle Electric Generating Plant (VEGP)

EGP) Units 3 and 4 ie ra w ft Updated d Reviewers Aid Tier 2* Matters ers Analysis Summary (LAR-17-037S4) 7-037S4 037S4)

Sum S

er

's Ai d

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

nsists

ND-18-0000 U Updated Reviewers Aid - Tier 2* Matters Analysis Summary (LAR-17-037S4)

Tier 2* Analysis ResultsSection VIII.B.6.b Selected for (Tier 2* Matters that additional Do Not Expire at Full Power) screening Basis Associated Criteria 1 Maximum fuel rod average burn- Yes Not addressed in Tier 1 Result in a material change to the fuel criteria up. evaluation pro process, the fuel principal requirements, nuclear design of fuel and al design desig id reactivity control system, orr maximum m fuel fue rod average burn-up limits.Result Result in any change to the maximum fuel tf uel rod average b A

burn-up limits; Commented [HN44]: Conforming change in response to RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 4).

2 Fuel principal design Yes Not addressed ddressed in Tier 1 Result in a materialterial change ch to the fuel requirements.

a principal pal design material esign requirements, terial change requiremen requirem hange to the fuel Result in a fu criteria evaluation process, cess, the fuel principal princ prin design requirements, r r's nuclear uclear design of fu fuel and reactivity control system, stem, or maxim m

maximum fuel rod average burn-up limits..

limits D e 3 Fuel criteria evaluation process. Yes Not addressed in n Tier 1 Result in a material change to the fuel criteria evaluation evalua va process, Result in a material echange c

cha tthe th w

han to the fuel criteria evaluation process, h fuel principal design requirements, nuclear design of fuel and reactivity control system, or maximum fuel rod average burn-up limits.

4 Fire areas. N/A Previous exem exemptio exemption re-designated VEG VE VEGP v 3 and i N/A Page P

e2 of 6 R

ND-18-0000 U Updated Reviewers Aid - Tier 2* Matters Analysis Summary (LAR-17-037S4)

Section VIII.B.6.b Selected for (Tier 2* Matters that additional Do Not Expire at Full Power) screening Basis Associated Criteria 4 fire area figures as Tier 2

5 Reactor coolant pump type. NoYes AdequatelyNot N/ARes in a change to the RCP N/AResult P type (canned addressed in Tier 1 motor de design). Commented [HN45]: Response to RAI LAR-17-037-3 id(MCB) in LAR 17-037S2 (ND-18-0608, Enclosure 11, pg. 4).

6 Small-break loss-of-coolant NoYes 10 CFR 50.46 and N/ Resu in any change N/AResult e to small break rea accident (LOCA) analysis adequately addressed by by LOCA an analysis methodology thodology desc described in i

methodology. paragraph VIII.B.5Safety significance Safety y UFSAR FSA Subsections tf 15.6.5.4B.2.3.

15.

ons 15.6.5.4B.2.2 or A Commented [HN46]: Response to RAI LAR-17-037-9 (SRSB) in LAR-17-037S3 (ND-18-0646, Enclosure 17, pg. 9).

7 Screen design criteria. Yes Paragraph graph VIII.B.5 may Adversely y affect the ccontainment debris limits or Commented [HN47]: Response to RAI LAR-17-037-4 not work well in all cases; safety a

debriss screen en design criteria.

criteri crit (SCVB) in LAR 17-037S2 (ND-18-0608, Enclosure 12, pg. 8).

significancee r r's 8 Heat sink data for containment No Adequately addressed N/A A

pressure analysis. by paragraph VIII.B.5 5 D e e w v i Page P

e3 of 6 R

ND-18-0000 U Updated Reviewers Aid - Tier 2* Matters Analysis Summary (LAR-17-037S4)

Section VIII.B.6.c Selected for (Tier 2* Matters that additional Expire at Full Power) screening Basis Associated Criteria 1 Nuclear Island Structural No Adequately addressed in N/A Dimensions. Tier 1 2 American Society of Mechanical No Adequately addressed in N/A Engineers Boiler & Pressure Tier 1; 10 CFR 50.55a; Vessel Code (ASME Code) piping design and welding Paragraph VIII.B.5 id restrictions, and ASME Code Cases.

A 3 Design Summary of Critical Yes Safety significance ignificance Involve olve design sign methodology methodol or construction Sections. materials erials that deviate from a code or standard

'r s credited dited in the plant plant-specific DCD for establishing ablishing the c criteria for the design or construction ofo a structure, system, or e

compone (SSC) important to safety.

component 4 American Concrete Institute Yes Safety significance cance ance Involve vo design methodology or construction (ACI) 318, ACI 349, American National Standards Institute/American Institute of emat w

materials that deviate from a code or standard credited in the plant-specific DCD for c

establishing the criteria for the design or Steel Construction construction of a structure, system, or (ANSI/AISC)-690, and American Iron and Steel i component (SSC) important to safety.

Institute (AISI), Specification for the Design of Cold Formed Steel Structural Members, Part e v Page P 4 of 6 R

ND-18-0000 U Updated Reviewers Aid - Tier 2* Matters Analysis Summary (LAR-17-037S4)

Section VIII.B.6.c Selected for (Tier 2* Matters that additional Expire at Full Power) screening Basis Associated Criteria 1 and 2, 1996 Edition and 2000 Supplement.

5 Definition of critical locations No Adequately addressed in N/A and thicknesses. Tier 1 6 Seismic qualification methods No Adequately addressed ed N/A id and standards. .B.5 by paragraph VIII.B.5 tf A Nuclear design of fuel and Yes Not addressed ddressed in Tier 1 Result in n a material terial change ch to the nuclear 7

reactivity control system, except burn-up limit.

significan and safety significance a

design Result n of fueluel and reactivity reactiv control system; sult in a material change chan to the fuel criteria evaluation luation process, tth the fuel principal design r r's requirements, uirements, nuclenuclear design of fuel and reactivity ctivity control con system, or maximum fuel rod average burn burn-up limits.

D e 8 Motor-operated and power- No Adequately addressed ressed in N/A operated valves. Tier 1 and byy paragraph Yes VIII.B.5 Safetyy Significance nificance w

Result in a material change to a design process 9 Instrumentation and control system design processes, methods, and standards.

i e described in the plant-specific DCD that is used to implement an industry standard or endorsed v regulatory guidance.

Page P

e5 of 6 R

ND-18-0000 U Updated Reviewers Aid - Tier 2* Matters Analysis Summary (LAR-17-037S4)

Section VIII.B.6.c Selected for (Tier 2* Matters that additional Expire at Full Power) screening Basis Associated Criteria 10 Passive residual heat removal No Adequately addressed in N/A (PRHR) natural circulation test Tier 1 and COL (first plant only).

11 Automatic depressurization No Adequately addressed in N/A system (ADS) and core make-up tank (CMT) verification tests Tier 1 and COL id (first three plants only). A 12 Polar crane parked orientation. No Does not meet et criteria eria for N/AA erefore, Tier 1; therefore, tf paragraphaph VIII.B.5 will adequately quately uately address 13 Piping design acceptance Yes Safety Significance a

Result sult in a material change chan to a design process criteria. described ribed in the plant plan plant-specific DCD that is used r r's mplement an ind to implement industry standard or endorsed regulatory gulatory guidance.

guidan gu 14 Containment vessel design No D e Adequately addressed ssed in N/A parameters, including ASME g graph Tier 1 and paragraph Code,Section III, Subsection VIII.B.5 NE.

15 Human factors engineering. Yes Paragraph graph VIII.B.5 may w

Result in a material change to a design process e

nott work well and sa safety described in the plant-specific DCD that is used significance ficance v i to implement an industry standard or endorsed regulatory guidance.

Page P

e6 of 6 R

ND-18-0000 U Updated Reviewers Aid - Tier 2* Matters Analysis Summary (LAR-17-037S4)

Section VIII.B.6.c Selected for (Tier 2* Matters that additional Expire at Full Power) screening Basis Associated Criteria 16 Steel composite structural Yes Safety significance Involve design methodology or construction ctio ction module details. materials that deviate from a code or standard ndar credited edite in the plant-specific DCD for establishing the criteria for the design establis establish sign or construct construction of a structure, system, stem,, or component (S (SSC) important to safety.

safety y.

id a

tf A r r's D e e w v i Page P

e 7 of 6 R

Southern Nuclear Operating Company ND-18-0000 Enclosure 6U Rev D Vogtle Electric Generating Plant (VEGP)

EGP) Units 3 and 4 ie ra w ft Updated Tier 2* Departure Example d Reviewers Aid e Not Requiring Requirin Prior (LAR-17-037S4) 7-037S4 037S4)

P NRC Approval oval er

's Ai d

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

sists o

ND-18-0646 U Updated Reviewers Aid - Tier 2* Departure Example Not Requiring Prior NRC Approval (LAR-17-037S4)

Example application of the LAR-17-037 proposed process to a proposed change to Tier 2*

material which results in a determination that prior NRC approval is not required:

In Vogtle 3&4 LAR-13-006R [ML13240A217], SNC proposed the following change in Enclosure 1, page 3 of 15, Summary

Description:

The proposed changes in the requirements for detailed design of structural wall modules used to construct containment internal structures and portions of the auxiliary building are necessary to address regulatory compliance for design of shear studs and internal trusses.

The proposed changes would depart from plant-specific Design Control Document R

(DCD) Tier 2* and associated Tier 2 material incorporated into the Updated Final ment for design spacing of Safety Analysis Report (UFSAR) by revising requirements shear studs and wall module trusses and the design gn of stru struc structural elements of the trusses such as angles and channels. hese ese revisions These revisi are to address ev D interferences and obstructions that may causee a change hange to the design de spacing in acing exceeds a local area. In each case where the spacing ceeds the the design des spacing,g, an evaluation supporting the increase will be completed to demonstrate dem d that the revised spacing is in conformance with h design and analysis requirements re s identified ie ra in the UFSAR. The designation of maximum um design spacing spaci is revised spacin d for the stud uce the spacing and truss spacing to reduce e potential confusion confu about the application of fabrication tolerances.

w ft The proposed changes include lude revising a note on o UFSAR Figure e 3.8.3-8, 3.8.3 8, Sheet S 1 to clarify that the stud spacing g specified is a design d value e not an exact dimens dimension.

dimensi A tolerance for stud spacing, consistent withw American can Welding Society Societ (AWS)

(A er D1.1 requirements, is added to the e note.

note The proposed changes include revision of the e weld symbol Tier 2* figure to ymbol on a Tie change the symbol to a symbol that indicates cates complete joint penetration p and change to the associated Tier 2 text to clarifyy that the weld symbol sy used in the

's figure indicates complete joint penetration.

tion.

Consider the proposed process flow chart Enclosure hart provided in Encl Enclo 4 of this LAR, with revising requirements for design spacing cing of shear studs and wall module trusses as the Ai Proposed Tier 2* Departure entry oval. The details of tthe proposed changes to spacing of shear studs and wall module trusses usses are found in LAR-13-006 LA Enclosure 1, Sections 2 and 3.

d Criterion 1 asks, Yes/No,No, does the PropProposed Tier 2* Departure Involve design Propos methodology or construction deviate from a code or standard credited in the uction materials that de plant-specific DCD for or establishing the criteria crite for the design or construction of a structure, system, or componentnt (SSC) important tot safety.

In this example, the answer wer to this question would be No. For this proposed change to Tier 2* material, SNC requested sted flexibility in the placement of studs and trusses within the bounds of the AP1000 DCD-endorsed ACI 349-01, AISC N690-94, and AWS D1.1 standards as described by UFSAR 3.8.3 et. al. The requested change eliminated potential confusion by deleting the adjective maximum from Tier 2* text and Figures describing Page 2 of 3

ND-18-0646 U Updated Reviewers Aid - Tier 2* Departure Example Not Requiring Prior NRC Approval (LAR-17-037S4) the design spacing of the shear studs and trusses inside the steel-concrete composite modules. No deviation from a code or standard was requested.

Of particular note is that the published NRC SER for LAR-13-006 [ML13266A164]

concurred that no deviation from a code or standard was requested by this proposed change and that the proposed changes were within the scope and technical requirements of the applicable codes, standards, and design methodology of the steel-concrete composite structures as described by the AP1000 DCD and Vogtle UFSAR.

Qualifying Criterion 2 asks if the proposed Tier 2* departure will, Result in a material change to a design process described in the plant-specific DCD that is used to implement an industry standard or endorsed regulatory guidance. Since no change was proposed R

to a design process addressed by Criterion 2 this Criterion does not apply.

Qualifying Criterion 3 and 4 pose questions regarding impacts acts to nuclear nuc nu fuel and the PXS Commented [HTE4

[HTE48]: Conforming change in response to in-containment refueling water storage tank (IRWST) screencreen design des and containment LAR-17-037-4 RAI LAR-17-037 4 (SCVB)

(S in LAR 17-037S2 (ND-18-0608, ev D Enclosure 12, pg. 5).

recirculation screen design; neither of those topics are re affected fected by the pproposed Tier 2*

change. Thus, the answer to both questions is No and the process shown in LAR-17-037 -037 continues to satisfy 10 CFR 52 Appendix D, Paragraph ragraph ph VIII.B.5.a. Commented mm [HN49]: Editorial correction. Added the word satisfy sfy which was missing from the original submittal (ND ie ra 1726).

LAR-17-037 Enclosure 4, page 3 of 3 stepss the user through the 10 1 CFR 52 Appendix D, estions.

s.

Paragraph VIII.B.5.a and subsequent questions.

er 2* change does not First, the LAR-13-006 proposed Tier n involve Tier er 1 material ateria nor the w ft Vogtle Technical Specifications (TS);

TS); thus, the answer answe to this question on is No and uestion a the screening continues.

Second, the LAR-13-006 proposed Tier 2* changechan does not ot promptpt a Yes answe nsw to any answer er gar of the eight questions posed in VIII.B.5.b regarding creased ed likelihood of an accident, the increased ype of accident; increased effects of accidents, or creation of a new type ccident; thus, th th the answer to this question is No and the screening continues.

's Third, the LAR-13-006 proposed Tier 2* change ge does es not prompt a Y Yes answer to either arding ex-of the two questions posed in VIII.B.5.c regarding ex -vessel accidents; ex-vessel accid a thus, the answer es.

to this question is No and the screening continues.

Ai Fourth, the LAR-13-006 proposed Tier 2* change ange does not no prompt a Yes answer to the arding the Aircraft Impact questions posed in VIII.B.5.d regarding Impa Assessment; thus, the answer creening ning continues.

to this question is No and the screening reening, the Enclos As a result of the above screening, Enclosure 4 flow chart directs the user to implement d

parture is then implemented the departure. The departure impleme implem in accordance with the applicable 10 CFR 50 Appendix B procedures and procesprocesses and reported accordingly.

AR--17 AR 17-037 prop In this example, the LAR-17-037 proposed screening process challenged the proposed ately and came Tier 2* change appropriately c to the correct conclusion that nuclear safety, pu regulatory compliance, and the public health and safety would not be adversely impacted t proposed change without requiring prior NRC approval.

by the licensee implementing the Page 3 of 3

Southern Nuclear Operating Company ND-18-0000 Enclosure 7U Rev D Vogtle Electric Generating Plant (VEGP)

EGP) Units its 3 and 4 ie ra w ft Updated d Reviewers Aid Tier 2* Departure Example ple Requiring Prior (LAR-17-037S4) 7-037S4 Prio NRC Approval 037S4))

proval al er

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ND-18-0646 U Updated Reviewers Aid - Tier 2* Departure Example Requiring Prior NRC Approval (LAR 037S4)

Example application of the LAR-17-037 proposed process to a proposed change to Tier 2*

material which would result in a determination that prior NRC approval is required:

In Vogtle 3&4 LAR-13-004 [ML13022A254], SNC proposed the following change in Enclosure 1, page 2 of 10, Summary

Description:

The proposed changes would depart from plant-specific Design Control Document (DCD) Tier 2* and associated Tier 2 material incorporated into the Updated Final Safety Analysis Report (UFSAR) by revising the structural analysis requirements to provide alternative requirements for development of shear reinforcement bars within the nuclear island basemat concrete.

R The proposed changes revise the requirements for development of basemat shear Appe reinforcement in the licensing basis from ACI 349 Appendix B to ACI 318-11, Section 12.6. The use of ACI 318 criteria for headed aded re rei reinforcement results in elow ow the elevator longer shear ties and thicker concrete in areas below elevat ele pits and a sump ev D in the nuclear island basemat. The thicker concretee is accomplished ncrete accomplish by raising the accomplishe basema basem resulting in a floor of the elevator pits and sump in the nuclear island basemat minor reduction in volume of the sump. The requirements equirements for fo concrete co cover ver over ged.

the reinforcement bars are also changed.

ie ra oval off the license amendment This enclosure requests approval a necessary essary to ges to the Tier 2* and a implement the proposed changes mat associated Tier 2 material.

w ft w chart provided in Enclosure Consider the proposed process flow En 4 of this LAR, with r evise revise the requirements for development of basemat she shear reinforcement ent in the licensing bab basis 318--11, Sec 318 from ACI 349 Appendix B to ACI 318-11, Section 12.6 as the he Proposed Ti Tier 2*

er Departure entry oval.

Criterion 1 asks, Yes/No, does the Proposed Tier er 2* Departure Involve Inv design methodology or construction materials that deviate from a code or standard standa credited in the plant-specific DCD for establishing the criteria forr the design or construc construction of a structure, const

's system, or component (SSC) important to safety.ety.

In this example, the answer to this questionion would Fo this proposed change to uld be Yes. For Tier 2* material, SNC requested to deviate viate from om the use of the th ACI 349-01 concrete code Ai and instead use ACI 318-11 for the design of headed shea shear reinforcement in the Nuclear sh Island basemat. ACI 349-01 wass endorsed orsed for use in the design and construction of concrete structures by the NRC RC inn the approval of the AP1000 Design Certification.

Conversely, ACI 318-11 was as not utilized in the AP1000 A Design Certification nor is ACI d

318-11 generically endorsed sed for the proposed us use by the NRC via other regulatory means such as an issued Regulatory ulatory Guide. In short, short the proposed Tier 2* change deviates from shor the design methodology logy that was credited in the plant-specific DCD for the design and construction of an SSC SC important to safety.

safe saf While other components of the LAR LAR-13-004 proposed change, such as a minor change to the floor elevation of the bottom ttom of an elevator pit, may not require prior NRC approval under the LAR-17-037 change process, the deviation from the approved code would be properly categorized by Criterion 1 which immediately directs the user to Submit license amendment request (Paragraph VIII.B.6.b or VIII.B.6.c).

Page 2 of 2

Southern Nuclear Operating Company ND-18-0000 Enclosure 8U Rev D Vogtle Electric Generating Plant (VEGP)

EGP) Units its 3 and 4 ie ra w ft Updated Proposed ed Regulatory Commitment 7-037S4 Com (LAR-17-037S4) 037S4))

er

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ND-18-0646 U Updated Proposed Regulatory Commitment (LAR-17-037S4)

The following table identifies the regulatory commitments in this document. Any other statements Commented [HN50]: Response to RAI LAR-17-037-6 in this submittal represent intended or planned actions. They are provided for information (NRO/LB4) in LAR-17-037S3 (ND-18-0646, Enclosure 14, pg.

4).

purposes and are not considered to be regulatory commitments.

REGULATORY COMMITMENT DUE DATE / EVENT Annotate Tier 2* departures implemented without submitting a Implemented coincident license amendment request within departure reports submitted with the implementation in accordance with 10 CFR Part 52, Appendix D, paragraphs of the license X.B.1 and X.B.3.b. amendment approving R

this LAR, and would be applicable to Tier 2*

app departures identified in depa depar departure reports depar departur ev D submitted subsequent submitte s to implementation of this the impleme his license cens amamendment ie ra Develop, implement, and maintain procedural guidance that Imp Implemented prior or to the contains a description of the qualifying criteria contained ned in i implementation of the im License Condition 2.D(13) and the supporting g detailed guidance license amendmentent and bases contained in the Technical Evaluation uation section of the th approving this LAR Commented [HN51]: Response to RAI LAR-17-037-6 w ft approved LAR-17-037, including additional nal guidance provided (NRO/LB4) in LAR-17-037S3 (ND-18-0646, Enclosure 14, pg.

4).

by SNC in the supplements to the LAR. This procedural guidance will be maintained in accordance with SNCs Commitments Management Program for as long g as the th license er condition remains in effect.

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