ML19091A293

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Summary of Public Meeting with Southern Nuclear Operating Company to Discuss Issues Associated with the Safety Review of Licensing Actions for Snc'S Vogtle Electric Generating Plant Units 3 and 4
ML19091A293
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 04/23/2019
From: Donald Habib
NRC/NRO/DLSE/LB2
To: Jennifer Dixon-Herrity
NRC/NRO/DLSE/LB2
habib d/415-1035
References
Download: ML19091A293 (10)
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Text

April 23, 2019 MEMORANDUM TO: Jennifer Dixon-Herrity, Chief Licensing Branch 2 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors FROM: Donald Habib, Project Manager /RA/

Licensing Branch 2 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors

SUBJECT:

SUMMARY

OF A PUBLIC MEETING WITH SOUTHERN NUCLEAR OPERATING COMPANY ON MARCH 21, 2019 The U.S. Nuclear Regulatory Commission (NRC) staff held a Category 1 public meeting with Southern Nuclear Operating Company (SNC) on March 21, 2019. The purpose of the meeting was to discuss issues associated with the safety review of licensing actions for SNCs Vogtle Electric Generating Plant (VEGP) Units 3 and 4.

The meeting notice can be found in the Agencywide Documents Access and Management System (ADAMS) under Accession No. ML19052A392. The meeting notice is also posted on the NRC public website. Enclosures 1 and 2 are the meeting agenda and attendance list for the meeting, respectively. The other documents referenced during the discussion can be found at the ADAMS Accession Nos. given below:

[Inspection, Test, Analysis, and Acceptance Criteria] ITAAC Optimization

  • Draft: Request for License Amendment and ML19072A060 Exemption, Consolidation of Structural Building ITAAC CONTACT: Donald Habib, NRO/DLSE (301) 415-1035

J. Dixon-Herrity

  • Notice of Uncompleted ITAAC 225-days Prior to ML19052A376 Initial Fuel Load, Item 2.2.02.07f.i [Index No. 145]
  • UIN ICN Comment Status Sheet ITAAC Index ML19077A387 No. 145 Summary of Meeting:

On March 21, 2019, staff from the NRC conducted a public meeting with representatives from SNC to discuss issues associated with the safety review of licensing actions for SNCs VEGP Units 3 and 4. Specifically, the meeting discussed the following four topics:

  • FLEX Implementation Plan
  • Uncompleted ITAAC Notice (UIN) for ITAAC Item 2.2.02.07f.i [Index Number 145]

FLEX Implementation Plan SNC presented its plan for closing out the Fukushima-related requirements related to Orders12-049 and 12-051 and meeting applicable requirements related to the regulations for mitigation of beyond design basis events (ADAMS Accession No. ML19072A060). SNC requested feedback from the staff about the timing, processes, and documentation expected by the staff. The staff agreed to take an action related to how to document its final review and how to conduct inspections. The plan was to do this before the next public meeting. SNC and the staff agreed to future public meetings to discuss progress in implementing requirements of NRC Orders EA-12-049 and EA-12-051 and 50.155 of Title 10 of the Code of Federal Regulations.

Draft LAR: Consolidation of Structural Building ITAAC SNC presented the draft LAR, which proposed to consolidate ITAAC for structural reconciliation, structural wall thickness, and shielding wall thickness, for several individual buildings, including four nuclear island structures and the Annex, Turbine, and Radwaste buildings (see ADAMS Accession No. ML19072A060). The staff noted that, for the Annex and Turbine buildings, the acceptance criteria needed to assure that the safety function of the buildings was maintained (e.g., during a safe shutdown earthquake). The staff provided feedback that the draft LAR included a description of the content of the structural reconciliation report that appeared to not be necessary to support the proposed changes being requested. NRC encouraged SNC to evaluate whether that should be included within the LAR. SNC and the staff agreed to a future public interaction on the content of the structural reconciliation reports; however, this is outside of the scope of this LAR. SNC also indicated it would re-evaluate the discussion of the global analysis in the draft LAR.

Draft LAR: Functional Arrangement ITAAC Optimization (LAR-19-002)

SNC presented the draft LAR, which proposed to eliminate eight ITAAC with acceptance criteria that the applicable as-built systems conform with the functional arrangement as described in the

J. Dixon-Herrity Tier 1 Design Description for several plant systems. In particular, the draft LAR proposed to delete the functional arrangement ITAAC for the Fuel Handling and Refueling System, Reactor Coolant System (RCS), Containment System (CNS), Passive Containment Cooling System (PCS), Passive Core Cooling System, Onsite Standby Power System, Annex/Auxiliary Buildings Nonradioactive Ventilation System, and Radiologically Controlled Area Ventilation System.

During a previous public meeting on February 14, 2019, SNC described its Functional Arrangement procedure to implement the provisions in the NRC-accepted Nuclear Energy Institute (NEI) Report 08-01, Industry Guideline for the ITAAC Closure Process Under 10 CFR Part 52, to complete the functional arrangement ITAAC for VEGP Units 3 and 4.

During the March 21, 2019 meeting, the staff stated that, based on the February 14, 2019 discussion, it had assumed that SNC would complete its procedure to implement NEI 08-01 to satisfy the functional arrangement ITAAC, and that the staff would monitor SNCs activities for those functional arrangement ITAAC for specific plant systems as part of its inspection activities.

However, at the March 21, 2019 public meeting, SNC suggested that the functional arrangement ITAAC are not necessary because other ITAAC are considered to satisfy that activity. Tier 1 defines functional arrangement as the physical arrangement of systems and components to provide the service for which the system is intended, and which is described in the system design description.

The staff noted that the draft LAR did not adequately describe how other ITAAC provide verification of the functional arrangement. For example, the draft LAR referenced ITAAC No. 107 for the Integrated Leak Rate Test of the containment and indicated that no additional information is verified by completion of the CNS functional arrangement ITAAC.

During the March 21, 2019 meeting, the staff questioned whether ITAAC No. 107, a test of the leakage rate from containment, addresses the specific containment isolation valves listed in the Tier 1 table referenced in the Design Description. The NRC staff is concerned ITAAC No. 107 might not confirm the functional arrangement of the CNS components and piping to provide the service for which the system is intended as described in the system Design Description.

For the RCS, the draft LAR referenced ITAAC No. 13 with an acceptance criterion that an American Society of Mechanical Engineers (ASME) Code Section III design report exists, ITAAC No. 19 with an acceptance criterion that the seismic Category I equipment is located on the Nuclear Island, and ITAAC No. 46 with an acceptance criterion that controls in the main control room cause a signal at the squib valve electrical leads that is capable of actuating the squib valve. During the March 21 meeting, the staff stated that ITAAC No. 13 relates to the ASME design report that focuses on the stress analysis of the installed piping and components, ITAAC No. 19 relates to assurance that the seismic equipment is placed on the Nuclear Island, and ITAAC No. 46 relates to the initiation of an electrical charge from the main control room.

The NRC staff expressed concern that ITAAC Nos. 13, 19, and 46 might not confirm the functional arrangement of the RCS components and piping to provide the service for which the system is intended as described in the system Design Description.

The staff also indicated concerns with the referenced ITAAC for functional arrangement ITAAC for other systems proposed to be deleted in the draft LAR. As a result, the staff does not consider the draft LAR to contain the level of detail necessary for the staff to evaluate the referenced ITAAC to satisfy the functional arrangement as specified in NEI 08-01. It is not apparent to the NRC staff that the acceptance criteria for the referenced ITAAC require a walkdown to confirm the functional arrangement of the installed components in the applicable system to provide its intended service. In summary, the NRC staff indicated that the draft LAR did not provide sufficient information to justify the deletion of the functional arrangement ITAAC

J. Dixon-Herrity based on the referenced ITAAC. At the end of the March 21, 2019 discussion, SNC stated that it would consider the staffs comments during its finalization of the draft LAR.

Issue for Uncompleted ITAAC Notice for ITAAC 2.2.02.07f.i, (Index No. 145) Regarding Testing for Water Delivery Rate for the Passive Containment Cooling System In response to the staff issue identified in the VEGP ICN/UIN Issues Tracking Sheet for ITAAC No. 145 (see ADAMS Accession No. ML19077A387), SNC clarified that the required test of the PCS flow was being performed with all piping installed in as-built condition. SNC was dividing the test into two parts in order to avoid flooding the spent fuel pool after it had been configured with the fuel racks. SNC advised that it would monitor flow conditions at a branch connection during testing to ensure that identical conditions would be experienced in both tests. SNC also advised that it would provide diagrams for discussion with the staff at a future public meeting.

At the conclusion of the meeting, there was an opportunity for the public to provide comments and ask questions. There were no comments or questions from the public Docket Nos.: 52-025 52-026

Enclosure:

As stated cc w/encls: See next page

ML19091A293 *via e-mail NRC-001 OFFICE PM: DLSE/LB2 LA: DLSE/LB2 BC: DEI/MEB PM: DLSE/LB2 NAME DHabib (c) RButler* TLupold CPatel DATE 4/15/19 4/8/19 4/15/19 4/23/19 OFFICE BC: DLSE/LB2 PM: DLSE/LB2 NAME JDixon-Herrity (c) DHabib (s)

DATE 4/18/19 4/23/19 AGENDA FOR PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION (NRC)

Thursday, March 21, 2019 Teleconference 9:00 a.m. - Noon PURPOSE: To discuss issues associated with the safety review of licensing actions for Southern Nuclear Operating Companys (SNC) Vogtle Electric Generating Plant (VEGP) Units 3 and 4.

OPEN Time Topic Led By 9:00 a.m. Opening Remarks NRC 9:05 a.m. Discussion regarding FLEX NRC/SNC Implementation Plan 9:40 a.m. Opportunity for Public Comment PUBLIC/NRC 9:45 a.m. Discussion regarding Draft LAR for NRC/SNC Structural Reconciliation Inspection, Test, Analysis, and Acceptance Criteria (ITAAC) Consolidation 10:25 a.m. Opportunity for Public Comment PUBLIC/NRC 10:30 a.m. Break 10:40 a.m. Discussion regarding Draft LAR NRC/SNC Functional Arrangement ITAAC Optimization 11:10 a.m. Opportunity for Public Comment PUBLIC/NRC 11:15 a.m. Break 11:40 a.m. Discussion regarding Uncompleted NRC/SNC ITAAC Notice for ITAAC Index No. 145 11:45 a.m. Opportunity for Public Comment PUBLIC/NRC 11:50 a.m. Adjourn Enclosure 1

PUBLIC MEETING U.S. NUCLEAR REGULATORY COMMISSION Thursday, March 21, 2019 One White Flint North, Room O-9B4 9:00 a.m. - Noon List of Attendees Name Organization Representing the Nuclear Regulatory Commission Donald Habib Chandu Patel NRO/DLSE/LB2 Jennifer Dixon-Herrity

  • NSIR/DPR/RLB Representing Industry Kelli Roberts Pamela Fergen
  • Catherine Prat Amy Chamberlain
  • Calvin Morrow Tom Petrak
  • Paul Marcotte Kara Stacy
  • Southern Nuclear Company Steve Leighty
  • Randy Blunt
  • Kevin Durrwacher
  • John Hall
  • Dave Midlik
  • Chuck Pierce
  • Russ Stroud
  • Zach Harper
  • Si Wu
  • Westinghouse Electric Company Todd Baker
  • Representing Public N/A
  • = participated via teleconference Enclosure 2

Vogtle Units 3 and 4 Mailing List (Revised 08/16/2018) cc:

Office of the Attorney General Resident Inspector 40 Capitol Square, SW Vogtle Plant Units 3 & 4 Atlanta, GA 30334 8805 River Road Waynesboro, GA 30830 Resident Manager Oglethorpe Power Corporation Mr. Barty Simonton Alvin W. Vogtle Nuclear Plant Team Leader 7821 River Road Environmental Radiation Program Waynesboro, GA 30830 Air Protection Branch Environmental Protection Division Southern Nuclear Operating Company, Inc. 4244 International Parkway, Suite 120 Document Control Coordinator Bin N-226-EC Atlanta, GA 30354-3906 3535 Colonnade Parkway Birmingham, AL 35243 George B. Taylor, Jr.

2100 East Exchange Pl Anne F. Appleby Atlanta, GA 30084-5336 Olgethorpe Power Corporation 2100 East Exchange Place Brian H. Whitley Tucker, GA 30084 3535 Colonnade Parkway, Bin N-226-EC 42 Inverness Center Parkway, BIN B237 County Commissioner Birmingham, AL 35243 Office of the County Commissioner Burke County Commission Mr. Michael Yox Waynesboro, GA 30830 Site Regulatory Affairs Director Vogtle Units 3 & 4 Mr. Wayne Guilfoyle 7825 River Road, Bin 63031 Commissioner District 8 Waynesboro, GA 30830 Augusta-Richmond County Commission 4940 Windsor Spring Rd Hephzibah, GA 30815 Gwendolyn Jackson Burke County Library 130 Highway 24 South Waynesboro, GA 30830 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission Atlanta, GA 30334 Page 1 of 3

Vogtle Units 3 & 4 Mailing List Email acchambe@southernco.com (Amy Chamberlian) agaughtm@southernco.com (Amy Aughtman)

ALPUGH@southernco.com (Amanda Pugh) awc@nei.org (Anne W. Cottingham) becky@georgiawand.org (Becky Rafter) bhwhitley@southernco.com (Brian Whitley)

Bill.Jacobs@gdsassociates.com (Bill Jacobs) bjadams@southernco.com (Brad Adams) bwwaites@southernco.com (Brandon Waites) castelca@westinghouse.com (Curtis Castell) comerj@westinghouse.com (James Comer) crpierce@southernco.com (C.R. Pierce) dahjones@southernco.com (David Jones) david.hinds@ge.com (David Hinds) david.lewis@pillsburylaw.com (David Lewis) dgbost@southernco.com (Danny Bost) dlfulton@southernco.com (Dale Fulton) drculver@southernco.com (Randy Culver) durhamdc@westinghouse.com (David Durham) ed.burns@earthlink.net (Ed Burns) edavis@pegasusgroup.us (Ed David) erg-xl@cox.net (Eddie R. Grant) fdhundle@southernco.com (Forrest Hundley) fhwillis@southernco.com (Fred Willis)

G2NDRMDC@southernco.com (SNC Document Control) graysw@westinghouse.com (Scott W. Gray) jadwilli@southernco.com (J.D. Williams) james1.beard@ge.com (James Beard) jannina.blanco@pillsburylaw.com (Jannina Blanco) jantol1dj@westinghouse.com (David Jantosik) jenmorri@southernco.com (Jennifer Buettner)

JHaswell@southernco.com (Jeremiah Haswell) jim@ncwarn.org (Jim Warren)

John.Bozga@nrc.gov (John Bozga)

Joseph_Hegner@dom.com (Joseph Hegner) jpredd@southernco.com (Jason R. Redd) jranalli@meagpower.org (Jerry Ranalli) karen.patterson@ttnus.com (Karen Patterson) karlg@att.net (Karl Gross) kmstacy@southernco.com (Kara Stacy)

KSutton@morganlewis.com (Kathryn M. Sutton) kwaugh@impact-net.org (Kenneth O. Waugh) markus.popa@hq.doe.gov (Markus Popa)

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Vogtle Units 3 & 4 Mailing List Matthew.Williams@hq.doe.gov (Matthew Williams) mdmeier@southernco.com (Mike Meier) media@nei.org (Scott Peterson)

Melissa.Smith@Hq.Doe.Gov (Melissa Smith)

Michael.Kuca@hq.doe.gov (Michael Kuca) mike.price@opc.com (M.W. Price)

MKWASHIN@southernco.com (MKWashington) mlgraves@southernco.com (Michelle Graves)

MSF@nei.org (Marvin Fertel) myox@southernco.com (Mike Yox) nirsnet@nirs.org (Michael Mariotte)

Nuclaw@mindspring.com (Robert Temple) patriciaL.campbell@ge.com (Patricia L. Campbell)

Paul@beyondnuclear.org (Paul Gunter) pbessette@morganlewis.com (Paul Bessette) r.joshi15@comcast.net (Ravi Joshi)

RJB@NEI.org (Russell Bell)

Ronald.Jones@scana.com (Ronald Jones) rwink@ameren.com (Roger Wink) sabinski@suddenlink.net (Steve A. Bennett) sara@cleanenergy.org (Sara Barczak) sblanton@balch.com (Stanford Blanton)

Shiva.Granmayeh@hq.doe.gov (Shiva Granmayeh) sjackson@meagpower.org (Steven Jackson) skauffman@mpr.com (Storm Kauffman) sroetger@psc.state.ga.us (Steve Roetger) stephan.moen@ge.com (Stephan Moen) stephen.burdick@morganlewis.com (Stephen Burdick) tom.miller@hq.doe.gov (Tom Miller)

TomClements329@cs.com (Tom Clements)

Vanessa.quinn@dhs.gov (Vanessa Quinn) vcsummer2n3@gmail.com (Brian McIntyre) wasparkm@southernco.com (Wesley A. Sparkman) wayne.marquino@gmail.com (Wayne Marquino) weave1dw@westinghouse.com (Doug Weaver) x2gabeck@southernco.com (Gary Becker) x2kmseib@southernco.com (Kristin Seibert)

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