ML19214A043
| ML19214A043 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 08/02/2019 |
| From: | NRC |
| To: | NRC/NRO/DLSE/LB4 |
| References | |
| Download: ML19214A043 (4) | |
Text
Vogtle PEmails From: Rankin, Jennivine Sent: Friday, August 2, 2019 8:03 AM To: Leighty, Steven; KRoberts@southernco.com Cc: Patel, Chandu; Dixon-Herrity, Jennifer; Dudek, Michael; Stutzcage, Edward; Vogtle PEmails; Gleaves, Bill
Subject:
Vogtle LAR-19-005 Draft RAI 9696 Attachments: Vogtle LAR-19-005 Draft RAI_9696 (rev_8-1-19).pdf Steve and Kelli, Attached is our management-approved draft RAI on the LAR-19-005. The next step is for SNC to identify if it has questions or comments or, if not, to accept the draft RAI as final by informing Billy of the acceptance.
Please let Billy or myself know by Tuesday morning if a clarification call is needed.
This email is also being sent to public ADAMS capture. If there is sensitive information, please inform me ASAP so that it will prevented from public viewing.
Please let me know if you have any questions.
- Thanks, Jennie Jennie Rankin, Project Manager Licensing Branch 2 Division of Licensing, Siting, and Environmental Analysis Office of New Reactors 1
Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 464 Mail Envelope Properties (BN6PR09MB2227ABBC9F324C793A4824AF98D90)
Subject:
Vogtle LAR-19-005 Draft RAI 9696 Sent Date: 8/2/2019 8:03:29 AM Received Date: 8/2/2019 8:03:34 AM From: Rankin, Jennivine Created By: Jennivine.Rankin@nrc.gov Recipients:
"Patel, Chandu" <Chandu.Patel@nrc.gov>
Tracking Status: None "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>
Tracking Status: None "Dudek, Michael" <Michael.Dudek@nrc.gov>
Tracking Status: None "Stutzcage, Edward" <Edward.Stutzcage@nrc.gov>
Tracking Status: None "Vogtle PEmails" <Vogtle.PEmails@nrc.gov>
Tracking Status: None "Gleaves, Bill" <Bill.Gleaves@nrc.gov>
Tracking Status: None "Leighty, Steven" <sleighty@southernco.COM>
Tracking Status: None "KRoberts@southernco.com" <KRoberts@southernco.com>
Tracking Status: None Post Office: BN6PR09MB2227.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 742 8/2/2019 8:03:34 AM Vogtle LAR-19-005 Draft RAI_9696 (rev_8-1-19).pdf 112925 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
DRAFT Request for Additional Information Vogtle Nuclear Site, Units 3 and 4, Dockets 52-0025 and 52-0026 Southern Nuclear Operating Co.
Docket Nos. 52-0025 and 52-0026 Section: 14.03.08 - Radiation Protection Inspections, Tests, Analyses, and Acceptance Criteria Application Section: Tier 1
Background
In LAR-19-005, the licensee requests changes to COL Appendix C and Tier 1, Table 3.3-1, "Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building," and Table 3.3-6, "Inspections, Tests, Analyses, and Acceptance Criteria." The proposed changes include the allowance of construction deviations from the thicknesses of radiation shielding barriers and the structural wall thickness in the nuclear island structures and annex building, if the changes can be made without a "loss of shielding function" and the structures will withstand design bases loads without loss of structural integrity or safety-related function.
Issue The proposed wording in Table 3.3-1, Footnotes 15, 16, and 17, and the Table 3.3-6 ITAAC acceptance criteria for ITAAC 3.3.00.02a.i.a, 3.3.00.02a.i.b, 3.3.00.02a.i.c, 3.3.00.02a.i.d, 3.3.00.02a.ii.e, 3.3.00.02a.ii.f, and 3.3.00.04b do not provide the clarity needed to assure that the proposed changes are designed and implemented consistently. As currently proposed, the criteria for loss of shielding function are unclear with regards to radiation shielding functionality and aggregate impacts (e.g., occupational dose, public dose, environmental qualification, SSC degradation, control room dose, vital area doses, and, as applicable, equipment survivability).
Additionally, the methodologies should be consistent with those used in the design certification.
Similarly, for structures the criteria to assess the resulting structural integrity is unclear and it is indeterminate whether the applicants proposal accounts for the global impacts of all proposed changes so that the changes do not result in a loss of structural integrity or safety-related functions.
The footnotes and associated ITAAC acceptance criteria should clearly define the radiation shielding functional requirements to be met when the licensee deviates from the thicknesses and tolerances that are currently in Table 3.3-1.
For the structural reconciliation of construction deviations mentioned in footnotes 15, 16, and 17 of the LAR enclosure 3, the staff is unclear about the bases used to justify deviations from the Tier 1 values, including details on the evaluation method and acceptance criteria. The staff did not find the supporting information in Tier 2 that provides the methodology to be used; nor did the staff find the associated acceptance criteria.
Question Please clarify or revise, as appropriate, the Table 3.3-1 Footnotes 15, 16, and 17 and the acceptance criteria for ITAAC 3.3.00.02a.i.a, 3.3.00.02a.i.b, 3.3.00.02a.i.c, 3.3.00.02a.i.d, 3.3.00.02a.ii.e, 3.3.00.02a.ii.f, and 3.3.00.04b in Table 3.3-6 to provide criteria that ensures that
radiation shielding function and structural integrity remain appropriate and the facility has been constructed and will be operated in accordance with the design and all relevant requirements.
Regulatory Basis 10 CFR Part 50, Appendix A, General Design Criterion (GDC) 2, Design Bases for Protection against Natural Phenomena, requires that SSCs important to safety shall be designed to withstand the effects of natural phenomena such as earthquakes, tornadoes, hurricanes, floods, tsunami, and seiches without loss of capability to perform their safety functions.
GDC 4, Environmental and Dynamic Effects Design Bases, requires that SSCs important to safety shall be designed to accommodate the effects of and to be compatible with the environmental conditions associated with normal operation, maintenance, testing and postulated accidents, including loss-of-coolant accidents.
GDC 61, requires that the fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety (2) with suitable shielding for radiation protection, and (3) with appropriate containment, confinement, and filtering systems.
10 CFR 52.80(a) requires that the application must contain the proposed inspections, tests, and analyses, that the licensee shall perform, and the acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, the facility has been constructed and will be operated in conformity with the combined license, the provisions of the Act, and the Commission's rules and regulations.