ML19340A072
| ML19340A072 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/06/2019 |
| From: | NRC |
| To: | NRC/NRR/DNRL |
| References | |
| Download: ML19340A072 (4) | |
Text
From:
Habib, Donald Sent:
Friday, December 6, 2019 8:41 AM To:
Quarles, Adam Graham Cc:
Vogtle PEmails; Santos, Cayetano; Patel, Chandu; Rankin, Jennivine; Roberts, Kelli Anne; Hansing, Nicholas
Subject:
Alternative Requirements for Inservice Test Interval Code Edition, Unit 4, IST-ALT-01, Staff Discussion Topics for Public Meeting Attachments:
2019-12-06 IST ALT 1 Clarification Topics.pdf Adam -
Attached please find clarification topics that the staff would like to discuss with SNC at a future public meeting. If possible, the December 12 meeting.
Please let me know when SNC can support a public meeting discussion for these topics.
Thanks Donald Habib Project Manager, Vogtle Project Office U.S. Nuclear Regulatory Commission Office of Nuclear Reactor Regulation 301-415-1035
Hearing Identifier:
Vogtle_COL_Docs_Public Email Number:
507 Mail Envelope Properties (BN7PR09MB25480500164FBB8734CD91BA975F0)
Subject:
Alternative Requirements for Inservice Test Interval Code Edition, Unit 4, IST-ALT-01, Staff Discussion Topics for Public Meeting Sent Date:
12/6/2019 8:41:20 AM Received Date:
12/6/2019 8:41:23 AM From:
Habib, Donald Created By:
Donald.Habib@nrc.gov Recipients:
"Vogtle PEmails" <Vogtle.PEmails@nrc.gov>
Tracking Status: None "Santos, Cayetano" <Cayetano.Santos@nrc.gov>
Tracking Status: None "Patel, Chandu" <Chandu.Patel@nrc.gov>
Tracking Status: None "Rankin, Jennivine" <Jennivine.Rankin@nrc.gov>
Tracking Status: None "Roberts, Kelli Anne" <KROBERTS@southernco.com>
Tracking Status: None "Hansing, Nicholas" <Nicholas.Hansing@nrc.gov>
Tracking Status: None "Quarles, Adam Graham" <AGQUARLE@southernco.com>
Tracking Status: None Post Office:
BN7PR09MB2548.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 456 12/6/2019 8:41:23 AM 2019-12-06 IST ALT 1 Clarification Topics.pdf 117927 Options Priority:
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NRC Public Meeting Clarification Topics on VEGP Units 3 and 4 IST-ALT-01 Alternative Request December 6, 2019 In VEGP 3&4-IST-ALT-01, the licensee requests to align Vogtle Unit 3 and 4 to the same initial and successive IST intervals to allow for a single plan for both units. The proposed alternative adjusts the requirements for Unit 4 in order to be consistent with the requirements for Unit 3. While the staff agrees that conducting IST programs for multiple unit sites using the same Code edition could provide an improvement in program effectiveness, the staff would like to discuss the following questions to clarify the proposed alternative submitted by SNC:
- 1) To align Vogtle Unit 3 and 4 to the same initial and successive IST intervals, several methods are possible. 10 CFR 50.55a(f)(4)(iv) outlines one such method (updating to subsequent editions).
NUREG-1482, Section 3.3.2 outlines other such methods (performing program updates more often than once every 120 months, extending intervals by more than 1 year, etc.). The staff would like to better understand the basis for the licensees proposed alternative, considering other options available, such as:
x Updating the Unit 3 program once Unit 4s initial IST interval is established x
Utilizing the 2017 Edition of the ASME OM Code for the Unit 3 program, which is anticipated to be the applicable Code Edition for Unit 4s program What factors led the licensee to propose aligning both units to the Unit 3 intervals, using the 2012 Edition of the ASME OM Code, in lieu of other options available?
- 2) Related to the question above regarding implementation of intervals between the two units, is it anticipated that Unit 3 will have a 10-year initial IST interval and Unit 4 will have a 9-year initial IST interval, or that Unit 3 will have a 11-year initial IST interval and Unit 4 will have a 10-year initial IST interval?
- 3) The proposed alternative assumes that Unit 4 will conduct its initial fuel load roughly 1 year after the Unit 3 initial fuel load. What are SNCs plans in the event of a delayed Unit 4 fuel load on its IST Program development? Should the delay be significant (suppose several years) would this impact SNCs plans for program development for the 2 Units?
- 4) The ASME OM Code is a constantly evolving Code that captures improved best practices and technological advances in the industry. The ASME OM Code is developed by a voluntary consensus body representing all stakeholders and the use of later editions could reflect significant improvements in IST that are beneficial to a licensee. The licensee addressed the effect of having two separate IST programs for Unit 3 and Unit 4 but did not address the effect of using a different applicable Code Edition for Unit 4. What effect would use of the 2012 Edition of the ASME OM Code have on the Unit 4 program instead of the 2017 Edition of the ASME OM Code, which is the anticipated applicable Code Edition for Unit 4?
This clarity is sought to better understand the basis and implementation of the proposed alternative.
NUREG-1482, Section 3.3.2 states that The IST program document and the request for the alternative or exemption would typically describe the method for selecting the interval dates, specifying the dates at which the interval will begin and end, and comparing the effect of those dates with that of the dates that would otherwise be required.