ML20042C616

COL Docs - Audit Questions Vogtle Units 3 and 4 - LAR 19-017 2020-01-08 Redacted-Public.docx

ML20042C616
Person / Time
Site:	Vogtle
Issue date:	02/11/2020
From:	NRC
To:	NRC/NRR/DNRL
References
Download: ML20042C616 (4)

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From: Habib, Donald Sent: Tuesday, February 11, 2020 8:31 AM To: Vogtle PEmails

Subject:

Audit Questions Vogtle Units 3 and 4 - LAR 19-017 2020-01-08 Redacted-Public.docx Attachments: Audit Questions LAR 19-017 2020-01-08 Redacted-Public.docx

Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 535 Mail Envelope Properties (BL0PR0901MB366719EAF28C2FC2F9FCBF5E97180)

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Audit Questions Vogtle Units 3 and 4 - LAR 19-017 2020-01-08 Redacted-Public.docx Sent Date: 2/11/2020 8:31:00 AM Received Date: 2/11/2020 8:31:03 AM From: Habib, Donald Created By: Donald.Habib@nrc.gov Recipients:

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

Tracking Status: None Post Office: BL0PR0901MB3667.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 6 2/11/2020 8:31:03 AM Audit Questions LAR 19-017 2020-01-08 Redacted-Public.docx 33235 Options Priority: Normal Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

LAR-19-017- Audit Questions/Comments January 8, 2020

1) The LAR proposes to include line resistance acceptance criterion for the PRHR subsystem of 3.085e-6 ft/gpm^2. [

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2) [

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3) E&DC Licensing Impact Determination Checklist Question 10 (Does the proposed AP1000 Activity deviate from the applicable CLB Regulatory Guides, codes and standards?) was answered No. Why? RG 1.68 specifies performance of a natural circulation test; therefore, without such a test there cannot be conformance with that portion of the guidance.

4) [

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5) After SNC submitted LAR 19-017 to the NRC on September 6, 2019, there were several interactions with the staff and the SNC was planning to send a supplement to the LAR.

For the staff to be able to focus on the audit, please provide a draft of the supplement you are working on and a planned date of submittal.

6) It is not clear how different data supports LAR 19-017. For example, whether the line resistance PRHR is going to be used for calculating natural circulation flow is not clear.

7) Providing a roadmap for the documents provided on Westinghouse ERR will make the audit more efficient. The staff is interested in knowing how those documents support LAR 19-017.

8) Enclosure 1 to LAR 19-017 states the following:

In the AP600 Final Safety Evaluation Report (FSER), the NRC staff confirmed that the exception to RG 1.68 was acceptable provided that the training requirements (described in UFSAR Subsection 1.9.4.2.1, TMI Action Plan Issues, under I.G.I, Training Requirements) are met and that Westinghouse demonstrates that all plants remain identical in physical layout and configuration of the proposed plant key components, and validate that acceptance criteria for the ranges of values for other system flow performance measurements that are taken during the ITP confirm that the overall flow characteristics of the proposed plant are

LAR-19-017- Audit Questions/Comments January 8, 2020 equivalent to the reference plant. Demonstrations of the layout of primary components as well as flow measurements are confirmed during the ITAAC closure process and preoperational testing.

Therefore, conformance with the RG requirements as described by the NRC staff in the AP600 FSER is maintained without performance of the preoperational PRHR heat exchanger natural circulation test.

However, AP600 FSER Section 14.2.9.2 states the following:

The staff confirmed that the new Section 14.2.10.3.7, "Passive Residual Heat Removal Heat Exchanger (First Plant Only)," provides for natural circulation testing of the PRHR system during startup testing of the initial plant. In addition, all plants are subjected to natural circulation testing of the PRHR during hot functional testing as described in Section 14.2.9.1.3.(e), (f), and (g). The staff finds that these testing provisions, in conjunction with the issues addressed in SSAR Section 1.9.4.2.1, item I.G.1, and the exception to RG 1.68, Appendix A.4.t in SSAR Appendix 1A, adequately address natural circulation testing for the AP600 design. On these bases, the staff also finds that a COL action item is no longer required on this subject. The staff finds this acceptable, and therefore, OSER COL Action Item 14.2.8-1 is dropped and OSER Open Item 14.2.8-7 is closed.

As such in AP600 FSER the staff has relied on Section 14.2.9.1.3(f) testing which LAR 19-017 proposes to remove and the exception to RG 1.68 apply to the Section 14.2.10.3.7, "Passive Residual Heat Removal Heat Exchanger (First Plant Only) test but not to the Section 14.2.9.1.3(f) test. Please explain.