ND-17-1583, Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

ML17265A787
Person / Time
Site:	Vogtle
Issue date:	09/22/2017
From:	Aughtman A Southern Nuclear Operating Co
To:	Document Control Desk, Office of New Reactors
References
LAR-17-035, ND-17-1583
Download: ML17265A787 (22)

Text

Southern Nuclear Operating Company, Inc.

42 Inverness Center Parkway Birmingham, AL 35242 September 22, 2017 Docket Nos.: 52-025 ND-17-1583 52-026 10 CFR 50.90 10 CFR 52.98 U.S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, DC 20555-0001 Southern Nuclear Operating Company Vogtle Electric Generating Plant Units 3 and 4 Request for License Amendment Regarding:

Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

Ladies and Gentlemen:

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

The requested amendment proposes to depart from approved AP1000 Design Control Document (DCD) Tier 2 information (text) and involved Tier 2* information (as incorporated into the Updated Final Safety Analysis Report (UFSAR) as plant-specific DCD information).

This amendment request proposes to modify the licensing requirements for the ASME Class 1 Piping component analysis from limited to design by rule evaluation as described in ASME Section III, NB-3600 to include the ability to perform design by analysis evaluations, as described in ASME Section III, NB-3200. This submittal requests approval of the license amendment necessary to implement these changes. provides the description, technical evaluation, regulatory evaluation (including the Significant Hazards Consideration Determination) and environmental considerations for the proposed changes. identifies the requested changes and provides markups depicting the requested changes to the VEGP Units 3 and 4 licensing basis documents.

This letter contains no regulatory commitments. This letter has been reviewed and determined not to contain security related information.

SNC requests NRC staff approval of the license amendment by February 28, 2018. Delayed approval of this license amendment could result in a delay in the installation of the Loop 2 Hot Leg Automatic Depressurization System (ADS)-4 Piping. SNC expects to implement this proposed amendment within 30 days of approval of the requested changes. SNC also expects to submit a Preliminary Amendment Request (PAR) within the coming weeks to support more near-term related construction activities. This PAR is expected to request a no objections finding from the NRC Staff by early January 2018.

U.S Nuclear Regulatory Commission ND-17-1583 Page 2 of 4 In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia by transmitting a copy of this letter and its enclosures to the designated State Official.

Should you have any questions, please contact Corey Thomas at (205) 992-5221.

I declare under penalty of pe~ury that the foregoing is true and correct. Executed on the 22nd of September 2017.

Respectfully submitted, Amy G. Aughtman Nuclear Development Licensing Director Southern Nuclear Operating Company

Enclosures:

1) Vogtle Electric Generating Plant (VEGP) Units 3 and 4- Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

2) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Proposed Changes to Licensing Basis Documents (LAR-17-035)

U.S Nuclear Regulatory Commission ND-17-1583 Page 3 of 4 cc:

Southern Nuclear Operating Company / Georgia Power Company Mr. S. E. Kuczynski (w/o enclosures)

Mr. M. D. Rauckhorst Mr. D. G. Bost (w/o enclosures)

Mr. M. D. Meier (w/o enclosures)

Mr. D. H. Jones (w/o enclosures)

Mr. D. L. McKinney (w/o enclosures)

Mr. T. W. Yelverton (w/o enclosures)

Mr. B. H. Whitley Mr. J. J. Hutto Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. E. W. Rasmussen Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Mr. M. K. Washington Ms. A. L. Pugh Mr. J. D. Williams Document Services RTYPE: VND.LI.L00 File AR.01.02.06 Nuclear Regulatory Commission Mr. W. Jones (w/o enclosures)

Ms. J. Dixon-Herrity Mr. C. Patel Ms. J. M. Heisserer Mr. B. Kemker Mr. G. Khouri Ms. S. Temple Ms. V. Ordaz Mr. T.E. Chandler Ms. P. Braxton Mr. T. Brimfield Mr. C. J. Even Mr. A. Lerch State of Georgia Mr. R. Dunn

U.S Nuclear Regulatory Commission ND-17-1583 Page 4 of 4 Oglethorpe Power Corporation Mr. M. W. Price Mr. K. T. Haynes Ms. A. Whaley Municipal Electric Authority of Georgia Mr. J. E. Fuller Mr. S. M. Jackson Dalton Utilities Mr. T. Bundros Westinghouse Electric Company, LLC Mr. R. Easterling (w/o enclosures)

Mr. G. Koucheravy (w/o enclosures)

Mr. P. A. Russ Mr. M. L. Clyde Ms. L. Iler Mr. D. Hawkins Mr. J. Coward Other Mr. S. W. Kline, Bechtel Power Corporation Ms. L. A. Matis, Tetra Tech NUS, Inc.

Dr. W. R. Jacobs, Jr., Ph.D., GDS Associates, Inc.

Mr. S. Roetger, Georgia Public Service Commission Ms. S. W. Kernizan, Georgia Public Service Commission Mr. K. C. Greene, Troutman Sanders Mr. S. Blanton, Balch Bingham Mr. R. Grumbir, APOG NDDocumentinBox@duke-energy.com, Duke Energy Mr. S. Franzone, Florida Power & Light

Southern Nuclear Operating Company ND-17-1583 Enclosure 1 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Request for License Amendment Regarding:

Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

(This Enclosure consists of 12 pages, including this cover page)

ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

Table of Contents

1.

SUMMARY

DESCRIPTION

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION

3. TECHNICAL EVALUATION (Included in Section 2)

4. REGULATORY EVALUATION 4.1. Applicable Regulatory Requirements/Criteria 4.2. Precedent 4.3. Significant Hazards Consideration 4.4. Conclusions

5. ENVIRONMENTAL CONSIDERATIONS

6. REFERENCES Page 2 of 12

ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

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 The proposed changes would revise the Combined Licenses (COLs) by changing technical Tier 2* material within the Updated Final Safety Analysis Report (UFSAR). This license amendment request (LAR) provides proposed markups to modify the licensing requirements for the ASME Class 1 Piping component analysis from limited to design by rule evaluation as described in ASME Section III, NB-3600 to include the ability to perform design by analysis evaluations, as described in ASME Section III, NB-3200. The requested amendment requires changes to plant-specific Tier 2* information. No structure, system, or component (SSC) design function or analysis as described in the UFSAR will be adversely affected. This enclosure requests approval of the license amendment necessary to implement these changes.

2. DETAILED DESCRIPTION and TECHNICAL EVALUATION As described in UFSAR Subsection 3.9.3.1, the integrity of the pressure boundary of safety-related components is provided by the use of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Vessel (B&PV) Code. Using the methods and equations in the ASME Code, stress levels in the components and supports are calculated for various load combinations. These load combinations may include the effects of internal pressure, dead weight of the component and insulation, and fluid, thermal expansion, dynamic loads due to seismic motion, and other loads.

To determine if a design is acceptable for the loading combination, the calculated stress levels are compared to acceptance standards in the ASME Code Section III. The acceptance standards in the ASME Code differ depending on the plant operating modes and loads considered. The ASME Code includes a design limit and four service limits (A, B, C, and D) against which to evaluate design conditions and plant and system operating conditions. UFSAR Subsection 3.9.1.1 describes the four service levels (Levels A, B, C, and D) as applied in the AP1000 design. Note that the definitions of service levels for the AP1000 design are consistent with the definition of service limits in ASME Section III, NB-3200.

Level A Service Conditions are normal conditions. These conditions include any condition in the course of system startup, operation in the design power range, hot standby, and system shutdown.

Level B Service Conditions are upset conditions and incidents of moderate frequency.

These conditions include any deviations from Level A service conditions anticipated to occur often enough that the design includes a capability to withstand the conditions without operational impairment.

Level C Service Conditions are emergency conditions and infrequent incidents. These conditions include deviations from Level A service conditions that require shutdown for correction of the conditions or repair of damage in the system.

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ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

Level D Service Conditions are faulted conditions and limiting faults. These conditions include those combinations of conditions associated with extremely low probability postulated events whose consequences are such that the integrity and operability of the nuclear energy system may be impaired.

As described in UFSAR Subsection 5.2.1.1, the AP1000 design is compliant with 10 CFR 50.55a (Codes and Standards). From UFSAR Subsection 5.2.1.1, The baseline used for the evaluations done to support this safety analysis report and the Design Certification is the 1998 Edition, 2000 Addenda, with an additional restriction for piping design. The restriction on piping design is that the treatment of dynamic loads, including seismic loads, in pipe stress analysis will satisfy the requirements of the ASME Code,Section III, Subarticles NB-3210, NB-3220, NB-3620, NB-3650...

The ASME Code Class 1 piping loading combinations, stress limits, and functional capability requirements are summarized in UFSAR Tables 3.9-5, 3.9-6, and 3.9-9. Table 3.9-5 specifies the minimum design loading combinations for ASME Class 1, 2, 3, and Core Support (CS) Systems and Components. Table 3.9-6 contains the additional load combinations and stress limits for ASME Class 1 Piping, including; the loads, the appropriate equation from ASME Section III, NB-3650, and the stress limit. Table 3.9-9 contains the stress criteria for ASME Code Section III Class 1 Components and Supports and Class CS Core Supports, including each service level (A, B, C, and D) and the appropriate ASME Code,Section III, NB-3600 equation. Table 3.9-11 contains the ASME Class 1 piping functional capability requirements for ASME Class 1, 2, and 3 piping systems that must maintain adequate fluid flow path to mitigate a Level C or Level D plant event.

The requirements to meet ASME Section III, NB-3600 (and specific equations of NB-3600, as identified in the UFSAR tables listed above) are one method of performing a piping component analysis. This is defined in ASME Section III as Design by Rule, as specific equations, methods, and stress limits are defined for specific types of components, including piping. The intent of this portion of the ASME Code is to simplify the approach to component design and stress analysis.

If the requirements are met at the simplified level, a more detailed approach is not required to demonstrate compliance, as noted in NB-3630.

Another method of piping component analysis (and design) is specified in ASME Section III, NB-3200. This section provides design rules for Design by Analysis, for Class 1 and 2 components. As identified in ASME Section III, NB-3630(c): When a design does not satisfy the requirements of NB-3640 and NB-3650, the more detailed alternative analysis given in NB-3200 may be used to obtain stress values for comparison with the criteria of NB-3200.

Currently, the Class 1 piping component analyses in the AP1000 design implemented at Vogtle Units 3 and 4 use the design by rule methods of ASME Section III, NB-3600 to evaluate stress and fatigue for each service level. However, there are instances when the simplified analysis results do not satisfy the requirements of ASME Section III, NB-3600. In these instances, ASME Section III, NB-3630(c) states, When a design does not satisfy the requirements of NB-3640 and NB-3650, the more detailed alternative analysis given in NB-3200may be used. In order to complete the outstanding analysis and address any future issues that may arise during as built reconciliation, UFSAR Tables 3.9-6, 3.9-9, and 3.9-11 are modified to clarify the ability for use of ASME Section III, NB-3200, when the simplified requirements of ASME Section III, NB-3600 cannot be met.

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ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

The ASME Class 1 as designed piping component analysis that is already complete and has demonstrated compliance with ASME Section III, NB-3600 will not be updated. The revised licensing basis will allow piping analyses that require a more detailed evaluation to demonstrate acceptability to ASME Section III, NB-3200 requirements. The locations that require use of ASME Section III, NB-3200 include: the piping design of the automatic depressurization system (ADS)

Stage 4 reactor coolant system (RCS) loop 2 branch nozzle and the piping design of the pressurizer surge line:

SNC has determined that a modification to enlarge the trailing edge radius of the branch nozzle would have a safety benefit, because it would prevent vibration in the RCS Loop 2 ADS-4 branch line from exceeding applicable vibration limits. This vibration, identified as an acoustic issue (flow induced vibration), was identified during hot functional testing for the first AP1000 plants in China, during the Thermal Expansion Dynamic Effects and Vibration (TEDEV) program, as a part of preoperational testing requirements. The enlarged radius meets the ASME Section III, NB-3200 requirements for design by analysis, as allowed by ASME Section III, subsection NB-3630, but is greater than that allowed by ASME Section III, NB-3600.

Due to the complicated thermal stratification that occurs in the pressurizer surge line, the piping analysis requires more detailed methods than those described in ASME Section III, NB-3600. The profile for stratification through the majority of the line requires modelling techniques utilizing more detailed Finite Element Analysis (FEA) to apply the temperatures and calculate the correct stresses. Since the loadings induced by this thermal stratification cannot be properly accounted for within the equations given in section ASME Section III NB-3650, this more detailed FEA method leads to the need for the use of ASME Section III NB-3200 within the fatigue analysis for the majority of the line, as allowed by ASME Section III NB-3630.

Additionally, the change allows the use of ASME Section III, NB-3200 for locations that are identified while performing future as-built reconciliation in accordance with ASME Section III requirements.

UFSAR Changes Tier 2* Table 3.9-6 title and notes are revised to add Note 9:

o 9. When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used as stated in NB-3630.

Tier 2* Table 3.9-9, Piping column and notes are revised to add Note i:

o i. When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used as stated in NB-3630.

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ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

Tier 2* Table 3.9-11, Note 2 is revised to add:

o When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used to calculate stress. The allowables listed above shall be met.

Tier 2 Section 3C.5 is revised to add:

o When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used as stated in NB-3630.

Tier 2* Subsection 5.2.1.1, paragraph 5 is revised to add NB-3630 to the list of ASME Code,Section III, Subarticles that the piping stress analysis will satisfy.

10 CFR 50.55a and ASME Code Compliance As described in UFSAR Subsection 5.2.1.1, 10 CFR 50.55a requires that ASME Section III Class 1, 2, and 3 components of the AP1000 design meet the requirements of the ASME Section III Code. The AP1000 reactor coolant pressure boundary components, including piping, are designed and fabricated in accordance with the ASME Code,Section III. The reactor coolant pressure boundary piping is designed to be ASME Class 1 piping (AP1000 Equipment Class A).

The quality requirements associated with AP1000 Equipment Class A are described in UFSAR Subsection 3.2.2.3. The proposed change to include ASME Section III, NB-3200 as an allowed code evaluation method for determining piping stress and functional capability does not change the quality requirements in place for the ASME Class 1, AP1000 Equipment Class A piping. The piping will continue to meet the approved quality standards of ASME Section III 1998 Edition and 2000 Addenda, as endorsed in 10 CFR 50.55a, and perform as required.

ASME Code,Section III, NB-3630(b) states, Within a given piping system, the stress and fatigue analysis shall be performed in accordance with one of the methods given in NB-3650, NB-3200, or Appendix II. The Code allows initial evaluations to be performed under either NB-3200 or NB-3650. The piping component analysis has been initially performed to meet the requirements of NB-3650. When these simplified requirements could not be met, the ASME Code allows a more detailed analysis to be performed, ASME Section III NB-3630(c) states, When a design does not satisfy the requirements of NB-3640 and NB-3650, the more detailed alternative analysis given in NB-3200 The AP1000 piping component analysis for ASME Class 1 piping stress and functional capability calculations that do not meet the simplified requirements of ASME Section III, NB-3650, meet the detailed requirements for stress and functional capability in ASME Section III, NB-3200. Each of the two methods are approved by the ASME Code for Section III components as endorsed in 10 CFR 50.55a, and the detailed analysis demonstrates compliance with code stress limits and functional capability requirements. The conditions outlined in 10 CFR 50.55a for the use of ASME Code,Section III, NB-3200 do not apply to the Vogtle Units 3 and 4 code of record.

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ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

NUREG-1367 and NUREG-0800 Compliance The requirements in UFSAR Table 3.9-11 are based on the requirements in NUREG-1367 (Functional Capability of Piping Systems), Reference 19 of UFSAR Section 3.9. NUREG-1367 provides additional requirements for piping components, beyond what the ASME Section III Code requires, to maintain fluid flow and function. The ASME Section III, NB-3600 equations are listed and discussed in the body of NUREG-1367; they are included to provide simple comparisons to multiple tests that were performed to validate the design of piping for functional capability. There is no discussion in NUREG-1367 that precludes the use of ASME Section III, NB-3200 as allowed by ASME Section III, NB-3630 for piping component analysis.

NUREG-0800, the Standard Review Plan (SRP), discusses the expectations for piping design in Sections 3.9.3 and 3.12. Section 3.9.3 states, The functional capability assurance program should incorporate the conclusions listed in Section 9 of NUREG-1367 Section 3.12 states, The acceptance criteria provided in NUREG-1367, may be used to ensure piping functionality under level D loading conditions. Alternative criteria will be reviewed on a case by case basis.

The proposed design change to allow piping component evaluations to be performed using ASME Section III NB-3200 will continue to be compliant with these two statements in NUREG-0800.

The conclusions of NUREG-1367, Section 9.1, referred to in NUREG-0800, states: The staff concludes that the piping functional capability is ensured by meeting the present Code requirements, provided with five provisions listed. The Code referenced is the entirety of the ASME Section III Code (Year 1989). The five provisions are still met and are not modified by the change to the UFSAR Tables as described in this license amendment request. Within Section 9.1 of NUREG-1367, there is no requirement for or reference to ASME Section III, NB-3600 equations. Therefore, use of ASME Section III, NB-3200 methodologies is acceptable to calculate stresses within a piping component for functional capability requirements and to maintain compliance with the ASME Section III provisions in NUREG-1367.

3. TECHNICAL EVALUATION (Included in Section 2)

4. REGULATORY EVALUATION 4.1 Applicable Regulatory Requirements/Criteria 10 CFR Part 52, Appendix D, VIII.B.6 requires prior NRC approval for the departure from Tier 2* information. The change makes Tier 2* changes to the Updated Final Safety Analysis Report (UFSAR) Chapter 3 material. This activity adds ASME Code,Section III, NB-3200 to the description of the piping component analysis methods for Class 1 piping, which includes a Tier 2* departure and thus requires NRC approval. Therefore, a license amendment request (LAR) (as supplied herein) is required.

10 CFR Part 50, Appendix A, General Design Criterion (GDC) 4, Environmental and dynamic effects design basis, requires that structures, systems, and components (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. These SSCs shall be appropriately protected against the dynamic effects, including the effects of missiles, pipe Page 7 of 12

ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035) whipping, and discharging fluids, that may result from equipment failures and from events and conditions outside the nuclear power unit. The expansion of Class 1 piping stress and functional analysis methods from NB-3600 alone to include NB-3200 does not adversely impact the ability to meet 10 CFR 50 Appendix A GDC 4. The AP1000 plant piping design accommodates the effects of and is compatible with the environmental conditions associated with all modes of operation. Therefore, it is concluded that compliance with 10 CFR Part 50, Appendix A, GDC 4 is not impacted as part of the proposed LAR.

Compliance with 10 CFR 50.55a, Codes and Standards, requires that ASME Section III Class 1, 2, and 3 components meet the requirements of the ASME Section III Code. The AP1000 reactor coolant pressure boundary components are designed and fabricated in accordance with the ASME Code,Section III, including piping. The reactor coolant pressure boundary piping is designed to be ASME Class 1 piping (AP1000 Equipment Class A). The quality requirements associated with AP1000 Equipment Class A are described in UFSAR Subsection 3.2.2.3. The proposed change to include ASME Section III, NB-3200 as an allowed code evaluation method for determining piping stress and functional capability does not change the quality requirements in place for the ASME Class 1, AP1000 Equipment Class A piping. The piping will continue to meet the approved quality standards and perform as required. Therefore, it is concluded that compliance with 10 CFR 50.55a is not impacted as part of the proposed LAR.

4.2 Precedent No precedent is identified.

4.3 Significant Hazards Consideration The requested amendment proposes a change to the Updated Final Safety Analysis Report (UFSAR) Tier 2* information to modify the licensing requirements for the ASME Class 1 piping component analysis. The ASME Class 1 Piping component analysis is currently limited to design by rule evaluation as described in ASME Section III, NB-3600.

This would be expanded to include the ability to perform for design by analysis evaluations, as described in ASME Section III, NB-3200. No structure, system, or component (SSC) design function or analysis as described in the UFSAR will be adversely affected.

The requested amendment proposes changes to Tier 2* information.

An evaluation to determine whether or not a significant hazards consideration is involved with the proposed amendment was completed by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment, as discussed below:

4.3.1 Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

Response: No.

The proposed change describes how the ASME Class 1 piping components are evaluated for stress and functional capability. The ASME Class 1 piping components are evaluated against ASME Section III to demonstrate that the Page 8 of 12

ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035) components meet the allowables required by the ASME Code. The ASME Code is endorsed by 10 CFR 50.55a. The change allows the ASME Class 1 piping components to be evaluated by not only ASME Section III, NB-3600, but also, in situations where the simplified analysis results do not satisfy the requirements, ability is added for an evaluation using the more detailed method of ASME Section III, NB-3200. This is performed in accordance with ASME Section III, NB-3630(c). This method will continue to demonstrate that the piping components meet acceptance criteria and will perform as required in the design. The proposed change does not affect the operation of any systems or equipment that may initiate a new or different kind of accident, or alter an SSC such that a new accident initiator or initiating sequence of events is created.

The change has no adverse effect on the design function of the ASME Class 1 piping components or the SSCs to which the piping is connected. The probabilities of accidents evaluated in the UFSAR are not affected.

The change does not impact the support, design, or operation of mechanical and fluid systems. The change does not impact the support, design, or operation of any safety-related structures. There is no change to plant systems or response of systems to postulated accident conditions. There is no change to the predicted radioactive releases due to normal operation or postulated accident conditions. The plant response to previously evaluated accidents or external events is not adversely affected, nor does the proposed change create any new accident precursors.

Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

4.3.2 Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

Response: No.

The proposed change describes how the ASME Class 1 piping components are evaluated for stress and functional capability. The ASME Class 1 piping components are evaluated against ASME Section III to demonstrate that the components meet the allowables required by the ASME Code. The ASME Code is endorsed by 10 CFR 50.55a. The change allows the ASME Class 1 piping components to be evaluated by not only ASME Section III, NB-3600, but also, in situations where the simplified analysis results do not satisfy the requirements, ability is added for an evaluation using the more detailed method of ASME Section III, NB-3200. This is performed in accordance with ASME Section III, NB-3630(c). This method will continue to demonstrate that the piping components meet acceptance criteria and will perform as required in the design.

The proposed change does not adversely affect the design function of the ASME Class 1 piping components, the structures and systems in which the piping components are used, or any other SSC design functions or methods of operation in a manner that results in a new failure mode, malfunction, or Page 9 of 12

ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035) sequence of events that affect safety-related or non-safety related equipment.

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 result in significant fuel cladding failures.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated.

4.3.3 Does the proposed amendment involve a significant reduction in a margin of safety?

Response: No.

The proposed change describes how the ASME Class 1 piping components are evaluated for stress and functional capability. The ASME Class 1 piping components are evaluated against ASME Section III to demonstrate that the components meet the allowables required by the ASME Code. The ASME Code is endorsed by 10 CFR 50.55a. The change allows the ASME Class 1 piping components to be evaluated by not only ASME Section III, NB-3600, but also, in situations where the simplified analysis results do not satisfy the requirements, ability is added for an evaluation using the more detailed method of ASME Section III, NB-3200. This is performed in accordance with ASME Section III, NB-3630(c). This method will continue to demonstrate that the piping components meet acceptance criteria and will perform as required in the design.

Because no safety analysis or design basis acceptance limit/criterion is challenged or exceeded by this change, no significant margin of safety is reduced.

Therefore, the proposed change does not involve a significant reduction in a margin of safety.

Based on the above, it is concluded that the proposed amendment 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 consideration is justified.

4.4 Conclusions Based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commissions regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public. Having arrived at negative declarations with regard to the criteria in 10 CFR 50.92, this assessment determined that the requested change does not involve a Significant Hazards Consideration.

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ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035)

5. ENVIRONMENTAL CONSIDERATIONS This review supports a request to amend the Combined License (COL) to allow departure from an element of the Tier 2* information in the Updated Final Safety Analysis Report (UFSAR). The proposed amendment specifies the information required to modify the licensing requirements for the ASME Class 1 Piping component analysis from limited to design by rule evaluation as described in ASME Section III, NB-3600 to include the ability for design by analysis evaluations, as described in ASME Section III, NB-3200.

Sections 2 and 3 of this license amendment request provide the details of the proposed changes.

A review has determined that the proposed changes require an amendment to the COL. However, a review of the anticipated construction and operational effects of the requested amendment has determined that the requested amendment meets the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), in that:

(i) There is no significant hazards consideration.

As documented in Section 4.3, Significant Hazards Consideration, of this license amendment request, an evaluation was completed to determine whether or not a significant hazards consideration is involved by focusing on the three standards set forth in 10 CFR 50.92, Issuance of amendment. The Significant Hazards Consideration determined that: (1) the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated; (2) the proposed amendment does not create the possibility of a new or different kind of accident from any accident previously evaluated; and (3) the proposed amendment does not involve a significant reduction in a margin of safety. Therefore, it is concluded that the requested amendment 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 consideration is justified.

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

The proposed changes are unrelated to any aspect of plant construction or operation that would introduce any change to effluent types (e.g., effluents containing chemicals or biocides, sanitary system effluents, and other effluents) or affect any plant radiological or non-radiological effluent release quantities. Furthermore, the proposed changes do not affect any effluent release path or diminish the functionality of any design or operational features that are credited with controlling the release of effluents during plant operation.

Therefore, it is concluded that the proposed amendment does not involve a significant change in the types or a significant increase in the amounts of any effluents that may be released offsite.

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

The proposed change in the requested amendment to ASME Class 1 piping component design requirements does not affect or alter any walls, floors, or other structures that provide shielding. Plant radiation zones and controls under 10 CFR 20 preclude a significant increase in occupational radiation exposure. Therefore, the proposed Page 11 of 12

ND-17-1583 Request for License Amendment Regarding: Use of ASME NB-3200 for Piping Component Analysis (LAR-17-035) amendment does not involve a significant increase in individual or cumulative occupational radiation exposure.

Based on the above review of the proposed amendment, it has been determined that anticipated construction and operational impacts of the proposed 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 the individual or cumulative occupational radiation exposure. Accordingly, the proposed 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 is not required.

6. REFERENCES None.

Page 12 of 12

Southern Nuclear Operating Company ND-17-1583 Enclosure 2 Vogtle Electric Generating Plant Units 3 and 4 Proposed Changes to Licensing Basis Documents (LAR-17-035)

Additions identified by blue underlined text.

Deletions Identified by red strikethrough of text.

• *

• indicates omitted existing text that is not shown.

(This Enclosure consists of 6 pages, including this cover page)

ND-17-1583 Proposed Changes to Licensing Basis Documents (LAR-17-035)

Revise UFSAR Tier 2* Table 3.9-6, Additional Load Combinations and Stress Limits for ASME Class 1 Piping, add Note 9 to the title and the following text after Note 8, as follows:

Table 3.9-6 Additional Load Combinations and Stress Limits for ASME Class 1 Piping(9)

9. When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used as stated in NB-3630.

Page 2 of 6

ND-17-1583 Enclosure 2 Proposed Changes to Licensing Basis Documents (LAR-17-035)

Revise UFSAR Tier 2* Table 3.9-9, Stress Criteria for ASME Code Section III Class 1 Components(a) and Supports and Class CS Core Supports, add a comma and Note i after Note h to the Piping column heading in the table and add the new Note i after Note h, as follows:

Table 3.9-9 Stress Criteria for ASME Code Section III Class 1 Components(a) and Supports and Class CS Core Supports Design/Service Components Level Vessels/Tanks Pumps Piping (h,i) Core Supports Valves, Disks & Seats Supports (c,d)

Notes:

i. When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used as stated in NB-3630.

Page 3 of 6

ND-17-1583 Proposed Changes to Licensing Basis Documents (LAR-17-035)

Revise UFSAR Tier 2* Table 3.9-11, Piping Functional Capability - ASME Class 1, 2, and 3(1) Note 2, as follows:

2. Applicable to ASME Code Class 1 piping. When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used to calculate stress. The allowables listed above shall be met.

Page 4 of 6

ND-17-1583 Proposed Changes to Licensing Basis Documents (LAR-17-035)

Revise UFSAR Tier 2 Section 3C.5, Reactor Coolant Loop Piping Stresses, add the following text after the last sentence, as follows:

3C.5 Reactor Coolant Loop Piping Stresses

• *

• The secondary stress caused by thermal expansion is qualified by satisfying Equation (12) in paragraph NB-3653 of the ASME Code,Section III. When the simplified requirements of ASME Section III, NB-3640 and NB-3650 are not satisfied, the more detailed methods of NB-3200 may be used as stated in NB-3630.

Page 5 of 6

ND-17-1583 Proposed Changes to Licensing Basis Documents (LAR-17-035)

Revise Tier 2* information in UFSAR Subsection 5.2.1.1, Compliance with 10 CFR 50.55a, fifth paragraph, add NB-3630 and a comma to the list of ASME Code,Section III, Subarticles, as follows:

The restriction on piping design is that the treatment of dynamic loads, including seismic loads, in pipe stress analysis will satisfy the requirements of the ASME Code,Section III, Subarticles NB-3210, NB-3220, NB-3620, NB-3630, NB-3650, NC-3620, NC-3650, ND-3620, and ND-3650 1989 Edition, 1989 Addenda. The requirements shown below for fillet welds are also applicable.

Page 6 of 6