ND-18-0646, Supplement to Request for License Amendment and Exemption: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S3)

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Supplement to Request for License Amendment and Exemption: Changes to Tier 2* Departure Evaluation Process (LAR-17-037S3)
ML18169A431
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 06/18/2018
From: Aughtman A
Southern Nuclear Operating Co
To:
Document Control Desk, Office of New Reactors
References
LAR-17-037S3, ND-18-0646
Download: ML18169A431 (32)
v • d • e


Text

Southern Nuclear Operating Company, Inc.

3535 Colonnade Pkwy Birmingham, AL 35243 June 18, 2018 Docket Nos.: 52-025 ND-18-0646 52-026 10 CFR 50.90 10 CFR 52.7 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 Supplement to Request for License Amendment and Exemption:

Changes to Tier 2* Departure Evaluation Process (LAR-17-037S3)

Ladies and Gentlemen:

Pursuant to 10 CFR 52.98(c) and in accordance with 10 CFR 50.90, Southern Nuclear Operating Company (SNC) requested 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) by SNC letter ND-17-1726, dated December 21, 2017 [ADAMS Accession Number ML17355A416],

and supplemented (LAR-17-037S1 and LAR-17-037S2) by SNC letters ND-18-0417, dated April 6, 2018 [ML18096B328] and ND-18-0608, dated May 11, 2018 [ML18131A263],

respectively, to apply the existing departure evaluation process for Tier 2 departures to the evaluation of certain Tier 2* departures. In this same license amendment request (LAR) SNC also requested an exemption from certain change requirements in 10 CFR Part 52, Appendix D.

The enclosures in this supplement provide information in response to five Requests for Additional Information (RAIs) from the NRC staff, as follows:

Date issued ADAMS Enclosure RAI Number NRC Branch (via email) Accession Number 13 RAI-LAR-17-037-5 HOIB 5/1/18 ML18121A437 14 RAI-LAR-17-037-6 NRO/LB4 5/1/18 ML18121A437 15 RAI-LAR-17-037-7 ARPB 5/1/18 ML18121A437 16 RAI-LAR-17-037-8 ICE 5/1/18 ML18121A437 17 RAI-LAR-17-037-9 SRSB 5/8/18 ML18128A369

U.S. Nuclear Regulatory Commission ND-18-0646 Page 2 of 5 The responses to these RAls consider feedback provided by the NRC staff during public meetings held May 24, 2018 (RAls LAR-17-037-5, -8, and -9), May 31, 2018 (RAls LAR-17-037-6 and 9),

and June 8, 2018 (RAI LAR-17-037-9).

Enclosures 1 through 8 were provided with the original LAR-17-037, in SNC letter ND-17-1726. provided a response to RAI LAR-17-037-1, as the first supplement to LAR-17-037, in SNC letter ND-18-0417. Enclosures 10, 11, and 12 were provided in the second supplement to LAR-17-037, in SNC letter ND-18-0608, and provided a revised response to RAI LAR-17-037-1, and the initial responses to RAls LAR-17-037-3 and RAI LAR-17-037-4, respectively.

The information provided in this LAR supplement does not impact the scope, technical content, or conclusions of the Significant Hazards Consideration Determination, or the Environmental Considerations of the original LAR-17-037 provided in Enclosure 1 of SNC letter ND-17-1726.

The response to RAI LAR-17-037-6 in Enclosure 14 contains a regulatory commitment associated with this amendment. Note that this commitment is only applicable if the NRC approves this licensing action. This letter has been reviewed and confirmed to not contain security-related information.

In accordance with 10 CFR 50.91, SNC is notifying the State of Georgia of this LAR supplement by transmitting a copy of this letter and its enclosures to the designated State Official.

Should you have any questions, please contact Mr. Wesley Sparkman at (205) 992-5061.

I declare under penalty of perjury that the foregoing is true and correct. Executed on the 181h of June 2018.

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

U.S. Nuclear Regulatory Commission ND-18-0646 Page 3 of 5 Enclosures 1 - 8) (Previously submitted with the original LAR, LAR-17-037, in letter ND-17-1726)

9) (Previously submitted with LAR-17-037S1, in letter ND-18-0417) 10 - 12) (Previously submitted with LAR-17-037S2, in letter ND-18-0608)
13) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Response to NRC Request for Additional Information (RAI) LAR-17-037 Regarding the LAR-17-037 Review (LAR-17-037S3)
14) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Response to NRC Request for Additional Information (RAI) LAR-17-037 Regarding the LAR-17-037 Review (LAR-17-037S3)
15) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Response to NRC Request for Additional Information (RAI) LAR-17-037 Regarding the LAR-17-037 Review (LAR-17-037S3)
16) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Response to NRC Request for Additional Information (RAI) LAR-17-037 Regarding the LAR-17-037 Review (LAR-17-037S3)
17) Vogtle Electric Generating Plant (VEGP) Units 3 and 4 - Response to NRC Request for Additional Information (RAI) LAR-17-037 Regarding the LAR-17-037 Review (LAR-17-037S3)

U.S. Nuclear Regulatory Commission ND-18-0646 Page 4 of 5 cc:

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

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

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

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

Mr. J. B. Klecha Mr. G. Chick Mr. D. L. McKinney (w/o enclosures)

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

Mr. B. H. Whitley Ms. C. A. Gayheart Mr. C. R. Pierce Ms. A. G. Aughtman Mr. D. L. Fulton Mr. M. J. Yox Mr. J. Tupik Mr. W. A. Sparkman Ms. A. C. Chamberlain Ms. A. L. Pugh Mr. F. J. Redwanz 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 Mr. F. Brown 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-18-0646 Page 5 of 5 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. L. Oriani (w/o enclosures)

Mr. G. Koucheravy (w/o enclosures)

Mr. M. Corletti Mr. M. L. Clyde Ms. L. Iller 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-18-0646 Enclosure 13 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) LAR 17-037-5 Regarding the LAR-17-037 Review (LAR-17-037S3)

Supplement 3 changes that are added to the original LAR submittal are shown as blue, underlined text; deletions of original LAR text are shown as red strikethrough text.

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

ND-18-0646 3 Response to NRC Request for Additional Information (RAI) LAR 17-037-5 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-5] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)-17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

Regulatory Basis:

10 CFR 50.34(f)(2)(iii) states:

Provide, for Commission review, a control room design that reflects state-of-the-art human factor principles prior to committing to fabrication or revision of fabricated control room panels and layouts.

Amongst other things, 10 CFR Part 52 Appendix D:

  • provides definitions of Tier 1, Tier 2, and Tier 2* as they pertain to the AP1000 design
  • Section VIII provides a change process for controlling Tier 2 information 10 CFR 52.79(a)(41) requires applicants to provide an evaluation of the facility against the standard review plan (SRP) or discuss how any departures from the SRP provide an acceptable method of complying with regulations that underlie the SRP acceptance criteria.

NUREG-0800, Chapter 18 of the SRP is the guidance NRC staff uses to ensure that

§ 50.34(f)(2)(iii) is met. Chapter 18 references NUREG-0711 which contains acceptance criteria related to licensee's human factors engineering (HFE) programs.

The Vogtle Units 3&4 Updated Final Safety Analysis Report (UFSAR), Section 18.2.1.2, "Regulatory Requirements," states, "The human factors engineering process is designed to meet the human factors engineering design process requirements specified in NUREG-0711.

NUREG-0711 contains the SRP acceptance criteria for an acceptable human factors design program.

Description of the Issue:

NRC human factors staff has reviewed the process described in LAR 17-037. The staff agrees that there is currently HFE information identified as Tier 2* that can be adequately controlled using the Tier 2 change process. However, it is unclear if the process proposed in LAR 17-037 will predictably and reliably identify human factors information that need not be controlled by the Tier 2* change process. Clarification is necessary to help the staff make a determination on the LAR.

Question:

Section 3, "Technical Evaluation" (Enclosure 1, Page 10 of 19) of LAR 17-037 provides specific examples of "material changes" that may affect design processes. The examples of material changes and non-material changes are helpful. However, it's not clear that the examples provided will be sufficient for either the licensee or the NRC staff to determine whether a change is material or not, especially when the proposed change is unlike any of the examples given.

Page 2 of 3

ND-18-0646 3 Response to NRC Request for Additional Information (RAI) LAR 17-037-5 Regarding the LAR-17-037 Review (LAR-17-037S3)

Clarifying this process is important because changes to the approved human factors implementation plans (IPs) may have significant effects on the iterative process, including generation of information from testing and interpretation of test results that employs various human factors processes to develop a final HFE design. Altering details that the NRC staff used in approving these implementation plans could, in some cases, invalidate the staff findings on the IPs, and may consequently challenge the staff's ability to rely on the results of HFE testing to confirm that the main control room HSIs will support safe operation. Moreover, lack of a clear definition of a "material change" or criteria for evaluating changes may be problematic in regard to both licensee and NRC inspections related to human factors inspections, tests, analyses, and acceptance criteria (ITAAC).

Please clarify how a determination will be made regarding changes to the Tier 2* information in the implementation plans using the examples given (which may or may not be applicable to the change being considered), or provide a clear threshold or set of criteria that will be applied to determine if a change is material. For example, one way to clarify this would be to add a statement to Enclosure 1 or the FSAR such as: "All proposed changes that are not clearly encompassed by the examples of non-material changes shall be treated as material changes."

SNC Response to RAI Question LAR 17-037-5 The detailed guidance provided for Criterion 2 in Enclosure 1 of ND-17-1726 is intended to provide clear guidance to be used when evaluating whether a proposed departure constitutes a material change to the affected Tier 2* information. While it would be SNC's expectation that relevant NRC Final Safety Evaluation Reports (FSERs) are reviewed as part of a proposed departure evaluation and that any alteration of a detail that served as the basis for the NRC's safety conclusion would be considered material, SNC proposes to clarify the detailed guidance for Criterion 2 to add a bullet that any alteration of a detail used as the basis for the NRC's safety determination constitutes a material change. Additionally, an editorial change is made to move the sentence reading, "A material change affects a design process output, or method of performing a design process, or method of controlling the design process," so that it is directly under the heading for Criterion 2 detailed guidance.

Changes to Original LAR-17-037:

Changes to Enclosure 1 Add a fourth sub-bullet to the bullet regarding examples of material changes under Criterion 2 on Page 10 of 19, and revise the format of these examples, such that it reads:

A material change affects a design process output, or method of performing a design process, or method of controlling the design process.

  • The following are examples of material changes:

o The addition, deletion, or alteration of a design process step o Reconfiguration of design process steps o Departures from regulatory guidance related to the design process o Alteration of a detail that serves as the basis for acceptance in an NRC Final Safety Evaluation Report (FSER) related to the affected design process Page 3 of 3

Southern Nuclear Operating Company ND-18-0646 Enclosure 14 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) LAR 17-037-6 Regarding the LAR-17-037 Review (LAR-17-037S3)

Supplement 3 changes that are added to the original LAR submittal are shown as blue, underlined text; deletions of original LAR text are shown as red strikethrough text.

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

ND-18-0646 4 Response to NRC Request for Additional Information (RAI) LAR 17-037-6 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-6] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)-17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

Question:

10 CFR Part 50, Appendix B requires an applicant for a combined license to include in its final safety analysis report a description of the quality assurance applied to the design, and to be applied to the fabrication, construction, and testing of the structures, systems, and components of the facility and to the managerial and administrative controls to be used to assure safe operation.

The Vogtle UFSAR Section 13.5.1 describes administrative procedures that provide administrative control over activities that are important to safety for the operation of the facility. of LAR 17-037 provides guidance for how the licensee intends to implement a proposed license condition and exemption that provides an alternative departure evaluation process for Tier 2* information in the Vogtle UFSAR. The licensee would use the guidance to implement the proposed license condition and exemption, which would involve determining whether Tier 2* information to be changed has safety significance commensurate with Tier 1 and requires prior NRC approval.

The guidance in Enclosure 1 describes how, in applying the proposed license condition criteria to proposed changes, the licensee would determine whether a proposed change requires prior NRC approval. The guidance includes the specific information to be considered by the licensee, including, for example:

  • What constitutes a deviation from a code or standard (Criterion 1)
  • What constitutes a material change (Criteria 2 and 3)
  • What design processes would be considered by the licensee (Criterion 2)
  • What constitutes an adverse change (Criterion 4)
  • What screens and debris quantities are considered in debris screen design criteria (Criterion 4)

The subcriteria listed above are substantive to the licensee's eventual determination about whether a proposed change requires prior NRC review and approval as Tier 2* information.

However, the LAR does not propose changes to the UFSAR or License to include these subcriteria or provide a commitment by the licensee.

The staff requests the licensee to propose revisions to the UFSAR or the proposed license condition, or to provide a commitment, as appropriate, (1) to commit to a procedure that would be used to implement the Tier 2* departure evaluation process and (2) to identify the minimum Page 2 of 4

ND-18-0646 4 Response to NRC Request for Additional Information (RAI) LAR-17-037-6 Regarding the LAR-17-037 Review (LAR-17-037S3) information from Enclosure 1 that it is committing to in the LAR, or explain why a commitment to such information is not necessary.

SNC Response to RAI Question LAR 17-037-6 SNC plans to develop, implement, and maintain detailed guidance related to the use of the proposed Criteria to evaluate proposed Tier 2* departures in procedures used to determine if a proposed departure requires prior NRC approval. The guidance material will include, as a minimum, a restatement of the Criteria contained in the associated license condition and detailed guidance and associated bases provided in Enclosure 1 of ND-17-1726 (as updated by supplements to LAR-17-037). The procedural guidance would be maintained in accordance with SNC's Commitments Management Program for as long as the license condition is in effect. In response to the RAI provided above, SNC is proposing to add a commitment which would commit SNC to adding to existing procedures detailed guidance related to the application of the qualification criteria contained in the proposed license condition. Changes to the commitment or material affecting the commitment would be addressed through SNC's Commitments Management Program.

Changes to Original LAR-17-037:

Changes to Enclosure 1 Add a new paragraph to the Detailed Description before the Licensing Basis Change Descriptions on Page 6 of 19 that reads:

To ensure the proposed qualifying Criteria reliably and predictably differentiate between Tier 2* information with safety significance commensurate with Tier 1 and other information that does not warrant the same level of control, SNC is proposing a regulatory commitment that would require SNC to develop, implement, and maintain procedural guidance with a level of detail commensurate with the detailed implementation guidance and related bases for the proposed Criteria contained in this LAR, including additional guidance provided by SNC in the supplements to this LAR. The proposed regulatory commitment would be implemented prior to the implementation of the license amendment approving this LAR.

Add a new paragraph to the Technical Evaluation after the paragraph related to the regulatory commitment regarding departure reporting on Page 14 of 19 that reads:

The proposed regulatory commitment that would require SNC to develop, implement, and maintain detailed procedural guidance related to how the qualifying criteria would be applied to proposed Tier 2* departures ensures that departures from Tier 2* information with a safety significance commensurate with Tier 1 will require prior NRC approval. This procedural guidance will be maintained in accordance with SNC's Commitments Management Program for as long as the license condition remains in effect.

Page 3 of 4

ND-18-0646 4 Response to NRC Request for Additional Information (RAI) LAR-17-037-6 Regarding the LAR-17-037 Review (LAR-17-037S3)

Changes to Enclosure 8 Change the introductory paragraph on Page 2 of 2 to read:

The following table identifies the regulatory commitments in this document. Any other statements in this submittal represent intended or planned actions. They are provided for information purposes and are not considered to be regulatory commitments.

Add a new regulatory commitment to the table on Page 2 of 2 as follows:

REGULATORY COMMITMENT DUE DATE / EVENT Develop, implement, and maintain procedural guidance that Implemented prior to the contains a description of the qualifying criteria contained in implementation of the License Condition 2.D(13) and the supporting detailed guidance license amendment and bases contained in the Technical Evaluation section of the approving this LAR approved LAR-17-037, including additional guidance provided by SNC in the supplements to the LAR. This procedural guidance will be maintained in accordance with SNC's Commitments Management Program for as long as the license condition remains in effect.

Page 4 of 4

Southern Nuclear Operating Company ND-18-0646 Enclosure 15 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

Supplement 3 changes that are added to the original LAR submittal are shown as blue, underlined text; deletions of original LAR text are shown as red strikethrough text.

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

ND-18-0646 5 Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-7] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)-17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

Question:

As noted in SNC's license amendment request (LAR) (ML17355A416), SECY-17-0075, "Planned Improvements in Design Certification Tiered Information Designations,"

(ML16196A321) describes how the purpose of the Tier 2* designation is to control certain information which the staff has determined to have safety significance commensurate with that of Tier 1 information. NRC's letter dated January 25, 2018, which accepted the LAR for review (ML18019A362), stated that the process criteria and guidance described in the application do not clearly differentiate between Tier 2* information with safety significance commensurate with Tier 1, and any Tier 2* information which does not warrant the same level of control. For example, Criteria 2 and 3 address "a material change," but do not clearly describe how controls on those changes ensure information with safety significance commensurate with Tier 1 is not modified without prior NRC review and approval.

Another example is the guidance for Criteria 1, 2, and 3, which includes statements that the process is intended to permit changes to achieve consistency within the document. However, it is not clear how SNC intends to determine that a Tier 2* change is appropriate to achieve consistency, when changing other information outside the scope of Tier 2* is more appropriate.

For example, if a discrepancy between Tier 1 and Tier 2* is identified, changing Tier 2* is appropriate if Tier 1 is correct. However, if Tier 2* is correct, then a Tier 1 change is needed.

Furthermore, Enclosure 5 identifies the categories of Tier 2* information the licensee plans to screen by the proposed process. However, Enclosure 5 does not identify what portions of Tier 2*

information it considers to contain information that has safety significance commensurate with Tier 1.

Additionally, page 8 of the LAR states that SNC performed an analysis of Tier 2* matters against several criteria, including "safety significance." However, it is not clear to the staff how this criteria was applied to the existing Tier 2* material.

Therefore, SNC is requested to provide a discussion of how the criteria described in the proposed amendment reliably and predictably differentiate between Tier 2* information with safety significance commensurate with Tier 1 and other information which does not warrant the same level of control.

SNC Response to RAI Question LAR 17-037-7 The purpose of the evaluation methodology used to develop the new criteria was to provide assurance that safety-significant changes to existing Tier 2* information would screen in for prior NRC review and approval. While a determination of safety significance was part of the process used to develop the criteria, SNC determined that a detailed analysis of all Tier 2* information in Page 2 of 7

ND-18-0646 5 Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3) order to differentiate it into "safety significance commensurate with Tier 1 information" and "Tier 2*

information which does not warrant Tier 1 level control" was not necessary to arrive at a conclusion that safety-significant changes to Tier 2* information would reliably and consistently require prior NRC review and approval.

The evaluation methodology used a multi-faceted approach to analyze broad categories of Tier 2*

information listed in 10 CFR Part 52, Appendix D, Paragraphs VIII.B.6.b and VIII.B.6.c. SNC reviewed available Commission approved policy papers such as SECY-96-077, "Certification of Two Evolutionary Designs," April 15, 1996 [ADAMS Accession No. ML003708129] and SECY-17-0075, "Planned Improvements in Design Certification Tiered Information Designations,"

[ADAMS Accession Number ML16196A321] to better understand the basIs behind the selection of Tier 1 information. SNC also reviewed existing certified Tier 1 DCDs to better understand the content and level of detail that should be contained in a Tier 1 DCD.

To support the assessment, SNC used the introduction to the AP1000 Design Control Document, Revision 19 [ADAMS Accession Number ML11171A303], which contains an index of AP1000 Tier 2 information requiring NRC approval for change (i.e., Tier 2*), to correlate Tier 2* items listed in 10 CFR Part 52, Appendix D to applicable sections of the Vogtle Electric Generating Plant (VEGP) 3 and 4 Plant-specific Design Control Document (DCD). Each referenced section of the VEGP 3 and 4 Plant-specific DCD was then assessed using the steps described below.

  • Is the Tier 2* information adequately addressed in the VEGP 3 and 4 Plant-specific Tier 1 DCD or VEGP 3 and 4 Combined License (COL)? This step included a review to determine the degree to which codes, standards, and design and qualification processes, are relied upon for ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1 DCD.
  • Would changes in the Tier 2* information be adequately addressed by other applicable regulations, e.g., 10 CFR 50.46?
  • Would a change to the Tier 2* information have safety significance commensurate with a change to Tier 1 information?
  • Would the evaluation process defined in 10 CFR Part 52, Appendix D, paragraph VIII.B.5 consistently and reliably require prior NRC approval of a change to the Tier 2* information?

The use of the 10 CFR Part 52, Appendix D, paragraph VIII.B.5 evaluation process as part of this methodology is based, in part, on text in SECY-17-0075 (Page 5) which reads:

"The NRC staff examined LARs affecting Tier 2* information from AP1000 COL licensees to assess the effectiveness of the Tier 2* designation and the "50.59-like" change process..

The NRC staff's assessment found that changes proposed in several LARs would have required a license amendment based on one or more of the "50.59-like" criteria, even if the information was not designated as Tier 2*. This suggests that the scope of AP1000 Tier 2* information is somewhat larger than necessary, as the change control process would require prior NRC approval of the changes, regardless of the Tier 2* designation.

Page 3 of 7

ND-18-0646 5 Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

.The staff also found that there are several non-safety-significant Tier 2* changes requested in LARs that also probably would not have tripped the "50.59-like" criteria.

These LARs also suggest that the scope of AP1000 Tier 2* information is somewhat larger than necessary, as these changes should not require prior NRC approval...

The staff also identified some Tier 2* LARs affecting safety-significant topics where the staff is not confident that the changes would have been identified as needing prior NRC approval using the current "50.59-like" criteria and guidance."

The staff's use of the "50.59-like" criteria as guidance in assessing the effectiveness of the Tier 2*

designations is similar to SNC's application of the 10 CFR Part 52, Appendix D, paragraph VIII.B.5 criteria in the methodology described above.

SNC is confident that the multi-faceted methodology used meets the intent of the NRC's policy and guidance in this area, which is to ensure that safety-significant changes would reliably and consistently require prior NRC review and approval. The purpose of the new evaluation criteria is to provide assurance that safety-significant changes to Tier 2* information that might otherwise not be flagged for prior NRC review and approval through existing processes would reliably and consistently require prior NRC review and approval.

Given the variability and inherent lack of specificity with which Tier 1 information is defined, and the speculative nature of the changes that might be sought, it was not considered productive to perform a safety-significance evaluation for each instance of Tier 2* information. For the Tier 2*

information that was evaluated for safety-significance relative to Tier 1 information, SNC utilized guidance and information from various sources (e.g., SECY papers, other approved Design Certifications, final safety evaluation reports) to form qualitative judgements. Principals such as the following were used:

  • whether the information involves top-level design features or performance characteristics at a level of detail that is proportional to the safety- and risk-significance of that top-level design information, and
  • whether a change to the information would fall outside of the envelope of the Commission's safety finding for the AP1000 Design Certification Rule.

Following the evaluation methodology described above, SNC made the following conclusions:

  • First, a set of Tier 2* information is already addressed in Tier 1 and thus a change to this Tier 2* information, which would involve a change to the associated Tier 1 information, would require prior NRC approval. Therefore, neither an evaluation of safety-significance nor new evaluation criteria were considered necessary to provide assurance that changes would receive prior NRC approval.
  • Second, for another set of Tier 2* information, it was concluded that a change to this information would not have safety-significance commensurate with a change to Tier 1 information. Thus, new evaluation criteria were not considered necessary for this set of Tier 2* information. In making this determination, SNC used a wide scope of possible changes to the Tier 2* information to screen for consideration. In the end, only one set of Page 4 of 7

ND-18-0646 5 Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

Tier 2* information, "Polar crane parked orientation," was screened-out based on this methodology step. The orientation of the crane is an input to the containment seismic analyses, but the top-level design requirement is that the containment can withstand seismic Category I and design bases loads. Any changes to the crane would require analyses to demonstrate that the top-level requirements were still met. Therefore, this Tier 2* text was not considered commensurate with Tier 1 information.

  • Third, it was determined that a change to a third set of Tier 2* information would require prior NRC approval under 10 CFR Part 52, Appendix D, paragraph VIII.B.5 or another regulation in a consistent and reliable manner. Thus, it was concluded that the evaluation criteria currently provided in 10 CFR Part 52, Appendix D, VIII.B.5.b or VIII.B.5.c are adequate to reliably and consistently address changes to this information and new evaluation criteria to address changes to this information were not necessary.

For those instances where a change to the Tier 2* information was considered safety-significant and prior NRC approval would not reliably and consistently be triggered through either the Tier 1 change control processes, the evaluation process under 10 CFR Part 52, paragraph VIII.B.5, or through another regulation, SNC performed a more in-depth review of the information to develop new evaluation criteria.

Using the methodology described above, a set of new evaluation criteria was developed that would be used to screen for the critical safety aspects of these Tier 2* matters to determine whether a proposed departure from Tier 2* could qualify to be evaluated under the departure evaluation process for Tier 2 departures outlined in paragraph VIII.B.5. These new evaluation criteria are provided in Enclosure 3 of LAR-17-037.

The use of the term "material change" in Criterion 2 and 3 is to ensure that significant changes, such as to a design process output, method of performing a design process, or method of controlling the design process (Criterion 2) or changes to a method of evaluation or calculation or any change that has an adverse effect on a design function (Criterion 3), receive prior NRC review and approval. In response to NRC Request for Additional Information (RAI) LAR-17-037-9 (Enclosure 17 to this letter) SNC further explained that the intent of using this term is to exclude from the Criterion those changes that are similar to those described in NRC-endorsed guidance NEI 98-03, Revision 1, Guidelines for Updating Final Safety Analysis Reports, Section A4, Simplifying Updated FSAR Information. This NEI guidance, which is added as a reference in updated Enclosure 1 to LAR-17-037, describes certain changes to Part 50 nuclear plant UFSARs that simplify information contained in the UFSAR to improve its focus, clarity and maintainability, such as removing excessive detail, obsolete information, or redundant information. The NEI guidance states that because these changes are not the result of changes to the plant or procedures, they do not require evaluation under 10 CFR 50.59. While plants licensed under 10 CFR Part 52 are not permitted to make any changes to the plant-specific DCD Tier 2 information without performing the evaluations required by 10 CFR Part 52, Appendix D (for AP1000 plants),Section VIII.B.5, this NEI guidance was considered applicable in defining the application of the term "material change" in the context of this proposed evaluation process.

Therefore, the application of the term "material change" through implementation of the guidance contained in Enclosure 1 of LAR-17-037 will ensure that any safety-significant change involving Criterion 2 or 3 will be screened-in as requiring prior NRC approval.

Page 5 of 7

ND- 18-0646 5 Respon setoNRCReque stfo rAdd i tiona lIn fo rma tion(RA I)LAR17- 037- 7Rega rdingthe LAR- 17-037Re view(LAR- 17- 037S3 )

Furthermore,in ma kingcon sis ten c ychange s,SNCag ree stha tifad iscrepan cybe tweenT ie r1 andT ier2*i s iden ti fied ,chang ingT ier2 *i s app rop r iatei f T ie r 1i sde te rminedtobeco rrect

.Su ch achange wou ldbee valua tedunde rthenewp ropo sed COLc riteriaandth roughthe10 CFR Part52, Append i xD , Se ct ion V III.B.5p ro ce sse s

.IfT ier2 *i sde te rm inedtobeco rre ct

,thena T

ier1changei sneededandthechange wou ldrequ i rep r ior NRCapp ro val

. Thiscon cep ti s a

lread ypa r to fSNC 'sp ro ce ssfo rcomp l y ing w ith10CFRPa rt52 ,Append ixD ,Se c tionV III.B.5, andi snotbe ingchangedb yth isreque sted li cen seamendmen t.

RegardingEn clo sure5 ,it wa sno tin tendedtha tthisen clo sureiden tify whatpo r tion so fT ie r2

  • informationarecon s ide redto con tainin fo rma tion thatha s"sa fetys ign i ficance commen su ratew ith T

ie r1."A ssta tedea r lie r

, wh i leade te rm ina tiono fsa fetys ign if i can ce wa spa r to fthep ro ce ss usedtode velopthec ri te ria,SNCde term inedtha tade tailedana l y s i so fal lT ier2 *info rma t ionin ordertoiden ti fy wha tpo rtion sha ve"sa fetys ign i fican cecommen su ra te wi thT ier1in forma tion" wasno tne ce ssa ry.En clo su re 5on lyp ro vide s asumma ryo fthere sultsofthee va lua t ionp ro ce ss describedabo ve. o ftheo rigina lLAR- 17- 037w i llbere v iseda sshownbe lowtoin corporatetheabo ve c

larif icat iono fthep roce ssu sedtode velopthenewe valuationc r ite ria.

Changesto O rigina lLAR- 17- 037 :

Change stoEn c lo sure1:

Revisethefirsttwopa rag raph sonPage8o f19o ftheo rigina lLAR- 17-037toreada sfollow s:

SNCpe r fo rmedanana l ysiso ftheT ie r2

  • ma ttersli stedin10 CFRPa r t52 ,Append i xD ,

Sect ionV II Ipa rag raph sB .6 .bandB .6 .c .Theana lysi sexam inedea chi tem in te rmso fthe fol low ingc ri te r ia:

IstheT ie r2 *info rma t ionadequa telyadd re ssed intheVEGP3and4P lan t spe ci ficT ier1DCDo rVEGP3and4Comb inedL i cen se(COL )?Th iss tep in c ludedare v iewtode te rm inethedeg reetowh ichcode s,standa rds,andde s ign andqua lifica t ionp ro cesse s,a rere lieduponfo rITAACa cceptan cecriteria,bu t notspe cified intheVEGP3and4P lant-spe cif icT ie r1DCD .

Wou ldchange sintheT ier2 *in forma tionbeadequa te lyadd re ssedb yo the r applicab leregu lation s,e .g.,10CFR50 .46?

Wou ld a changetothe Tie r2 *in forma tion ha vesa fety - s ignif ican cecommen sura te wi thachangetoT ie r1in forma tion?

Wou ldthee va lua t ionp ro ce ssde f inedin10CFRPa rt52 ,Append ixD ,pa rag raph VII I.B.5con sisten t l yandre l iab l yrequ irep rio r NRCapp rova lo fachangetothe Tier2 *in forma tion?

Deg reetowh ichthe T ier2 *in fo rma t ion isnotadd re ssedin the fol lowingbu tmee ts Tier1in clu sionc riteria:

Page6o f7

ND-18-0646 Enc losure15 ResponsetoNRCReque stfo rAdd it iona lInfo rma tion(RA I

)LAR17- 037- 7Rega rd ingthe LAR-17-037Re view(LAR- 17- 037S3 )

o VEGP3and4P lan t-spe c ificT ier1De signCon trolDo cumen t(DCD ),o r o VEGP3and4Comb inedL i cen se(COL ),o r o App li cableregu lation s,e.g .

,10CFR50 .46 Deg reeto wh ich Code s

,s tanda rd s,andde signandqua l if ication p ro ce ss,a re re l ieduponfo rITAACa c cep tan cec r iteria,bu tno tspe c ifiedintheVEGP3and4 Plan t- spe cificT ie r1DCD Sa fety-s ignifican ce Deg reeto wh ich10 CFRPa rt52 ,Append ixD ,Se ct ionV III

.B .5 wou lde ffe ct i ve l y e valua teaT ie r2 *depa rtu re Fol low ingthee valua t ionp ro cessde scr ibedabo ve,SNC madethefo l low ingcon c lu s ion s regard ing11o fthe24T ier2

  • ma t te rslistedin10CFRPa r t52 ,Append i xD ,Se ct ionV II I

paragraph sB .6 .bandB .6 .c:

F irst, ase to fT ie r2 *in fo rma tion i salread yadd ressedin T ier 1andthu sachange toth isT ier2 *in fo rma t ion , wh ich wou ldinvo lveachangetothea ssociatedT ier1 in forma tion ,wou ldrequ irep r io rNRCapp ro val

.The refore,ne ithe rane valua tiono f sa fety -significan ce no r new eva lua tion c r ite r ia we re con s ide red ne ce ssa ryto pro videa ssu ran cetha tchange swou ldre ceivep riorNRCapp ro val.

Se cond ,fo rano the rse to fT ie r2 *in fo rma tioni t wa scon cludedtha tachangeto th isin fo rma tion wou ldno tha vesa fety-significan cecommen surate w i thachange toT ie r 1in fo rma tion .Thu s,newe valua t ionc r ite r iawe reno tcon sideredne ce ssary fo rth isse tofT ie r2 *in fo rma tion .

Th ird,it wa sde te rm inedtha tachangetoath irdse to fT ier2 *in forma t ion wou ld requ ire ap rior NRCapp ro valunde r 10 CFR Pa r t52 , Append ixD ,pa rag raph VIII.B.5o rano the rregu lationinacon s i stentandre liable manne r

.Thu s,it wa s con cludedtha tthe e valua t ion c riteria cu rren tl yp ro v idedin 10 CFR Pa rt 52, Append ixD ,V III

.B .5 .b o rV III

.B .5.c a re adequa tetore l iabl y and con s i stently add re ss change stoth i sin fo rma tion and new e valuation c riter iato add ress change stoth isin fo rma tionwe reno tne ce ssa ry.

Basedonthere sultso ftheana l ysis,13o fthe24T ie r2

  • mattersl is ted in10CFR Part52 ,Append ixD ,Se ctionV IIIpa rag raph sB .6.bandB .6.cwe rede term inedtobe adequa te lyco veredb ye xistingT ie r1 info rma t ion ,co veredb yano the rregu lat iono rthe comb inedl i cen se,o rd idno tr isetothele velo fT ier1sa fe tysignifican ce.Therema ining 1311o fthe24T ier2
  • ma t te rsli s ted in10CFRPa rt52 ,Append i xD,Se ct ionV III paragraph sB .6 .bandB .6 .cwe rese le c tedfo rde velopmen to fadd it iona lsc reening cr iter iatha twou ldde term inewhe the rana sso ciatedT ier2 *depa rturequa l if ie sfo rthe departu ree valua t ionp ro ce s sou tl inedin10CFRPa rt52 ,Append ixD ,Se ct ionV III.B .5.

Asumma ryo ftheana ly s i si sp ro videdinEn c lo sure5 .These lected ma tte rsare:

Page7o f7

Southern Nuclear Operating Company ND-18-0646 Enclosure 16 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) LAR 17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

Supplement 3 changes that are added to the original LAR submittal are shown as blue, underlined text; deletions of original LAR text are shown as red strikethrough text.

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

ND-18-0646 6 Response to NRC Request for Additional Information (RAI) LAR 17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

LAR 17-037-8] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

RAI Question LAR 17-037-8 10 CFR Part 52, Appendix D, Section VIII.B.6.b states, in part, that an applicant who references this appendix may not depart from the Tier 2* matters without prior NRC approval. In the LAR 17-037 submittal, Page 9 of Enclosure 1 states that Criterion 2 was developed as a screening criterion as a result of the analysis performed that was related to Tier 2* matters, which include, among other things, instrumentation and control (I&C) system design processes, methods, and standards. As mentioned in the LAR 17-037 submittal, the proposed Criterion 2 is to be used to screen material changes to the design processes for the following two I&C systems:

  • Diverse Actuation System (DAS)
  • Protection and Safety Monitoring System (PMS)

The Vogtle Units 3 and 4 UFSAR designates only the following technical or topical reports, as a whole, as Tier 2* items for I&C:

  • WCAP-17201-P, "AC160 High Speed Link Communication Compliance to DI&C-ISG-04 Staff Position 9, 12, 13, and 15," Rev. 0
  • WCAP-15927, "Design Process for AP1000 Common Q Safety Systems," Rev. 2
  • WCAP-17179, "AP1000 Component Interface Module Technical Report," Rev. 2
  • WCAP-16096-NP-A, "Software Program Manual for Common Q Systems," Rev. 01A Question 1 Although the Component Interface Module (CIM) design process is briefly discussed in Tier 1 under the PMS description, WCAP-17179 states that the CIM interfaces with the PMS and other systems, indicating that it is separate from the PMS. In addition, the CIM design process is different from that for the PMS. The licensee is requested to identify the CIM design processes as among those considered under Criterion 2 by explicitly listing them as examples under that criterion, or explain why this is unnecessary.

SNC Response to RAI Question 1 Because the CIM provides the priority logic between the PMS and other systems, CIM is often addressed in association with PMS, and in fact, the CIM is addressed in Tier 1 Section 2.5.2, Protection and Safety Monitoring System. So, for simplicity, the guidance and bases provided in to SNC letter ND-17-1726 (LAR-17-037) did not specifically call out the CIM separately from the discussion provided for the PMS. However, SNC concurs that the CIM could Page 2 of 4

ND-18-0646 6 Response to NRC Request for Additional Information (RAI) LAR 17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3) be addressed in a separate bases discussion, similar to that provided for other elements of Tier 2* information covered by Criterion 2 of the proposed License Condition. It is worth noting that there is only a minimal, high-level discussion of the CIM development information in Tier 2*

document WCAP-17179, and there is a very low likelihood that this information will be changing at this point in the plant's design/construction. Because the evaluation of changes to the design process applicable to PMS and the CIM would follow a similar approach, the basis for an evaluation of changes to the CIM design process would be consistent with that already provided for changes to the PMS design process in ND-17-1726, Enclosure 1.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-8, Question 1:

Changes to Enclosure 1:

Add the following to the detailed description and bases for Criterion 2 on pages 10 and 11 of 19:

Criterion 2 (Design Processes) Bases:

The design processes addressed in the VEGP 3 and 4 Plant-specific Tier 1 DCD and for which some Tier 2* information is contained in the VEGP 3 and 4 plant-specific Tier 2 DCD are:

  • Diverse Actuation System (Plant-specific Tier 1 DCD, Section 2.5.1; Plant-specific Tier 2 DCD, Chapter 7);
  • Protection and Safety Monitoring System (Plant-specific Tier 1 DCD, Section 2.5.2; Plant-specific Tier 2 DCD, Chapter 7);
  • Component Interface Module (Plant-specific Tier 1 DCD, Section 2.5.2; Plant-specific Tier 2 DCD, Chapter 7);
  • Human Factors Engineering (Plant-specific Tier 1 DCD, Section 3.2; Plant-specific Tier 2 DCD, Chapter 18);

Diverse Actuation System (DAS)

While paragraph B.5.b allows changes to design processes without prior NRC approval provided that the design function is not more than minimally adversely affected, this new criterion does not allow any material change to a design process.

Protection and Safety Monitoring System (PMS)

UFSAR Tier 2* information related to PMS is contained in Westinghouse WCAP reports that are incorporated by reference into the UFSAR. For the PMS, departures related to a design process as described in Westinghouse WCAPs may not be easily evaluated against the eight criteria of paragraph B.5.b; therefore, some departures may not receive prior NRC approval as required. The application of proposed Criterion 2 assures that any material departure related to PMS design processes receives prior NRC approval.

Page 3 of 4

ND-18-0646 6 Response to NRC Request for Additional Information (RAI) LAR 17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

Component Interface Module (CIM)

UFSAR Tier 2* information related to the CIM is contained in WCAP-17179-P (Proprietary) and WCAP-17179-NP (Non-Proprietary), which are incorporated by reference into the UFSAR. For the CIM, departures related to a design process as described in WCAP-17179-P/NP may not be easily evaluated against the eight criteria of paragraph B.5.b; therefore, some departures may not receive prior NRC approval as required. The application of proposed Criterion 2 assures that any material departure related to the CIM design processes receives prior NRC approval.

Question 2 The design process for the DAS is covered in Tier 1 Section 2.5.1. The staff is not aware of any Tier 2* information governing the DAS design process. However, the staff notices that there is a discussion in the LAR on changes to the DAS design process. The licensee is requested to clarify how changes to the DAS design process will receive prior NRC approval. In particular, identify the DAS design process information that is designated as Tier 2* information.

SNC Response to RAI Question 2 Tier 2* incorporated by reference document, WCAP-17179, "AP1000 Component Interface Module Technical Report," addresses aspects of DAS related to the DAS design process.

Specifically, Section 2.9 discusses the application of the various aspects of diversity (i.e., diversity in design, equipment, function, humans, signals, and software) in the design of the CIM and DAS.

Additionally, Tier 2* information related to DAS is found in UFSAR Subsection 7.7.1.11, as follows:

[The manual actuation function of the diverse actuation system is implemented by hard-wiring the controls located in the main control room directly to the final loads in a way that completely bypasses the normal path through the protection and safety monitoring system cabinets, and the diverse actuation system automatic logic.]*

A material change regarding the hard-wiring aspect of the design as described in this Tier 2*

UFSAR Subsection 7.7.1.11 text would be screened as a Tier 2* change, but may not trip the "design process" aspect of proposed License Condition 2.D.(13)(a)2, because this text is more directly associated with the design features of the system, rather than the design process. A further evaluation under the requirements of 10 CFR Part 52, Appendix D, paragraph B.5 would then be performed to determine if the change would require prior NRC approval of the change as a result of the responses to the paragraph B.5.b and B.5.c questions.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-8, Question 2:

None.

Page 4 of 4

Southern Nuclear Operating Company ND-18-0646 Enclosure 17 Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) LAR 17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

Supplement 3 changes that are added to the original LAR submittal are shown as blue, underlined text; deletions of original LAR text are shown as red strikethrough text.

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

ND-18-0646 7 Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

The following were questions provided by the NRC Staff [Request for Additional Information (RAI)

[LAR 17-037-9] regarding the review of Southern Nuclear Operating Company (SNC) License Amendment Request (LAR)17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

RAI Introduction The scope of Tier 2* information of the AP1000 certified design is defined in 10 CFR Part 52 Appendix D Sections VIII.B.6.b and VIII.B.6.c, which state that changes to Tier 2* will be treated as a request for a license amendment and require staff review and approval prior to implementation. SECY-17-0075, "Planned Improvements in Design Certification Tiered Information Designations," (ADAMS Accession No. ML16196A321) states that Tier 2* information has safety significance commensurate with that of Tier 1 information and would have received the Tier 1 designation, except that NRC decided to provide more flexibility for this type of information. Per the SECY and the statements of consideration associated with the final rule for Part 52 (72 FR 49352, Licenses, Certifications and Approvals for Nuclear Power Plants, p.49365, August 28, 2007), the purpose of the Tier 2* designation is to control certain information which the staff has determined to have safety significance commensurate with that of Tier 1 information. Consistent with this significance, the Tier 2* change process ensures that the information is controlled in a similar manner (e.g. changes to such information require prior staff review and approval).

Question 1 of LAR-17-037 contains the proposed revision to COL license condition 2.D which includes a new condition. This new condition governs the desired departures from plant-specific DCD Tier 2* information and states that SNC would be exempt from the requirements of 10 CFR Part 52, Appendix D, Paragraphs II.F and VIII.B.6 that invoke the Tier 2* change process. Among the provisions of the new condition is that the exemption from the current Tier 2* change process would apply except for departures from Tier 2* information that would ". . . Result in a material change to the fuel criteria evaluation process . . ."

Section 5.6.3 of Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Technical Specifications provides the reporting requirement for the Core Operating Limits Report (COLR). Section 5.6.3(b) provides the analytical methods used to determine the core operating limits and states that these methods shall be those previously reviewed and approved by the NRC.

WCAP-12488-P-A, "Fuel Criteria Evaluation Process," is not included in the methods listed in Section 5.6.3(b) of technical specifications; however, it is not clear to the staff whether WCAP-12488-P-A is integral to any of the listed methodologies.

Please confirm that WCAP-12488-P-A is not referenced within any of the approved methodologies listed in Technical Specification Section 5.6.3(b) or provide justification that would demonstrate that the proposed departure process as presented in LAR-17-037 couldn't lead to a change in a methodology as listed in the COLR without requiring NRC approval.

2 of 9

ND-18-0646 7 Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

SNC Response to RAI Question 1 The proposed changes to the Tier 2* evaluation process described in LAR-17-037 do not affect the Technical Specifications change control process requirements specified in 10 CFR Part 52, Appendix D, VIII.B.5.a or the specific Technical Specifications requirements in Section 5.6.3 for changes to analytical methods used to determine the core operating limits in the Core Operating Limits Report (COLR). Any changes to the documents listed in Technical Specifications Section 5.6.3.b require prior NRC approval. If WCAP-12488-P-A were referenced in any of these documents, changes to WCAP-12488-P-A would also require a change in the document that references it and thus require prior NRC approval. Nevertheless, a review of the references listed in Technical Specifications 5.6.3(b) was performed and confirmed that WCAP-12488-P-A is not referenced in any of the Technical Specifications COLR reference documents.

Therefore, the proposed departure process as presented in LAR-17-037 could not lead to a change in analytical methods used to determine the core operating limits (i.e., the documents listed in Technical Specifications Section 5.6.3.b) without obtaining prior NRC approval.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 1 None.

Question 2 Item (1) of 10 CFR Part 52 Appendix D, Section VIII.B.6.b covers the maximum rod average fuel burnup. Additionally, the validity of the methods contained in referenced topical report WCAP-12488-P-A and the staff's approval for this topical report are based upon the burnup-dependent empirical fuel performance models. of LAR-17-037 contains the proposed revision to COL license condition 2.D which includes a new condition. This new condition governs the desired departures from plant-specific DCD Tier 2* information and states that SNC would be exempt from the requirements of 10 CFR Part 52, Appendix D, Paragraphs II.F and VIII.B.6 that invoke the Tier 2* change process. The exemption from the current Tier 2* change process would apply except for departures from Tier 2*

information that, "Result in a material change to the . . . maximum fuel rod average burn-up limits

. . ." However, the staff notes that Enclosure 1 of LAR-17-037 provides guidance (Criterion 3) which states that "[a] material change is any change that would have an effect on maximum fuel rod average burn-up limits". The staff is concerned that the wording in Enclosure 3 does not reflect the guidance provided in Enclosure 1 and could lead a screener to interpret that some changes to rod average burn-up limits could be made without requiring prior staff review and approval.

Please revise Enclosure 3 to clarify whether any changes to maximum fuel rod average burn-up limits are excluded from this departure.

3 of 9

ND-18-0646 7 Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

SNC Response to RAI Question 2 Proposed Criterion 3 in Enclosure 3 of the original LAR-17-037 will be revised to require prior NRC approval for any changes to maximum fuel rod average burn-up limits.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 2 Changes to Enclosure 1:

Change the detailed guidance for Criterion 3 on Page 11 of 19 to read as follows:

  • A material change is Any change to the that would have an effect on maximum fuel rod average burn-up limits requires prior NRC approval.

Changes to Enclosure 3:

Revise Criterion 3 as follows:

3. Result in a material change to the fuel criteria evaluation process, the fuel principal design requirements, or nuclear design of fuel and reactivity control system,; or result in any change to the maximum fuel rod average burn-up limits, or (Additional changes, not shown here, are made to Criterion 3 in response to Question 6 below.) Similar conforming changes are also applicable to Enclosures 1, 4, and 5 of the original LAR-17-037.

Question 3 of LAR-17-037 provides detailed guidance for Criterion 3 and contains examples of what are not considered material changes and would therefore not require prior NRC review and approval. The list includes "minor corrections to drawings and figures (e.g., correcting mislabeled components)." It is unclear to the staff what drawings and figures this refers to since the Tier 2*

information provided in FSAR Sections 4.2, 4.3, and 4.4 does not include any drawings or figures.

The staff requests the licensee to clarify which Tier 2* drawings and figures the guidance is referring to, or correct the Criterion 3 guidance to only refer to relevant examples specific to the Tier 2* information governed by Criterion 3.

SNC Response to RAI Question 3 The reference in the Criterion 3 detailed guidance to minor corrections to drawings and figures was inappropriate, since there are no applicable figures or drawings in the UFSAR that are Tier 2*. of the original LAR-17-037 will be revised to remove this reference.

4 of 9

ND-18-0646 7 Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 3 Changes to Enclosure 1:

Revise the detailed guidance for Criterion 3 on Pages 11 and 12 of 19 as follows:

The following examples are not material changes:

o Editorial Changes o Clarifications to improve reader understanding o Correction of inconsistencies within the document which are clearly discernible (e.g., between sections) o Minor corrections to drawings and figures (e.g., correcting mislabeled components) o Changes that do not change the meaning or substance of information presented (e.g., reformatting or removing detail)

Question 4 In Enclosure 1, the detailed guidance for Criterion 3 contains examples of what are not considered material changes. The list includes "[c]hanges that do not change the meaning or substance of information present (e.g., reformatting or removing detail)." The staff disagrees that removing detail does not necessarily change the meaning or substance of information.

The staff requests the licensee to revise the guidance in Enclosure 1 to clearly indicate when removing detail would not require NRC approval.

SNC Response to RAI Question 4 The intent of the referenced guidance was to exclude from the definition of a material change those changes that are similar to those described in NRC-endorsed guidance NEI 98-03, Revision 1, Guidelines for Updating Final Safety Analysis Reports, Section A4, Simplifying Updated FSAR Information. This NEI guidance describes certain changes to Part 50 nuclear plant UFSARs that simplify information contained in the UFSAR to improve its focus, clarity and maintainability, such as removing excessive detail, obsolete information, or redundant information. The NEI guidance states that because these changes are not the result of changes to the plant or procedures they do not require evaluation under 10 CFR 50.59. While plants licensed under 10 CFR Part 52 are not permitted to make any changes to the plant-specific DCD Tier 2 information (i.e., UFSAR) without performing the evaluations required by 10 CFR Part 52, Appendix D (for AP1000 plants),Section VIII.B.5, this NEI guidance was considered applicable in defining the application of the term "material change" in the context of this proposed evaluation process.

To clarify this section of the Criterion 3 guidance, Enclosure 1 to the original LAR-17-037 will be revised to add a reference to NEI 98-03 regarding removing detail.

5 of 9

ND-18-0646 7 Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 4 Changes to Enclosure 1:

Revise the detailed guidance for Criterion 3 on Pages 11 and 12 of 19 as follows (includes changes made in response to Question 3 of this RAI):

The following examples are not material changes:

o Editorial Changes o Clarifications to improve reader understanding o Correction of inconsistencies within the document which are clearly discernible (e.g., between sections) o Minor corrections to drawings and figures (e.g., correcting mislabeled components) o Changes that do not change the meaning or substance of information presented (e.g., reformatting or removing detail as described in NEI 98-03, Revision 1, Guidelines for Updating Final Safety Analysis Reports, Section A4 [ADAMS Accession Number ML003779028]).

Question 5 of LAR-17-037 provides guidance for Criterion 3 to help distinguish which changes could be made without requiring prior staff review and approval. The guidance includes the statement "[a] material change to a design would be any change that has an adverse effect on a design function." The staff notes that no definition is provided to clarify what types of changes would be considered "adverse." Additionally, it is unclear if the term "design function" refers to the design criteria presented in WCAP-12488, or if a different definition was intended.

The staff requests the licensee to provide a definition for "adverse" and "design function" to clarify the guidance provided in relation to Criterion 3 in Enclosure 1 and assist the reader in determining if a particular change to a Tier 2* item would be considered material, thereby requiring prior staff review and approval.

SNC Response to RAI Question 5 The application of the terms "adverse" and "design function," as used in the guidance discussions in Enclosure 1 of the original LAR-17-037, is derived from the use of the same terms in NRC-endorsed guidance NEI 96-07, Revision 1, Guidelines For 10 CFR 50.59 Implementation (refer to footnote 6 on Page 12 of 19 in Enclosure 1 of the original LAR 17-037). This NEI guidance provides an extensive discussion regarding how to evaluate whether a change adversely affects a design function. The term "design function" is defined in NEI 96-07 as follows (from Section 3.3 of NEI 96-07):

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ND-18-0646 7 Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

"Design functions are UFSAR-described design bases functions and other SSC functions described in the UFSAR that support or impact design bases functions. Implicitly included within the meaning of design function are the conditions under which intended functions are required to be performed, such as equipment response times, process conditions, equipment qualification and single failure.

Design bases functions are functions performed by systems, structures and components (SSCs) that are (1) required by, or otherwise necessary to comply with, regulations, license conditions, orders or technical specifications, or (2) credited in licensee safety analyses to meet NRC requirements" The use of the term "design function" in the guidance was not intended to directly refer to the design criteria presented in WCAP-12488.

While it is not the intent of the LAR guidance to include the volume of the information contained in NEI 96-07 regarding the application of these terms, Enclosure 1 of the original LAR-17-037 will be revised to expand the reference to NEI 96-07 to clarify the use of the terms "adverse" and "design function".

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 5 Changes to Enclosure 1:

Revise footnote 6 on Page 12 of 19 to read as follows:

The use of the terms "adverse" and "design function," as used in the guidance discussions, is derived from the use of the same terms in NEI 96-07, Revision 1, Guidelines For 10 CFR 50.59 Implementation [ADAMS Accession Number ML003771157]. This NEI guidance provides an extensive discussion regarding how to evaluate whether a change adversely affects a design function. The term "design function" is defined in NEI 96-07, Section 3.3.

Furthermore, the citation for footnote "6" will be moved up in Enclosure 1 to be placed adjacent to the first usage of the term "adverse" in the guidance text. The footnote text already refers to the use of the term in "the guidance discussions" and therefore makes clear that the footnote applies to subsequent uses of the term.

Question 6 The staff reviewed the proposed departure evaluation process outlined in LAR-17-037, including the Reviewer's Aids in Enclosure 4 and Enclosure 5. The staff notes that there are no proposed screening criteria for changes to Tier 2* information associated with small-break loss-of-coolant accident (LOCA) analysis methodology. Due to the uniqueness of the AP1000 design the staff determined the use of the NOTRUMP code to be acceptable, in part, because of the identified Tier 2* information in Chapter 15 (two paragraphs in Sections 15.6.5.4B.2.2 and 15.6.5.4B.2.3).

Under the 50.59 process NEI 96-07 allows changes to methodology input parameters; however, 7 of 9

ND 0646 7 Respon setoNRCReque stforAdd it iona lIn forma tion(RA I)LAR- 17- 037- 9Rega rd ingthe LAR 037Re v iew(LAR- 17- 037S3 )

the s ta f fcon side rsT ier2 *in forma t ion asso ciatedw ithNOTRUMPhomogeneou ssen s iti vitymode l andc rit i calhea tf lu xa sse ssmen tdu r inga ccumu lato rinje ct iontobesa fetys igni ficantandan integrala spe cto fthe me thodo logya sapp ro vedfo rtheAP1000 .The refo re,thes taff ma inta ins thatan ychange stotha tin forma tion wou ldinvo l veadepa rturef roma me thodo fe valua tion describedin theFSARandrequ irep riorNRCre viewandapp ro val.HadT ier2 *note xisteda tthe t

imeo fapp ro valo ftheAP1000de sign,thein forma t ionre latedtothe NOTRUMP me thodo logy wouldha vee ithe rbeende signa tedT ier1o rachangetotheapp ro vedtop icalreportwou ldha ve beenne ces sary.

Thes taffreque ststha tadd it iona ls creen ingc r ite r iabein cluded in the T ier2 *depa r turee valua tion proce sstha tcap tu re sthec r it i calsa fetya spe c to ftheT ie r2*in forma t ionfo rsma ll-brea kLOCA analysisme thodo logy , andiden t ify thatan ychange s(ma te r ialo ro the rwise )totho seTier2 *item s mustunde rgoNRCre viewandapp ro vala sachangetotheme thodo logy.

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  • informa tionfo rsma llb rea kLOCAana l ysis me thodo logy .

Changesto O rig ina lLAR- 17- 037inresponsetoRA ILAR- 17- 037- 9

, Ques tion6 Change stoEn clo sure1  :

Revisetheth irds creen ingc r ite r ionp ro v idedonpage6o f19toread  :

3. Re su l tina ma terialchangetothefue lc r iteriae valua tionp ro ce ss,thefue lp rincipal de s ignrequ iremen ts,o rnu clea rde signo ffuelandrea ctivi tycon trolsystem, ;o rre su lt in an ychangetothema ximum fue lroda ve ragebu rn- upl imi ts ;orre sul tin an ychange to sma llb rea k LOCA ana l ysis me thodo logy de sc ribedin UFSAR Sub se c tion s 15.6 .5.4B .2.2o r15 .6 .5.4B .2.3 ;o r Repla cethela stpa ragraphandsuppo rt ingbu l le tsonpage8o f19w ith:

[Note :Th isnewte xta lsore fle ctste xttha t isaddedb ythere spon setoRA ILAR 037- 3in SNCle tterND- 18- 0608 ,En clo sure11 ,page3o f4(LAR- 17- 037- S2).]

      • Therema ining1311o fthe24T ier2 *ma t te rs listed in 10CFRPa r t52 ,Append ixD ,

Se c tion V II Ipa rag raph sB .6 .band B .6.c we rese lectedfo r de velopmen to f add it iona l screen ingc riteriatha twou ldde term inewhe the rana sso ciatedT ie r2*depa r turequa l ifie s forthedepa rtu ree valua t ionp ro cessou t l

inedin10CFR Pa rt 52 ,Append ixD , Se c tion VI II.B.5. Asumma ryoftheana lysisi spro v idedin Enclo su re5 .These lectedma t te r sa re:

Rea ctorcoo lan tpumptype Sma ll-brea klo ss- o f- coolan ta cciden t(LOCA )ana l ysi smethodo logy S creende s ignc riteria 8o f9

ND-18-0646 7 Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

Add the following new paragraph at the end of the bases discussion for Criterion 3 on Page 12 of 19:

Due to the uniqueness of the AP1000 design, the use of the NOTRUMP code is considered acceptable, in part, because of the identified Tier 2* information in Chapter 15 (two paragraphs in Subsections 15.6.5.4B.2.2 and 15.6.5.4B.2.3). The Tier 2* information associated with NOTRUMP homogeneous sensitivity model and critical heat flux assessment during accumulator injection is considered to be safety-significant and an integral aspect of the methodology as approved for the AP1000. Therefore, any changes to that information would involve a departure from a method of evaluation described in the FSAR and require prior NRC review and approval.

Changes to Enclosure 3:

Revise Criterion 3 as follows (includes changes made in response to RAI LAR-17-037-9 Question 2):

3. Result in a material change to the fuel criteria evaluation process, the fuel principal design requirements, or nuclear design of fuel and reactivity control system,; or result in any change to the maximum fuel rod average burn-up limits; or result in any change to small break LOCA analysis methodology described in UFSAR Subsections 15.6.5.4B.2.2 or 15.6.5.4B.2.3; or Changes to Enclosure 4:

Revise the text adjacent to the decision box for Qualifying Criterion 3 on page 2 of 3 to read:

3. Result in a material change to the fuel criteria evaluation process, the fuel principal design requirements, or nuclear design of fuel and reactivity control system,; or result in any change to the maximum fuel rod average burn-up limits; or result in any change to small break LOCA analysis methodology described in UFSAR Subsections 15.6.5.4B.2.2 or 15.6.5.4B.2.3; or Changes to Enclosure 5:

Revise the table entry for small-break loss-of-coolant accident (LOCA) analysis methodology on Page 3 of 6 to read as follows:

6 Small-break loss-of- No Yes 10 CFR 50.46 and N/A Result in any coolant accident adequately change to small break (LOCA) analysis addressed by LOCA analysis methodology. paragraph VIII.B5 methodology described Safety significance in UFSAR Subsections 15.6.5.4B.2.2 or 15.6.5.4B.2.3.

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