ML19024A509
| ML19024A509 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 12/05/2018 |
| From: | Williams J Office of New Reactors |
| To: | Frank Akstulewicz, Joseph Colaccino, Jordan Hoellman Office of New Reactors |
| Muniz A | |
| Shared Package | |
| ML18256A400 | List: |
| References | |
| Download: ML19024A509 (271) | |
Text
1 Williams, Joseph From: Williams, Joseph Sent: Tuesday, December 05, 2017 8:45 AM To:Hoellman, Jordan; Akstulewicz, Frank; Cola ccino, Joseph; Bradford, Anna; Dixon-Herrity, Jennifer; Patel, Chandu; Monninger, John; Fr anovich, Mike; Taylor, Robert; Campbell, Andy; Caldwell, Robert; Segala, John; McGinty, Tim; Krohn, Paul; Carpenter, Cynthia; Hearn, Peter; Rivera-Varona, Aida; Fetter, Allen
Subject:
Initial Comments on DRAFT SN C LAR-17-037 Changes to Tier 2* Departure Evaluation Process for 12/14/2017 public meeting Attachments:ND-17-1726_LAR-17-037_T2-Star Chng_Pre-submittal_Final DRAFT 2017-12-01 JFW comments 20171205.docx Categories:
Red CategoryMy initial comments are given below and in the attached file. I expect to refine these thoughts and develop additional comments as I have more opportunity to think about the issues and discuss them with colleagues. The attached file is a Word version the PDF distributed yesterday; while no text has been changed, I haven't checked to see if the pagination has been affected.
- 1. We need to carefully consider the generic implications of this proposal, both for AP1000 licensees, and other current and future Part 52 licensees. a. Arguably, given the generic implications, this issue should be addressed via rulemaking. Issuing an amendment appears to circumvent the rulemaking process, as it would be difficult to argue that a future rule could not be based on this amendment. However, the amendment is not subject to the same requirements for public engagement and comment as a rule. b. This topic is also arguably a policy issue which should be considered by the Commission. i. The proposal fundamentally affects the structure of a Part 52 certification and license, which were subjects of Commission decisions. ii. A paper addressing the issue should discuss the staff's views regarding rulemaking issues. 2. The proposed criteria are too subjective, and do not provide a clear delineation between Tier 2* information that is Tier 1-equivalent and other less significant information. 3. There is no reference to NEI's proposed Tier 1 First Principles, so there does not appear to be any alignment between that activity and the proposed amendment. 4. The proposed amendment does not provide any reporting requirements to ensure NRC is made aware of changes, similar to reporting of 50.59 changes. 5. It would be helpful if SNC described how it envisions the process could be applied to what it considers to be the problematic Tier 2* amendments that have already been issued. 6. The proposal may be overly broad, in that it seems likely that many of the issues (e.g., editorial problems, internal consistency issues, mislabeled figures, etc.) could be addressed without introducing subjective questions about whether or not a change is "material." Reaching agreement on such questions could be difficult, so focusing on a narrower set of issues could yield a significant portion of the benefit without introducing more difficult aspects. A narrower scope might avoid introducing policy issues, as well.
For these reasons, it is my opinion that this is an issue worthy of careful consideration, including stakeholder engagement, so we would be running a great risk if we move too quickly to issue the amendment as soon as the draft LAR suggests.
Joe Williams
Senior Project Manager 2Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 From:Hoellman,JordanSent:Monday,December04,20178:25AMTo:Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>;Franovich,Mike<Mike.Franovich@nrc.gov>;Taylor,Robert<Robert.Taylor@nrc.gov>;Campbell,Andy<Andy.Campbell@nrc.gov>;Caldwell,Robert<Robert.Caldwell@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;McGinty,Tim<Tim.McGinty@nrc.gov>;Krohn,Paul<Paul.Krohn@nrc.gov>;Carpenter,Cynthia<Cynthia.Carpenter@nrc.gov>;HQOWFN 07B04 25p<HQ OWFN 07B04 25p@nrc.gov>;Hearn,Peter<Peter.Hearn@nrc.gov>;RiveraVarona,Aida<Aida.Rivera Varona@nrc.gov>;Fetter,Allen<Allen.Fetter@nrc.gov>
Subject:
FW:DRAFTSNCLAR 17 037ChangestoTier2*DepartureEvaluationProcessfor12/14/2017publicmeetingHiall-PleaseseetheattacheddraftTier2*LARthatwillbediscussedinapre submittalmeetingwithSNCon12/14/17.
Thankyou,JordanFrom:Redd,JasonP.[mailto:JPREDD@southernco.com
]Sent:Friday,December01,201710:28AMTo:Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>Cc:Amundson,TheodoreEdwin<X2TAMUNS@southernco.com
>;Pierce,ChuckR.<CRPIERCE@southernco.com
>;Allen,LeslieG.(Balch)<lgallen@balch.com
>;Haggerty,Neil<X2NHAGGE@SOUTHERNCO.COM
>;Hicks,ThomasE.<X2TEHICK@southernco.com
>;Marrichi,JamesP.<X2JPMARR@southernco.com
>;Chamberlain,AmyChristine<ACCHAMBE@southernco.com
>;Blanton,Stan(Balch)<sblanton@balch.com
>;Aughtman,AmyG.<AGAUGHTM@SOUTHERNCO.COM
>;Sparkman,WesleyA.<WASPARKM@southernco.com
>;Yox,Michael<MYOX@SOUTHERNCO.COM
>;Jones,DavidH.<DAHJONES@southernco.com
>
Subject:
[External_Sender]DRAFTSNCLAR 17 037ChangestoTier2*DepartureEvaluationProcessfor12/14/2017publicmeetingChandu,AttachedpleasefindtheDRAFTSNCLAR 17 037"ChangestoTier2*DepartureEvaluationProcess"fortheupcoming12/14/2017publicmeeting.PleasesharethisdraftwiththeStaffandwiththeinterestedpublicfortheirrev iewpriortotheplannedpresubmittalmeeting.Welookforwardtohavinganopen,beneficialdiscussionwiththeStaffonthistopicinsupportoftheformalsubmittaloftheLARpromptlyafterthepresubmittalmeeting.Ifyouhaveanyquestions,pleasegivemeacall;thankyou.JasonP.Redd,PEProjectEngineerNuclearDevelopmentRegulatoryAffairsSouthernNu clearOperatingCompany(205)9926435/8 992 6435jpredd@southernco.com 3
4 Williams, Joseph From: Williams, Joseph Sent: Thursday, December 07, 2017 7:08 AM To: Karas, Rebecca; Jackson, Diane Cc: Segala, John
Subject:
Tier 2* LAR Meeting Becky/Diane, FYI, I spoke to John Monninger to tell him that I wasn't particularly satisfied with the Tier 2* LAR meeting yesterday. I told him that it's not clear what messages we intend to convey to SNC (at least to me), and it appeared the only meaningful input came from staff outside DNRL. I briefly reviewed my comments with John, DNRL management provided reactions to what we said, but there wasn't much offered in the way of independent contributions. I told John you were both there and had participated if you'd like to offer your perspectives. My feeling is that we aren't ready for a meaningful discussion at the public meeting next week.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 5 Williams, Joseph From: Williams, Joseph Sent: Monday, December 11, 2017 11:18 AM To: Jackson, Diane; Karas, Rebecca
Subject:
FW: Tier 2* LAR Meeting Diane and Becky, FYI. I should have included you when I forwarded this to Monninger, et al.
Joe From:Williams,JosephSent:Monday,December11,201711:17AMTo:Monninger,John<John.Monninger@nrc.gov>;Franovich,Mike<Mike.Franovich@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>
Subject:
FW:Tier2*LARMeetingJohn and Mike, See below. I reached out to DNRL regarding the Tier 2* proposed LAR meeting planned for this coming Thursday morning. Given the feedback below, I don't think we are ready to discuss this proposed LAR outside the agency.
Joe From:Patel,ChanduSent:Monday,December11,201710:43AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>
Subject:
RE:Tier2*LARMeetingHiJoe, Thankyouforaskinggoodquestions.WearecheckingwithSNCtoseeiftheywillhaveanyhandouts.Yes,youarerightthatwedidnotmakeanydecisions.Wewilldecideallthedetailsbeforethemeetinghopefullywithinnextcoupleofdays.Butasofnow,Ithinkyoushouldexpres sanyopinionyouhaveduringthemeeting.IbelieveFrankwantstohaveDivisionlevelpresencesoitmaybeagoodideatomakeyourmanagementawareofyourideas.JenniferandIwilltalkwithFrankandAnnatoseehowtheywanttohandlethemeeting.Thisisapre a pplicationmeetingandanybodyshouldexpresshis/herviewsandletlicenseedecidehowtheywillsubmitthefinalproduct.Wewillletyouknowasthedetailsgetclear.Ideally,thestaffshouldspeakwithonevoicebutIamnotsureifwehavetimetodothatingiventimeframe.Wewilldoourbesttominimizetheconfusionsinthemeeting.AsfarastheEPIDisconcerned,wewillsendittoyou.Itissupposedtobechargedtopre applicationmeetings.
Thanks,Chandu 6From:Williams,JosephSent:Monday,December11,20178:41AMTo:Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>
Subject:
Tier2*LARMeetingChandu and Jordan, I'm not clear on how things are supposed to proceed in the Tier 2* public meeting on Thursday. I'd very much like to avoid a situation like the internal meeting last Wednesday where I was called upon to make an ad hoc presentation, so can you tell me who is going to lead the discussion? Are there any handouts being prepared by DNRL or from SNC? I'm also not clear on messages we intend to convey, as I don't think we reached an agreement on at least some of the issues discussed last Wednesday.
I also need a CAC for my preparations and attendance.
Thanks.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors Office of New Reactors 301.415.1470 7 Williams, Joseph From: Williams, Joseph Sent: Monday, December 11, 2017 1:33 PM To: Hoellman, Jordan; Patel, Chandu Cc: Segala, John; Karas, Rebecca; Jackson, Diane; Habib, Donald; Dixon-Herrity, Jennifer
Subject:
RE: Tier 2* LAR Meeting Jordan, This is a potentially precedent-setting proposal that deserves more deliberate consideration. My high level concerns include lack of alignment on whether this request involves a policy decision and potential rulemaking implications. I also don't think we have a common position on the relationship between this proposal and NEI's Tier 1 First Principles. Further, the proposed schedule is unrealistic, in my opinion. We also didn't discuss detailed comments to any degree, so I'm not sure whether there would be any internal disagreement on those points. It's my understanding that DNRL wants division management support at the meeting, but I'm unaware of any alignment discussion at that level; division management participation in the meeting last week was quite
limited. Frankly, beyond the discussion Frank and Anna participated in, I was disappointed that DNRL didn't have its own thoughts to offer regarding either the broad issues raised by the proposal or the specifics. Given these issues, I personally don't feel we are ready to discuss this proposed LAR without additional discussion.
Joe From:Hoellman,JordanSent:Monday,December11,201711:53AMTo:Patel,Chandu<Chandu.Patel@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>
Subject:
RE:Tier2*LARMeetingJoe-Forthispresubmittalmeeting,SNCdecidedthatitwouldbebesttousethedraftLARtoleadtheconversation.Assuch,SNCwillnotbeprovidingapresenta tion,butinsteadwilljustprovideaverybriefoverviewoftheLAR,thengorighttoquestionsfromtheStaff.SNCwillbepreparedtoanswerourquestions,ortakethembackforconsideration.Youwillnotbeaskedorexpectedtoprovideanypresentation,butarewelcometoaskthequestionsyouhave.
Whichissuesdon'tyouthi nkwereachedanagreementonthatyouwouldliketodiscussatthemeeting?Itismyunderstandingthatwe'veagreedtoaskabouthowthisLARimpactsHFE,criticalsections,fuel;iftheLARshouldpropo s especificreportingrequirements;andexamplesofhowtheproposedprocesswouldbeapplied,atleast.
TheEPIDis000463/05200025/L 2017 LLA 0138 ,VogtleLARPreSubmittalMeetings.Ifyouhaveotherquestions,pleaseletusknow.Thanks,Jordan 8From:Patel,ChanduSent:Monday,December11,201710:43AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>
Subject:
RE:Tier2*LARMeetingHiJoe, Thankyouforaskinggoodquestions.WearecheckingwithSNCtoseeiftheywillhaveanyhandouts.Yes,youarerightthatwedidnotmakeanydecisions.Wewilldecideallthedetailsbeforethemeetinghopefullywithinnextcoupleofdays.Butasofnow,Ithinkyoushouldexpres sanyopinionyouhaveduringthemeeting.IbelieveFrankwantstohaveDivisionlevelpresencesoitmaybeagoodideatomakeyourmanagementawareofyourideas.JenniferandIwilltalkwithFrankandAnnatoseehowtheywanttohandlethemeeting.Thisisapre a pplicationmeetingandanybodyshouldexpresshis/herviewsandletlicenseedecidehowtheywillsubmitthefinalproduct.Wewillletyouknowasthedetailsgetclear.Ideally,thestaffshouldspeakwithonevoicebutIamnotsureifwehavetimetodothatingiventimeframe.Wewilldoourbesttominimizetheconfusionsinthemeeting.AsfarastheEPIDisconcerned,wewillsendittoyou.Itissupposedtobechargedtopre applicationmeetings.
Thanks,ChanduFrom:Williams,JosephSent:Monday,December11,20178:41AMTo:Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>
Subject:
Tier2*LARMeetingChandu and Jordan, I'm not clear on how things are supposed to proceed in the Tier 2* public meeting on Thursday. I'd very much like to avoid a situation like the internal meeting last Wednesday where I was called upon to make an ad hoc presentation, so can you tell me who is going to lead the discussion? Are there any handouts being prepared by DNRL or from SNC? I'm also not clear on messages we intend to convey, as I don't think we reached an agreement on at least some of the issues discussed last Wednesday.
I also need a CAC for my preparations and attendance.
Thanks.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors Office of New Reactors 301.415.1470 9 Williams, Joseph From: Karas, Rebecca Sent: Tuesday, December 12, 2017 11:36 AM To:Jackson, Diane; Monninger, John; Franovich, Mike Cc:Dias, Antonio; Hayes, Michelle; Williams, Joseph; Van Wert, Christopher
Subject:
RE: key messages - FW: Tier 2* LAR Meeting Categories:
Red CategoryI agree with Diane's writeup.
From:Jackson,DianeSent:Monday,December11,201711:34AMTo:Monninger,John<John.Monninger@nrc.gov>;Franovich,Mike<Mike.Franovich@nrc.gov>Cc:Karas,Rebecca<Rebecca.Karas@nrc.gov>;Dias,Antonio<Antonio.Dias@nrc.gov>;Hayes,Michelle<Michelle.Hayes@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
keymessagesFW:Tier2*LARMeetingJohn and Mike From the meeting last week, I agree with Joe below, DNRL does not have a NRC unified message for Vogtle - which we have been advised to do for public meetings.
I have not socialized this with other BCs (given the short time frame and hearing tomorrow), so others, please
chime in.
(suggested) Key messages from DSRA: - NRC looks to be a predictable and consistent regulator
- Making a new process that is unique to one licensee or even one design does not lead to consistency
- Approving a new screening process is a longer term effort than March - As such, we suggest that we first look to apply the approach discussed in the Tier 2* Commission paper, and was applied to KHNP - To come close to meeting the Vogtle requested due date of March, SNC and NRC staff should focus on the current Tier 2* information and determine what is Tier 1 that Vogtle wishes to be Tier 2* - If they want to still pursue the process, it can be/ must be done on a more management timeline. - They should re-formulate their package before submittal.
From:Patel,ChanduSent:Monday,December11,201710:43AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>
Subject:
RE:Tier2*LARMeetingHiJoe, 10 Thankyouforaskinggoodquestions.WearecheckingwithSNCtoseeiftheywillhaveanyhandouts.Yes,youarerightthatwedidnotmakeanydecisions.Wewilldecideallthedetailsbeforethemeetinghopefullywithinnextcoupleofdays.Butasofnow,Ithinkyoushouldexpres sanyopinionyouhaveduringthemeeting.IbelieveFrankwantstohaveDivisionlevelpresencesoitmaybeagoodideatomakeyourmanagementawareofyourideas.JenniferandIwilltalkwithFrankandAnnatoseehowtheywanttohandlethemeeting.Thisisapreapplicat ionme etingandanybodyshouldexpresshis/herviewsandletlicenseedecidehowtheywillsubmitthefinalproduct.Wewillletyouknowasthedetailsgetclear.Ideally,thestaffshouldspeakwithonevoicebutIamnotsureifwehavetimetodothatingiventimeframe.Wewilldoourbesttomini mizeth econfusionsinthemeeting.AsfarastheEPIDisconcerned,wewillsendittoyou.Itissupposedtobechargedtopre applicationmeetings.Thanks,ChanduFrom:Williams,JosephSent:Monday,December11,20178:41AMTo:Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>
Subject:
Tier2*LARMeetingChandu and Jordan, I'm not clear on how things are supposed to proceed in the Tier 2* public meeting on Thursday. I'd very much like to avoid a situation like the internal meeting last Wednesday where I was called upon to make an ad hoc presentation, so can you tell me who is going to lead the discussion? Are there any handouts being prepared by DNRL or from SNC? I'm also not clear on messages we intend to convey, as I don't think we reached an agreement on at least some of the issues discussed last Wednesday.
I also need a CAC for my preparations and attendance.
Thanks.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 11 Williams, Joseph From: Williams, Joseph Sent: Wednesday, December 13, 2017 8:33 AM To:Monninger, John; Franovich, Mike; Segala, John; Karas, Rebecca; Jackson, Diane Cc: Van Wert, Christopher
Subject:
Notes for Public Meeting Discussion of Draft Tier 2* LAR Attachments:
20171214 LAR comments for public meeting.docx Importance:HighThe attached file provides notes I plan to discuss at the public meeting tomorrow morning. I think my views largely align with others in DSRA. One distinction might be that I know some people believe that the best way to proceed would be an amendment assessing existing Tier 2* topics and information with the intent of yielding a much more focused set of topics and scope of italicized information. My view is that a request focused on easily addressed items like screening obvious editorial and consistency issues is the quickest way to get a significant portion of the potential benefit (item 6 in my notes). Regardless, I certainly have no objection to discussing a full range of options and observations, so I hope we have that opportunity tomorrow, though I'm concerned there may not be adequate time to discuss all staff comments in the time allotted for the meeting.
I made these points in an email to the DNRL project staff earlier this week:
This is a potentially precedent-setting proposal that deserves more deliberate consideration. I am unaware of any management discussion to ensure alignment on messages prior to the meeting, though division management attendance is requested. I know that we are not aligned on whether this request involves a policy decision and potential rulemaking implications. We do not have a common position on the relationship between this proposal and NEI's Tier 1 First Principles. The proposed schedule is unrealistic.
Thus far, I haven't received any response from DNRL. In addition to these issues, it's my impression that DNRL management may be overly eager to process and issue this amendment. Overall, I'm concerned that we are setting ourselves up for an unproductive meeting. I don't think we're ready, but it looks like we are going forward, regardless.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
14 Williams, Joseph From: Habib, Donald Sent: Friday, December 22, 2017 11:24 AM To:Jung, Ian; Mitchell, Matthew; Samaddar, Sujit; Lupold, Timothy; Martinez Navedo, Tania; Karas, Rebecca; Dias, Antonio; Jackson, Dian e; Hayes, Michelle; Segala, John; Kavanagh, Kerri; Rivera-Varona, Aida; Cook, Christopher; Devlin-Gill, Stephanie; Harvey, Brad; Dudek, Michael; Erwin, Kenneth; Bu rkhart, Lawrence; Cusumano, Victor Cc:Dixon-Herrity, Jennifer; Patel, Chandu; Van Wert, Christopher; Williams, Joseph; Akstulewicz, Frank; Bradford, Anna; Lee, Samuel; McCoppin, Michael; Colaccino, Joseph
Subject:
Corrected: Acceptance Review - Vogtle Units 3 and 4, License Amendment and Exemption Request LAR 17-037: Changes to Tier 2* Departure Evaluation Process Attachments:Vogtle LAR 17-037 Initial Submittal - Changes to Tier 2STAR Departure Evaluation
Process ML17355A416.pdf Follow Up Flag:Follow up Due By: Tuesday, January 09, 2018 8:00 AM Flag Status:
CompletedDate corrected on this version.
From:Habib,DonaldSent:Friday,December22,201711:09AMTo:Jung,Ian<Ian.Jung@nrc.gov>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov>;Lupold,Timothy<Timothy.Lupold@nrc.gov>;MartinezNavedo,Tania<Tania.MartinezNavedo@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Dias,Antonio<Antonio.Dias@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>;Hayes,Michelle<Michelle.Hayes@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov>;RiveraVarona,Aida<Aida.Rivera Varona@nrc.gov>;Cook,Christopher<Christopher.Cook@nrc.gov>;Devlin Gill,Stephanie<Stephanie.Devlin Gill@nr c.gov>;Harvey,Brad<Brad.Harvey@nrc.gov>;Dudek,Michael<Michael.Dudek@nrc.gov>;Erwin,Kenneth<Kenneth.Erwin@nrc.gov>;Burkhart,Lawrence(Lawrence.Burkhart@nrc.gov)<Lawrence.Burkhart@nrc.gov>;Cusumano,Victor<Victor.Cusumano@nrc.gov>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;VanWert,Christopher<Christopher.VanWert@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>;Lee,Samuel<Samuel.Lee@nrc.gov>;McCoppin,Michael<Michael.McCoppin@nrc.gov>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov>
Subject:
AcceptanceReviewVogtleUnits3and4,Li censeAmendmentandExemptionRequestLAR17037:ChangestoTier2*DepartureEvaluationProcessBranch Chiefs -
Please conduct an acceptance review of Vogtle Units 3 and 4, License Amendment and Exemption Request LAR 17-037: Changes to Tier 2* Departure Evaluation Process (attached).
SNC has requested approval of this LAR by May 15, 2018.
For this activity, please use EPID L-2017-LLA-0421, Vogtle LAR 17-037 Changes to Tier 2* Departure Evaluation Process
For the acceptance review, please provide the following information, as scheduled (note these questions are slightly different from the usual ones).
16 Williams, Joseph From: Segala, John Sent: Monday, January 08, 2018 7:44 AM To: Williams, Joseph
Subject:
FW: Vogtle Tier 2* LAR From:Monninger,JohnSent:Tuesday,January02,201811:21AMTo:Bradford,Anna<Anna.Bradford@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>
Subject:
RE:VogtleTier2*LARYes, very true. It is our responsibility for any policy implications. With that said, it may be in their best interest to try to convince us why it is not a policy matter so that it does not impact their schedule.
From:Bradford,AnnaSent:Tuesday,January02,201811:06AMTo:Monninger,John<John.Monninger@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
RE:VogtleTier2*LARI agree with your thought that policy issues would be a schedule problem, not an acceptance problem. My other thought is that it's not SNC's problem if there's a larger policy issue generic to all other COLs, so they have no reason to address it in their LAR, nor should they. That's the NRC's issue to address, not SNC's.
Anna H. Bradford Deputy Director Division of New Reactor Licensing U.S. Nuclear Regulatory Commission
301-415-1560 From:Monninger,JohnSent:Tuesday,January02,201811:00AMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
RE:VogtleTier2*LAROk. Thanks.
Given that the issues were raised at the meeting, my thought is that SNC would consider and appropriately modify the LAR to discuss any policy implications. If there are policy implications, they do not, in and of themselves, provide a basis to no accept the LAR. I believe we can still accept the LAR and subsequently engage the Commission on any policy implications. A review of the NRR acceptance review procedure should be done to confirm this. I assume we follow the NRR LAR acceptance review procedure. The potential impact would be on schedule and not necessarily the acceptance review. If there are policy implications requiring Commission engagement, the schedule will be protracted. Please let me know if this matches your understanding. Thanks.
17 From:Bradford,AnnaSent:Tuesday,January02,201810:49AMTo:Monninger,John<John.Monninger@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
RE:VogtleTier2*LARJoe raised all of his issues during the pre-app meeting with Southern.
Anna H. Bradford Deputy Director Division of New Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1560
From:Monninger,JohnSent:Tuesday,January02,201810:40AMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
FW:VogtleTier2*LARAnna, This morning you mentioned the Tier 2* LAR, which we have in-house for the acceptance review. Please see the comment below from Joe Williams. I did not attend the public meeting, so I don't know whether the potential policy implications of the LAR were discussed during the meeting. I do know that Joe raised these issues prior to the meeting within NRO; however, I'm not sure whether they were transmitted at the meeting to SNC.
- Thanks, John From:Williams,JosephSent:Thursday,December21,20171:59PMTo:Segala,John<John.Segala@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>Cc:Jackson,Diane<Diane.Jackson@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>
Subject:
VogtleTier2*LARDon Habib told me that SNC will be submitting their Tier 2* LAR tomorrow, and said he plans to ask me to contribute to the acceptance review.
I strongly believe their proposal is a policy issue, and is generic to all AP1000 COLs and possible all other COLs, as well. I would like to know immediately if DNRL plans to proceed without consideration of those issues.
Thanks.
Joe 18 Williams, Joseph From: Williams, Joseph Sent: Tuesday, January 09, 2018 11:26 AM To:Monninger, John; Segala, John Cc: Jackson, Diane; Karas, Rebecca
Subject:
Vogtle Tier 2* Amendment Request Acceptance Review Attachments:
Corrected: Acceptance Review - Vogtle Units 3 and 4, License Amendment and Exemption Request LAR 17-037: Changes to Tier 2* Departure Evaluation Process In the attached email, DNRL has requested that NRO staff conduct an acceptance review of a license amendment and exemption regarding Tier 2* information for the Vogtle COLs. This message provides my initial feedback, which DNRL requested be provided by January 11. Pending your feedback, I intend to provide the input below to DNRL by that date.
I strongly believe that the proposed LAR represents a policy issue requiring a Commission decision before the LAR review can proceed. I cannot concur to approve the proposal, and will not recommend concurrence by others, unless the policy issues are properly vetted and addressed.
The structure of design certification rules, including Tier 2*, was the subject of Commission decisions as the Part 52 process was developed in the early 1990s, as documented in several Commission papers and associated SRMs. The proposed amendment and exemption affect structural and administrative processes where the Commission has provided specific direction, including change controls on Tier 1, Tier 2*, and Tier 2 information. The proposal is distinct from amendments and exemptions regarding the technical adequacy license-specific implementation of the design where the staff and licensee function within those approved structural and administrative processes. In addition, the proposal set a precedent affecting not just this individual licensee and AP1000, but also the fundamental structure of all design certification rules and other COL licenses. Therefore, the generic implications of the proposal must be considered before proceeding. Further, the generic nature of the precedent arguably circumvents the rulemaking process; the amendment is not subject to the same requirement s for public engagement and comment as the rulemaking process. Additional issues may be identified in the course of developing policy recommendations. Accordingly, I do not believe that the NRC staff has a sufficient basis to conduct the review until after the policy issue is fully articulated via a Commission paper describing options, and an SRM provided.
DNRL has requested feedback on the schedule and resources to complete the review. However, the review schedule is dependent on resolution of the policy issue. While a resource estimate might be provided, any resource estimate provided now must be re-evaluated after an SRM is issued. Resources expended to develop a Commission paper addressing the generic policy issue should not be billed to the licensee.
DNRL requested feedback by January 11 on whether a branc h intends to participate in the review. Given ARPB's responsibility for development of SECY-17-0075 and cognizance of Tier 2* issues, I believe ARPB should participate.
There are other challenges associated with this proposal, aside from the policy issue. Those challenges can be addressed in the course of reviewing the proposed amendment and exemption once a Commission decision is obtained. I will provide feedback to DNRL on those topics as part of my review.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors Office of New Reactors 19301.415.1470 20 Williams, Joseph From: Williams, Joseph Sent: Wednesday, January 10, 2018 7:20 AM To:Monninger, John; Segala, John Cc: Jackson, Diane; Karas, Rebecca; Van Wert, Christopher
Subject:
Additional Thoughts Regard ing Vogtle Tier 2* LAR Attachments:
Vogtle Tier 2* Amendment Request Acceptance ReviewI have thought further about the need for a Commission decision regarding implications of the Vogtle Tier 2* LAR request, and have realized that the Commission would expect a paper to describe what the staff thinks a revised Tier 2* change process would look like. Therefore, the LAR review needs to proceed in parallel with development of a paper, not in series as I originally thought. I still believe that the amendment and exemption cannot be granted until after a Commission decision.
I've heard a rumor about an internal meeting to discuss the LAR sometime next week. Do you know anything about it? I haven't been invited (at least not yet).
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 21 Williams, Joseph From: Williams, Joseph Sent: Wednesday, January 10, 2018 3:39 PM To:Akstulewicz, Frank; Bradford, Anna; Dixon-Herrity, Jennifer; Habib, Donald; Patel, Chandu; Hoellman, Jordan Cc:McGinty, Tim; Monninger, John; Taylor, Robert; Caldwell, Robert; Campbell, Andy; Carpenter, Cynthia; Krohn, Paul; Segala , John; Karas, Rebecca; Jackson, Diane
Subject:
Acceptance Review for LAR 17-037: Changes to Tier 2* Departure Evaluation Process Categories:
Red CategoryThis message responds to Don Habib's December 22, 2017 email regarding the acceptance review for Vogtle LAR 17-037 which proposes changes to the Tier 2* departure evaluation process.
I believe that LAR 17-037 raises policy issues requiring a Commission decision before the LAR review can be completed. I cannot concur to approve the proposal, and will not recommend concurrence by others, unless the policy issues are thoroughly vetted and addressed.
The structure of design certification rules, including the Tier 1, Tier 2, and Tier 2* designations and associated change control processes, was the subject of Commission decisions as the Part 52 process was first being implemented in the early 1990s, as documented in several Commission papers and associated SRMs. The LAR 17-037 proposal is distinct from amendments and exemptions regarding the technical adequacy license-specific implementation of the AP1000 design where the staff and licensee function within those Commission-approved processes. In this case, the proposed amendment and exemption request changes to processes explicitly approved by the Commission. Therefore, the requested changes should not be made until the staff has obtained Commission permission to
deviate from that previous approval.
In addition, the proposal sets a precedent for all other design certification rules and COL licenses. Therefore, the generic implications of the proposal must be considered before the requested amendment and exemption can be granted. It is reasonable to expect that the Commission would be interested in proposals with such
broad applicability.
The generic nature of the precedent also arguably bypasses the rulemaking process. While this specific proposal applies only to the Vogtle COLs, there is no obvious reason why the proposed process would not also apply to any other COL referencing an existing design certification. Therefore, LAR 17-037 appears to establish a precedent equivalent to rulemaking that is applicable to any current COL, and any future COL referencing an existing design certification. However, the LAR 17-037 review is not subject to the same requirements for public engagement and comment as the rulemaking process, and so circumvents that process. This issue should be discussed with OGC to determine if there are legal impediments to proceeding with the review.
As a minimum, a Commission paper must address the issues described above. Additional issues may be identified in the course of developing policy recommendations. I believe the Commission would expect a pape r to describe what the staff thinks a revised Tier 2* change process would look like. Therefore, the LAR review needs to proceed in parallel with development of a paper. However, the amendment and exemption cannot be granted until after receipt of an SRM.
I look forward to discussing these issues at the program meeting next Tuesday afternoon.
Joe Williams
Senior Project Manager 22Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
23 Williams, Joseph From: Williams, Joseph Sent: Wednesday, January 17, 2018 7:34 AM To: Segala, John
Subject:
RE: Question: NRO Schedule Milestones for Vogtle LAR 17-037 Some things that come to mind: 1. Branch chiefs and staff have not yet been clear guidance on standards to be applied to the review. Specifically, any criteria used to screen out Tier 2* changes from requiring prior NRC approval must clearly demonstrate the change does not affect Tier 1-equivalent information (i.e., Tier 2* that meets the intent of the designation). Communicating that expectation is a prerequisite for providing schedule and resource estimates. Otherwise, people don't know what they are buying into. 2. The schedule milestones DNRL proposes are overly aggressive. For example, an RAI milestone should not be established until the standard for the review is defined, including management buy-in. 3. It is a bad idea to provide a schedule in the acceptance letter assuming a Commission paper will not be written. I personally think that decision should be made before the letter is issued. 4. Joe Colaccino's branch should be involved, given the effect this topic has on various bits of guidance (e.g., NEI First Principles, SRP, 50.59-like reviews, etc.). Traditionally, organizations like his have had active roles in similar topics, such as when 50.59 was revised in the late 1990s. 5. I think the proposed criteria are inadequate, as they are vague, somewhat redundant to 50.59, and (perhaps most importantly) do not clearly determine Tier 1 equivalence (plus, they aren't anything like the NEI First Principles). Given those considerations, I think we must assume at least 2 rounds of RAIs: one set to identify shortcomings in the initial proposal and a second set for clarifications and adjustments based on an improved set of criteria.
These are the first things that I've come up with. I'll let you know if I come up with anything else.
Joe From:Segala,JohnSent:Tuesday,January16,20185:25PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
Fwd:Question:NROScheduleMilestonesforVogtleLAR17 037Thoughts?
Original Message -------- From: "Habib, Donald" <
Donald.Habib@nrc.gov
> Date: Tue, January 16, 2018 5:08 PM -0500
To: "Jung, Ian" <
Ian.Jung@nrc.gov>, "Mitchell, Matthew" <
Matthew.Mitchell@nrc.gov>, "Lupold, Timothy" <Timothy.Lupold@nrc.gov
>, "Samaddar, Sujit" <Sujit.Samaddar@nrc.gov
>, "Rivera-Varona, Aida" <Aida.Rivera-Varona@nrc.gov>, "Segala, John" <
John.Segala@nrc.gov>, "Jackson, Diane" <Diane.Jackson@nrc.gov
>, "Karas, Rebecca" <
Rebecca.Karas@nrc.gov
> CC: "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov
>, "Bradford, Anna" <Anna.Bradford@nrc.gov
>, "Akstulewicz, Frank" <Frank.Akstulewicz@nrc.gov>, "Patel, Chandu" <Chandu.Patel@nrc.gov
>, "Carpenter, Cynthia" <
Cynthia.Carpenter@nrc.gov
>, "Caldwell, Robert" <Robert.Caldwell@nrc.gov
>, "Monninger, John" <
John.Monninger@nrc.gov
>
Subject:
Question: NRO Schedule Milestones for Vogtle LAR 17-037 24To: Branch Chiefs Reviewing LAR-17-037 Ian Jung (ICE)Matthew Mitchell (MCB)Tim Lupold (MEB)Sujit Samaddar (SEB)Aida Rivera-Varona (HOIB)John Segala (ARPB)Diane Jackson (SCVB)Rebecca Karas (SRSB) To develop a review schedule for the LAR, I need your input on key milestones by COB Friday, 1/19
- Assumptions The LAR will be accepted on 1/21 While the decision to prepare a SECY paper is still pending, assume that SECY paper preparation would not affect the SER schedule (we will make a uniform assumption (e.g., +3 months, +6 months) to account for a SECY paper. Please provide any other key assumptions support your schedule (e.g., 2 nd RAI)o [ ]o [ ]o [ ] MilestoneYour Proposed DateDate Tech Branch provides RAIs to
DNRL (DNRL Proposes 2/23)[ ]Date Tech Branch provides SE
input (if any) to DNRL (DNRL Proposes 5/4)[ ] Please contact me if you have any questions. ThanksDon Don HabibProject Manager NRO/DNRL, Licensing Branch 4O-8D13 301-415-1035 25 Williams, Joseph From: Williams, Joseph Sent: Wednesday, January 17, 2018 9:08 AM To:
Subject:
Vogtle Tier 2* Amendment Attachments:
Acceptance Review for LAR 17-037: Changes to Tier 2* Departure Evaluation Process; Notes for Public Meeting Discussion of Draf t Tier 2* LAR; Initial Comments on DRAFT SNC LAR-17-037 Changes to Tier 2* Departure Evaluation Process for 12/14/2017 public meeting; RE: Southern LAR rela ted to tier 2* implementation - OUO For your information, here are several emails I've written over the past few months regarding the Vogtle Tier 2* amendment request. I'm interested in any thoughts you can offer.
Thanks. Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 26 Williams, Joseph From: Williams, Joseph Sent: Wednesday, January 17, 2018 10:03 AM To: Segala, John; Jackson, Diane; Karas, Rebecca
Subject:
Proposed Feedback to DNRL Regarding Vo gtle Tier 2* Amendment Schedule MilestonesHere are some thoughts regarding feedback to be provided in response to the email Don Habib sent out after the program meeting yesterday requesting schedule milestone feedback. I think it would be beneficial if these thoughts are shared as a DSRA position, which hopefully would make DNRL more likely to address the
issues.
- 1. A decision on engaging the Commission on policy issues is needed before the acceptance letter is issued. This issue was identified prior to the pre-submittal meeting last month, so it's hard to say we haven't had time to answer the question before issuing the letter. It is a bad idea to provide a schedule in the acceptance letter assuming a Commission paper won't be written, especially if we believe that assumption isn't valid. We aren't doing the licensee any favors by not giving them the full story. 2. Branch chiefs and staff have not yet been clear guidance on standards to be applied to the review. Specifically, any criteria used to screen out Tier 2* changes from requiring prior NRC approval must clearly demonstrate the change does not affect Tier 1-equivalent information (i.e., Tier 2* that meets the intent of the designation). This approach would be consistent with SECY-17-0075. Communicating that expectation should be a prerequisite for providing schedule and resource estimates. Otherwise, people don't know what they are buying into.
- 3. We should assume multiple rounds of RAIs. The proposed criteria are inadequate, as they are vague, somewhat redundant to 50.59, and (probably most importantly) do not clearly determine Tier 1 equivalence (plus, they aren't anything like the NEI First Principles). Given those considerations, there will be at least 2 rounds of RAIs: one set to identify shortcomings in the initial proposal and a second set for clarifications and adjustments based on an improved set of criteria. It is likely that multiple iterations will be required.
- 4. Joe Colaccino's branch should be involved, given the effect this topic has on various bits of guidance (e.g., NEI First Principles, SRP, 50.59-like re views, etc.). Traditionally, organizations like his have had active roles in similar topics, such as when 50.59 was revised in the late 1990s.
- 5. We should insist on at least seeing the letter before it goes out the door. Asking to concur isn't a bad idea. That may not be their typical approach, but this isn't a typical LAR, either. Items 1 and 2, in particular, must be addressed before meaningful schedule feedback can be provided.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 27 Williams, Joseph From: Habib, Donald Sent: Thursday, January 18, 2018 1:38 PM To: Williams, Joseph Cc: Segala, John
Subject:
Acceptance Letter (for Vogtle LA R on Tier 2* Departure Process)
Attachments:
Acceptance Letter (003).docxJoe -
Attached is an early version of the letter. Can you please look at the language for policy issues? Is it acceptable, even if it is less than what you think is ideal?
Please give me a markup edit if you think one is needed.
Thanks Don 28 Williams, Joseph From: Habib, Donald Sent: Monday, January 22, 2018 9:29 AM To: Williams, Joseph Cc: Segala, John; Karas, Rebecca; Jackson, Diane; Dixon-Herrity, Jennifer; Bradford, Anna
Subject:
RE: Acceptance Letter (for Vogtle LAR on Tier 2* Departure Process)
Attachments:
Acceptance Letter wSEB-SRSB inputs.docx Joe -
Attached is the current draft of the acceptance letter. We are trying to get the letter completed today, so please resolve get any input from your management today.
As we discussed, the letter only accepts the LAR for review, and that is all it needs to do.
In this case, however, because this LAR addresses process rather than technical issues, the acceptance letter differs from the template for acceptance review letters:
It mentions two areas of concern (critical sect ions and fuels) identified by the staff during the acceptance review. It indicates that the LAR could involve policy questions. It does not provide a date for completion.
Please provide me your input today so that the letter can be issued.
Thanks Don From:Williams,JosephSent:Thursday,January18,20182:21PMTo:Habib,Donald<Donald.Habib@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Don, I'll provide feedback on the policy text after I have a chance to talk to my management. I'm out of the office tomorrow, so it may be early next week.
Separately, I'm curious about the text at the end of the second paragraph regarding critical sections. If this letter is supposed to convey issues of this sort, I have comments that I can offer up, as well. At the public meeting, I discussed how the proposed criteria do not clear ly discriminate between Tier 2* information that is Tier 1-equivalent (i.e., should not be changed without prior NRC approval) and information designated as Tier 2* that is less significant (i.e., perhaps can be changed without NRC approval). This is a significant shortcoming in my view which is at least as significant as the critical sections issue. If the letter is going to address specific shortcomings in the application, I have a lot of input to offer, and I'm sure others would, too. As written, SNC could be led to believe they've made a good start, which I don't think is accurate.
Joe
29From:Habib,DonaldSent:Thursday,January18,20181:38PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe -
Attached is an early version of the letter. Can you please look at the language for policy issues? Is it acceptable, even if it is less than what you think is ideal?
Please give me a markup edit if you think one is needed.
Thanks Don 30 Williams, Joseph From: Williams, Joseph Sent: Monday, January 22, 2018 12:46 PM To: Habib, Donald Cc: Segala, John; Karas, Rebecca; Jackson, Diane; Dixon-Herrity, Jennifer; Bradford, Anna; Monninger, John; Hayes, Barbara
Subject:
RE: Acceptance Letter (for Vogtle LAR on Tier 2* Departure Process)
Attachments:
Acceptance Letter wSEB-SRS B inputs JFW comments.docx Don, Attached is a markup of the acceptance letter. I've reviewed the changes with John Monninger, so the changes reflect DSRA's position.
The markup provides additional text regarding the shortcomings of the initial proposal. The additions note how
the proposal does not clearly differentiate between Tier 2* information that has significance equivalent to Tier 1 and other less significant information. The new text also notes the relationship between this activity and the NEI Tier 1 "first principles" effort. These process issues are fundamental to the proposal, cross-cutting to all Tier 2* content, and are at least as significant as the critical sections and fuel issues.
The markup also provides a comment on the paragraph just ahead of your contact information. As written, it's a bit unclear, especially since no schedule is being provided, as discussed in the comment balloon, so it needs to be revised.
Please let me know what revisions are made to address these comments before the letter is signed.
Thanks.
Joe From:Habib,DonaldSent:Monday,January22,20189:29AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe -
Attached is the current draft of the acceptance letter. We are trying to get the letter completed today, so please resolve get any input from your management today.
As we discussed, the letter only accepts the LAR for review, and that is all it needs to do.
In this case, however, because this LAR addresses process rather than technical issues, the acceptance letter differs from the template for acceptance review letters:
It mentions two areas of concern (critical sect ions and fuels) identified by the staff during the acceptance review. It indicates that the LAR could involve policy questions.
31 It does not provide a date for completion.
Please provide me your input today so that the letter can be issued.
Thanks Don From:Williams,JosephSent:Thursday,January18,20182:21PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Don, I'll provide feedback on the policy text after I have a chance to talk to my management. I'm out of the office tomorrow, so it may be early next week.
Separately, I'm curious about the text at the end of the second paragraph regarding critical sections. If this letter is supposed to convey issues of this sort, I have comments that I can offer up, as well. At the public meeting, I discussed how the proposed criteria do not clear ly discriminate between Tier 2* information that is Tier 1-equivalent (i.e., should not be changed without prior NRC approval) and information designated as Tier 2* that is less significant (i.e., perhaps can be changed without NRC approval). This is a significant shortcoming in my view which is at least as significant as the critical sections issue. If the letter is going to address specific shortcomings in the application, I have a lot of input to offer, and I'm sure others would, too. As written, SNC could be led to believe they've made a good start, which I don't think is accurate.
Joe From:Habib,DonaldSent:Thursday,January18,20181:38PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe - Attached is an early version of the letter. Can you please look at the language for policy issues? Is it acceptable, even if it is less than what you think is ideal?
Please give me a markup edit if you think one is needed.
Thanks Don 32 Williams, Joseph From: Williams, Joseph Sent: Tuesday, January 23, 2018 6:57 AM To: Jackson, Diane Cc:Segala, John; Ashley, Clinton; Goel, Raj; Chien, Nan
Subject:
RE: final review dates? ACTION - Acceptan ce Review - Vogtle Units 3 and 4, License Amendment and Exemption Request LAR 17-037: Changes to Tier 2* Departure Evaluation Process Diane, For what it's worth, I think that schedule is unrealistic, as DNRL has not yet given guidance to staff regarding the target for their review, and it doesn't reflect the need to consider generic implications of the proposal. To be consistent with what we told the Commission in SECY-17-0075, we need to confirm that the process proposed by SNC clearly differentiates between Tier 2* information that has safety significance equivalent to
Tier 1 which would require prior NRC approval for changes, and any lesser significant information where another change process might be employed. This effort is closely entwined with the NEI Tier 1 "First Principles," and should be addressed in parallel for consistency.
Joe From:Jackson,DianeSent:Monday,January22,20183:48PMTo:Ashley,Clinton<Clinton.Ashley@nrc.gov>;Goel,Raj<Raj.Goel@nrc.gov>;Chien,Nan<Nan.Chien@nrc.gov>Cc:Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
RE:finalreviewdates?ACTIONAcceptanceReviewVogtleUnits3and4,LicenseAmendmentandExemptionRequestLAR17 037:ChangestoTier2*DepartureEvaluationProcessDon called me back. The Acceptance letter will go out without a schedule. He foresees two potential paths for technical branches; 1) direct impacts on your review area. 2) policy / regulatory questions.
This may involve a Commission paper.
For now, the dates for RAIs are 2/23 (1 month); and SE 5/4 (but this may change).
Diane From:Jackson,DianeSent:Monday,January22,20183:36PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Williams,Joseph<Joseph.Williams@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Goel,Raj<Raj.Goel@nrc.gov
>;Chien,Nan<Nan.Chien@nrc.gov
>
Subject:
finalreviewdates?ACTIONAcceptanceReviewVogtleUnits3and4,LicenseAmendmentandExemptionRequestLAR17 037:ChangestoTier2*DepartureEvaluationProcess Hello Don -
Is the schedule still in flux?
36 Williams, Joseph From: Habib, Donald Sent: Tuesday, January 23, 2018 9:02 AM To: Williams, Joseph
Subject:
FW: Acceptance Letter (for Vogtle LAR on Tier 2* Departure Process)
Attachments:
Acceptance Letter(rev).docxJoe - Here is the current version of the letter.
Can you please give me your feedback on the final paragraph about the schedule?
Thanks Don From:Habib,DonaldSent:Tuesday,January23,20188:21AMTo:Bradford,Anna<Anna.Bradford@nrc.gov>
Subject:
FW:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Anna - Attached is the acceptance letter for the Tier 2* LAR. Please give me your feedback.
In this case, because this LAR addresses process rather than technical issues, the acceptance letter differs from the template for acceptance review letters. In particular:
It mentions two areas of concern (critical sect ions and fuels) identified by the staff during the acceptance review. It indicates that the LAR could involve policy questions. It does not provide a date for completion.
Thanks Don
From:Patel,ChanduSent:Monday,January22,20184:38PMTo:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)HiDon, Looksgreat.Thanks,ChanduFrom:Habib,DonaldSent:Monday,January22,20189:30AM 37 To:Patel,Chandu<Chandu.Patel@nrc.gov
>
Subject:
FW:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Chandu -
Sorry I forgot to cc you on this email.
Don From:Habib,DonaldSent:Monday,January22,20189:29AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe -
Attached is the current draft of the acceptance letter. We are trying to get the letter completed today, so please resolve get any input from your management today.
As we discussed, the letter only accepts the LAR for review, and that is all it needs to do.
In this case, however, because this LAR addresses process rather than technical issues, the acceptance letter differs from the template for acceptance review letters:
It mentions two areas of concern (critical sect ions and fuels) identified by the staff during the acceptance review. It indicates that the LAR could involve policy questions. It does not provide a date for completion.
Please provide me your input today so that the letter can be issued.
Thanks Don From:Williams,JosephSent:Thursday,January18,20182:21PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Don, I'll provide feedback on the policy text after I have a chance to talk to my management. I'm out of the office tomorrow, so it may be early next week.
Separately, I'm curious about the text at the end of the second paragraph regarding critical sections. If this letter is supposed to convey issues of this sort, I have comments that I can offer up, as well. At the public meeting, I discussed how the proposed criteria do not clear ly discriminate between Tier 2* information that is Tier 1-equivalent (i.e., should not be changed without prior NRC approval) and information designated as Tier 2* that is less significant (i.e., perhaps can be changed without NRC approval). This is a significant 38shortcoming in my view which is at least as significant as the critical sections issue. If the letter is going to address specific shortcomings in the application, I have a lot of input to offer, and I'm sure others would, too. As written, SNC could be led to believe they've made a good start, which I don't think is accurate.
Joe From:Habib,DonaldSent:Thursday,January18,20181:38PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe -
Attached is an early version of the letter. Can you please look at the language for policy issues? Is it acceptable, even if it is less than what you think is ideal?
Please give me a markup edit if you think one is needed.
Thanks Don 39 Williams, Joseph From: Habib, Donald Sent: Tuesday, January 23, 2018 11:35 AM To:Hayes, Barbara; Williams, Joseph
Subject:
RE: Acceptance Letter (for Vogtle LAR on Tier 2* Departure Process)
Attachments:
LAR Acceptance Letter anna cmmts.docx Barb and Joe -
For the first issue, I reworded the sentence as follows:
Giventhegenericimplicationsoftheseactivities,itisimportantforNRCstafftoensureconsistencybetweentheseactivities.
For the other wording changes, I can pursue it, but it's putting a fine point on the issue. The letter is currently with Frank, and should go out today.
Don From:Hayes,BarbaraSent:Tuesday,January23,201810:46AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Habib,Donald<Donald.Habib@nrc.gov>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Hi Joe, John Segala suggested I drop by to discuss tweaking the wording with you but you were not in. The suggested wording is unclear on who the actor is in terms of alignment with NEI's first principles. I also think that Southern's part in it (weak or non-explicit alignment of their proposed "qualification criteria" with Tier 2* information with safety significance commensurate with Tier 1) might get swamped by the note on NEI. I've suggested some wording in the attached.
This is just a suggestion. Feel free to modify or to give me a call to discuss.
BarbaraHayes(301)415 7442,office:OWFN7 E04NRO/DNRL/LB3/ProjectManager From:Williams,JosephSent:Tuesday,January23,20186:30AMTo:Hayes,Barbara<Barbara.Hayes@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Barb, It should be NRC. Southern is responsible for their licenses. We are responsible for administering licenses for all plants, so the generic aspects are our responsibility.
Joe 40 From:Hayes,BarbaraSent:Monday,January22,20189:44PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe, Thanks for copying me on this. I had let Chandu and Jordan Hoellman know that Frank wanted me to stay cognizant of this LAR so this is very helpful catch-up. I'm curious about the sentence DSRA added which I believe is referring to NEI's first principles efforts that reads "
"Giventhegenericimplicationsoftheseactivities,itisimportanttoensureconsistencybetweentheseactivities." Who is supposed to ensure consistency? Southern?
Barb BarbaraHayes(301)415 7442,office:OWFN7 E04NRO/DNRL/LB3/ProjectManager From:Williams,JosephSent:Monday,January22,201812:46PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Don, Attached is a markup of the acceptance letter. I've reviewed the changes with John Monninger, so the changes reflect DSRA's position.
The markup provides additional text regarding the shortcomings of the initial proposal. The additions note how
the proposal does not clearly differentiate between Tier 2* information that has significance equivalent to Tier 1 and other less significant information. The new text also notes the relationship between this activity and the NEI Tier 1 "first principles" effort. These process issues are fundamental to the proposal, cross-cutting to all Tier 2* content, and are at least as significant as the critical sections and fuel issues.
The markup also provides a comment on the paragraph just ahead of your contact information. As written, it's a bit unclear, especially since no schedule is being provided, as discussed in the comment balloon, so it needs
to be revised.
Please let me know what revisions are made to address these comments before the letter is signed.
Thanks.
Joe From:Habib,DonaldSent:Monday,January22,20189:29AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Bradford,Anna 41<Anna.Bradford@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe -
Attached is the current draft of the acceptance letter. We are trying to get the letter completed today, so please resolve get any input from your management today.
As we discussed, the letter only accepts the LAR for review, and that is all it needs to do.
In this case, however, because this LAR addresses process rather than technical issues, the acceptance letter differs from the template for acceptance review letters:
It mentions two areas of concern (critical sect ions and fuels) identified by the staff during the acceptance review. It indicates that the LAR could involve policy questions. It does not provide a date for completion.
Please provide me your input today so that the letter can be issued.
Thanks Don From:Williams,JosephSent:Thursday,January18,20182:21PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>
Subject:
RE:AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Don, I'll provide feedback on the policy text after I have a chance to talk to my management. I'm out of the office tomorrow, so it may be early next week.
Separately, I'm curious about the text at the end of the second paragraph regarding critical sections. If this letter is supposed to convey issues of this sort, I have comments that I can offer up, as well. At the public meeting, I discussed how the proposed criteria do not clear ly discriminate between Tier 2* information that is Tier 1-equivalent (i.e., should not be changed without prior NRC approval) and information designated as Tier 2* that is less significant (i.e., perhaps can be changed without NRC approval). This is a significant shortcoming in my view which is at least as significant as the critical sections issue. If the letter is going to address specific shortcomings in the application, I have a lot of input to offer, and I'm sure others would, too. As written, SNC could be led to believe they've made a good start, which I don't think is accurate.
Joe From:Habib,DonaldSent:Thursday,January18,20181:38PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
AcceptanceLetter(forVogtleLARonTier2*DepartureProcess)Joe -
42Attached is an early version of the letter. Can you please look at the language for policy issues? Is it acceptable, even if it is less than what you think is ideal?
Please give me a markup edit if you think one is needed.
Thanks Don 43 Williams, Joseph From: Williams, Joseph Sent: Wednesday, January 24, 2018 3:33 PM To: Habib, Donald Cc:Bradford, Anna; Segala, John; Colaccino, Joseph; Hayes, Barbara; Monninger, John
Subject:
RE: Update: Acceptance letter Don, I can live with the proposed revision. I would like to understand how DNRL expects to move forward on these
issues: 1. What is the plan for organizational alignment on the policy issue question? 2. The amendment review needs to be coordinated with LB3 to ensure consistency between the LAR review and the NEI Tier 1 First Principles effort. 3. The expectations for Tier 2* as documented in SECY-17-0075 need to be communicated to staff and branch chiefs engaged in the review to ensure that the proposed process clearly differentiates between Tier 2* that is Tier 1-equivalent and less significant information where prior NRC review of changes may not be necessary.
Thanks.
Joe From:Habib,DonaldSent:Wednesday,January24,20183:09PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
Update:AcceptanceletterJoe - Here are some edits from Anna after she met with Segala.
If possible, let's talk shortly.
Thanks Don YourapplicationreferencesSECY170075,"PlannedImprovementsinDesignCertificationTieredInformationDesignations"(ADAMSaccessionnumberML16196A321),whichdocumentedthat"-Tier2*informationisintendedtohavesubstantialsafetysignificance,commensuratewithinformationdesignatedasTier1."However,thecriteriaandprocessdescribedintheapplicationdonotclearlydifferentiatebetweenTier2*informationwithsafetysignificancecommensuratewithTier1,andanyTier2*informationwhichhaslessersignificance.TheNRCstaffalsonotesongoingengagementwiththeNuclearEnergyInstitutetodescribe"firstprinciples"forTier1information.SECY 17 0075notesthatthiseffortcanbeusefultoidentifytheproperscopeofTier2*information.AsdiscussedattheDecember14,2017presubmittalmeetingforthisamendment,yourapplicationisenvisionedtobeindependentoftheTier1"firstprinciples."Giventhegenericimplicationsoftheseactivities,itisimportantforNRCstafftoensureconsistencybetweentheseactivities.
44 Weexpectthatcertaintopicsinyourapplicationwillrequireadditionaldiscussionatafuturepublicmeeting.Forexample,thecriteriaandprocessdescribedintheapplicationdonotclearlydifferentiatebetweenTier2*informationwithsafetysignificancecommensuratewithTier1,andanyTier2*informationwhichhaslessersignificance.Additionally,theproposedchangeprocessforTier2*itemsrelatedtonuclearfuelintroducescomplexities,giventhattheassociatedfueltopicalreportsalreadyincludewithinthemapprovedchangeprocessesthatremainapplicabletotheseTier2*items.Thestaffwillrequireadditionalinformationregardingtheneedforfurtherchangeprocessesfortheseitems,andanticipatesextensiveeng agementmaybenecessaryforsuchanadditionalchangeprocesstobedevelopedandreconciledwiththeexistingapprovedchangeprocessforthefueltopicalreports.Finally,theproposedprocessdoesnotsufficientlyaddresscriticalsectionsusedtodepictan"essentiallycompletedesign."Weexpectthesetopicswillbediscussedwithyouatafuturepubli cmeeti ng.YouwillbeadvisedofanyfurtherinformationneededtosupporttheNRCstaff'sdetailedtechnicalreviewbyseparatecorrespondence.
Anna H. Bradford Deputy Director Division of New Reactor Licensing U.S. Nuclear Regulatory Commission
301-415-1560 45 Williams, Joseph From: Williams, Joseph Sent: Tuesday, January 30, 2018 2:01 PM To: NRO_DNRL_LB4_Cal Resource Cc:Habib, Donald; Hoellman, Jordan; Patel, Ch andu; Dixon-Herrity, Jennifer; Bradford, Anna; Segala, John; Monninger, John
Subject:
Tentative: FW: Public Meeting with SNC Importance:HighDiscussion of the Tier 2* amendment at this meeting is premature, given that expectations for the review have not yet been discussed with staff. As stated in the acceptance letter, "the criteria and process 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 has lesser significance." To the best of my knowledge, this standard has not been communicated with staff. Application of some other standard would be contrary to the intent of Tier 2* as described in SECY-17-0075, and arguably inconsistent with established Commission policy.
Addressing specific technical issues without clear expectations sets us up for inconsistent treatment of the review by various organizations.
I also note that this is another example of a meeting on this topic being scheduled when I have a significant conflict. I believe the meeting should be rescheduled to another date after expectations have been communicated and all staff involved can participate.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
46 Williams, Joseph From: Habib, Donald Sent: Tuesday, January 30, 2018 3:35 PM To: Williams, Joseph Cc: Hoellman, Jordan; Patel, Chandu; Dixon-Herrity, Jennifer; Bradford, Anna; Segala, John; Monninger, John; Van Wert, Christopher; Karas, Rebecca
Subject:
RE: Public Meeting with SNC (LAR 17-037)Joe -
Thanks for talking to me about this matter.
We'll plan to have the discussion with SNC on Thursday so that we can get a better understanding of SNC's intent on the issues involving fuel.
I agree with your comment about thinking strategically about this LAR. As we discussed, I'll organize an internal meeting to discuss strategy options.
Thanks Don
Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
_____________________________________________ OriginalAppointmentFrom:Williams,JosephSent:Tuesday,January30,20182:01PMTo:NRO_DNRL_LB4_CalResourceCc:Habib,Donald;Hoellman,Jordan;Patel,Chandu;Dixon Herrity,Jennifer;Bradford,Anna;Segala,John;Monninger,John
Subject:
Tentative:FW:PublicMeetingwithSNCWhen:Thursday,February01,20189:00AM 12:00PM(U TC 05:00)EasternTime(U S&Canada).Where:HQOWFN 16D03 27PImportance:HighDiscussion of the Tier 2* amendment at this meeting is premature, given that expectations for the review have not yet been discussed with staff. As stated in the acceptance letter, "the criteria and process 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 has lesser significance." To the best of my knowledge, this standard has not been communicated with staff. Application of some other standard would be contrary to the intent of 47Tier 2* as described in SECY-17-0075, and arguably inconsistent with established Commission policy. Addressing specific technical issues without clear expectations sets us up for inconsistent treatment of the review by various organizations.
I also note that this is another example of a meeting on this topic being scheduled when I have a significant conflict. I believe the meeting should be rescheduled to another date after expectations have been communicated and all staff involved can participate.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
48 Williams, Joseph From: Habib, Donald Sent: Friday, February 02, 2018 9:29 AM To: Williams, Joseph Cc:Dixon-Herrity, Jennifer; Bradford, Anna
Subject:
17-037 Alignment Meeting - Agenda.docx Attachments:
17-037 Alignment Meeting - Agenda.docxJoe -
Can you look at the attached handout for an internal alignment meeting we discussed?
I think you need to add to it more to articulate the challenge confronting us for this LAR. Most of what I put in is background information, rather than real substance.
Here is my invite list for the meeting:
SES for DNRL, DEI, DSRA, DCIP BCs and selected staff for involved 10 branches: ICE, MCB, MEB, SEB, ARPB, SCVB, SRSB, HOIB, LB3, LB4 Additionally, I think part of our review strategy needs to include discussions with SNC to see how flexible they are. Since it looks like approval of this LAR-if it is even approvable-will take too long to be able to help them.
Thanks Don
50 Williams, Joseph From: Bradford, Anna Sent: Tuesday, February 06, 2018 9:00 PM To:Williams, Joseph; Habib, Donald Cc:Dixon-Herrity, Jennifer; Patel, Chandu
Subject:
Re: Planning Meeting LAR 17-037 Tier 2star And it needs to be before we go to the LARM meeting with Vogtle on 2/20.
Anna H. Bradford Deputy Director Division of New Reactor Licensing
U.S. Nuclear Regulatory Commission 401-415-1560 On: 06 February 2018 20:31, "Williams, Joseph" <Joseph.Williams@nrc.gov
> wrote: I agree an hour would be more suitable. The original time was problematic for John Segala, so a different time would be better, regardless.
Joe On: 06 February 2018 09:38, "Bradford, Anna" <
Anna.Bradford@nrc.gov
> wrote: I agree the meeting is needed but I doubt 30 minutes is enough. Can we make it an hour? Please also invite Barbara Hayes because she is working the NEI first principles proposal.
Anna H. Bradford Deputy Director Division of New Reactor Licensing
U.S. Nuclear Regulatory Commission 401-415-1560 On: 06 February 2018 09:35, "Habib, Donald" <
Donald.Habib@nrc.gov
> wrote: Anna - I am working on a POP with Joe Williams. I think there are multiple angles to discuss:
51 We should align on approach to address the question about Tier 1-equivalent information that was in the acceptance letter.
I'm going to need some guidance about how we review/decide the process-aspect of the request.
Joe is also interested in how a decision on the LAR could affect the ongoing NEI first-principles effort that he is
working on.
I had wanted to meet with Joe and within DNRL before advising the branches on what we might need from them, if anything.
Don _____________________________________________From:Bradford,AnnaSent:Tuesday,February06,20188:49AMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>
Subject:
RE:PlanningMeetingLAR17037Tier2star Don, Can you please tell me the purpose of this meeting?
Anna H. Bradford
Deputy Director Division of New Reactor Licensing U.S. Nuclear Regulatory Commission
301-415-1560 OriginalAppointmentFrom:DNRLCALResourceSent:Monday,February05,20183:46PMTo:DNRLCALResourceCc:Akstulewicz,Frank;Bradford,Anna;Habib,Donald;Williams,Joseph;Dixon Herrity,Jennifer;Weaver,Tonna;Patel,Chandu
Subject:
FW:PlanningMeetingLAR17037Tier2starWhen:Thursday,February08,201810:30AM 11:00AM(UTC 05:00)EasternTime(US&Canada).Where:HQOWFN 07B02 12p OriginalAppointmentFrom:Kuhn,TiaOnBehalfOfDNRLCALResourceSent:Monday,February05,20183:28PM 52 To:DNRLCALResource
Subject:
PlanningMeetingLAR17 037Tier2starWhen:Thursday,February08,201810:30AM 11:00AM(UTC 05:00)EasternTime(US&Canada).Where:HQOWFN 07B02 12p 53 Williams, Joseph From: Williams, Joseph Sent: Monday, February 12, 2018 10:54 AM To: Segala, John
Subject:
POP for Tier 2* Discussion with DNRL Attachments:
201802XX internal alignment with DNRL.docx John, Here's a POP I wrote to guide the discussion with DNRL regarding the Tier 2* LAR.
I've had a couple people call or stop by my office to talk about the LAR, which reinforces the need for this discussion in my mind.
Joe 54 Williams, Joseph From: Sent: Friday, February 16, 2018 11:04 AM To: Williams, Joseph;
Subject:
For Comment - Proposed LAR 17-037 Ques tions for Internal Alignment.docx Attachments:
For Comment - Proposed LAR 17-037 Ques tions for Internal Alignment.docx Attached is my first cut at questions we should pose Tech Staff regarding LAR 17-037.
Please take a look and give me your feedback.
Thanks 55 Williams, Joseph From: Sent: Friday, February 16, 2018 11:31 AM To: Cc: Williams, Joseph;
Subject:
RE: For Comment - Proposed LAR 17-037 Qu estions for Internal Alignment.docx Attachments:For Comment - Proposed LAR 17-037 Questions for Internal Alignment bdh comments.docxPleaseseeattachedwithcommentsforyourconsideration.
Havealovelyweekend.From:Sent:Friday,February16,201811:04AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>;
Subject:
ForCommentProposedLAR17 037QuestionsforInternalAlignment.docx Attached is my first cut at questions we should pose Tech Staff regarding LAR 17-037.
Please take a look and give me your feedback.
Thanks
59 Attached is my first cut at questions we should pose Tech Staff regarding LAR 17-037.
Please take a look and give me your feedback.
Thanks
61
Subject:
RE:ForCommentProposedLAR17 037QuestionsforInternalAlignment.docxPleaseseeattachedwithcommentsforyourconsideration.
Havealovelyweekend.From:Sent:Friday,February16,201811:04AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;
Subject:
ForCommentProposedLAR17 037QuestionsforIntern alAlignment.docx Attached is my first cut at questions we should poseTech Staff regarding LAR 17-037.
Please take a look and give me your feedback.
Thanks
63 Williams, Joseph From: Williams, Joseph Sent: Thursday, February 22, 2018 8:11 AM To: Habib, Donald
Subject:
RE: For Review: Proposed Questions for Te ch Staff Regarding LAR 17-037, Tier 2*
Departure ProcessThe only reason to wait that comes to mind is uncertainty regarding the outcome of the I doubt they'll say it can't be done at all, but if they did, that certainly affects what the staff is told. Less dramatic outcomes could still affect the staff, though, such as a determination that we need to get Commission permission before we proceed, or if we proceed in paralle l with informing the Commission. It would be worth telling the staff that their future decisions would be vetted at that level.
From:Habib,DonaldSent:Thursday,February22,20188:00AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Hayes,Barbara<Barbara.Hayes@nrc.gov>Cc:Patel,Chandu<Chandu.Patel@nrc.gov>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov>;Segala,John<John.Segala@nrc.gov>
Subject:
RE:ForReview:ProposedQuestionsforTechStaffRegardingLAR17037,Tier2*DepartureProcess I was thinking I'd get this out to the tech staff shortly, today or tomorrow, unless there was a reason to hold off.
I would distribute it to the BCs and assigned staff for the 8 branches that have indicated an involvement in the LAR (MEB, MCB, SEB, ICE, SRSB, SCVB, HOIB, ARPB).
Yes, I was going to cancel the Tuesday meeting.
From:Williams,JosephSent:Thursday,February22,20187:12AMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>Cc:Patel,Chandu<Chandu.Patel@nrc.gov
>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>
Subject:
RE:ForReview:ProposedQuestionsforTechStaffRegardingLAR17037,Tier2*DepartureProcess I'm OK with it. Does this mean the Tuesday meeting is cancelled? When do you plan to provide this guidance to the staff?
Joe From:Bradford,AnnaSent:Wednesday,February21,201810:04PMTo:Habib,Donald<Donald.Habib@nrc.gov
>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>
64 Cc:Patel,Chandu<Chandu.Patel@nrc.gov
>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov
>
Subject:
Re:ForReview:ProposedQuestionsforTechStaffRegardingLAR17037,Tier2*DepartureProcess Looks good to me.
Anna H. Bradford Deputy Director Division of New Reactor Licensing
U.S. Nuclear Regulatory Commission 401-415-1560 On: 21 February 2018 15:47, "Habib, Donald" <
Donald.Habib@nrc.gov
> wrote: DNRL Team -
Below for your review is the latest list of questions for the tech staff. Please reply with any further adjustments, or thoughts.
Thanks Don 1. For the Tier 2* information in your review area, can you distinguish the portion of information that you consider to be Tier 1-equivalent from that which is other Tier 2* information?
- 2. Would the proposal in the LAR, if correctly applied by the licensee, properly protect the information that you believe is Tier 1-equivalent in your review area?
- a. If not, what additional criteria would you suggest to ensure that Tier 1-equivalent information is properly screened?
- 3. Can you envision a case where the process propos ed by the LAR, when correctly applied by the licensee, could lead to an unacceptable outcome in your area?
From:Bradford,AnnaSent:Wednesday,February21,201811:18AMTo:DNRLCALResource<DNRLCAL.Resource@nrc.gov
>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>Cc:Patel,Chandu<Chandu.Patel@nrc.gov
>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov
>
Subject:
Re:ProposedQuestionsforTechStaffRegardingLAR17 037,Tier2*DepartureProcess Don, 65Do we really need to meet on this? Jen and I were talking here at Vogtle and thinking maybe you could just send out the latest version and do it via email rather than waiting till next week? We need to get these questions out sooner rather than later.
Anna H. Bradford Deputy Director Division of New Reactor Licensing
U.S. Nuclear Regulatory Commission 401-415-1560 On: 21 February 2018 11:02, "DNRLCAL Resource" <
DNRLCAL.Resource@nrc.gov
> wrote:
Subject:
Proposed Questions for Tech Staff Regarding LAR 17-037, Tier 2* Departure Process Meeting Requested By: Don Habib Scheduled By: Christine Richie
66 Williams, Joseph From: Williams, Joseph Sent: Thursday, February 22, 2018 9:10 AM To: Habib, Donald
Subject:
Re: For Review: Proposed Questions for Te ch Staff Regarding LAR 17-037, Tier 2*
Departure Process You can say a is pending, outlining those questions, and say you'll provide an update, if needed. On: 22 February 2018 08:47, "Habib, Donald" <
Donald.Habib@nrc.gov
> wrote: However, I don't want to cycle the tech staff on what we ask them to do. If I send it out to the tech staff before I'd want to make sure the saving of a few days is worth the risk of cycling the tech staff.
From:Williams,JosephSent:Thursday,February22,20188:11AMTo:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
RE:ForReview:ProposedQuestionsforTechStaffRegardingLAR17037,Tier2*DepartureProcess The only reason to wait that comes to mind is uncertainty regarding the outcome of the I doubt they'll say it can't be done at all, but if they did, that certainly affects what the staff is told. Less dramatic outcomes could still affect the staff, though, such as a determination that we need to get Commission permission before we proceed, or if we proceed in paralle l with informing the Commission. It would be worth telling the staff that their future decisions would be vetted at that level.
From:Habib,DonaldSent:Thursday,February22,20188:00AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>Cc:Patel,Chandu<Chandu.Patel@nrc.gov
>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>
Subject:
RE:ForReview:ProposedQuestionsforTechStaffRegardingLAR17037,Tier2*DepartureProcess I was thinking I'd get this out to the tech staff shortly, today or tomorrow, unless there was a reason to hold off.
I would distribute it to the BCs and assigned staff for the 8 branches that have indicated an involvement in the LAR (MEB, MCB, SEB, ICE, SRSB, SCVB, HOIB, ARPB).
Yes, I was going to cancel the Tuesday meeting.
From:Williams,JosephSent:Thursday,February22,20187:12AMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Akstulewicz,Frank 67<Frank.Akstulewicz@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>Cc:Patel,Chandu<Chandu.Patel@nrc.gov
>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>
Subject:
RE:ForReview:ProposedQuestionsforTechStaffRegardingLAR17037,Tier2*DepartureProcess I'm OK with it. Does this mean the Tuesday meeting is cancelled? When do you plan to provide this guidance to the staff?
Joe From:Bradford,AnnaSent:Wednesday,February21,201810:04PMTo:Habib,Donald<Donald.Habib@nrc.gov
>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>Cc:Patel,Chandu<Chandu.Patel@nrc.gov
>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov
>
Subject:
Re:ForReview:ProposedQuestionsforTechStaffRegardingLAR17037,Tier2*DepartureProcess Looks good to me.
Anna H. Bradford Deputy Director Division of New Reactor Licensing
U.S. Nuclear Regulatory Commission 401-415-1560 On: 21 February 2018 15:47, "Habib, Donald" <
Donald.Habib@nrc.gov
> wrote: DNRL Team -
Below for your review is the latest list of questions for the tech staff. Please reply with any further adjustments, or thoughts.
Thanks Don 1. For the Tier 2* information in your review area, can you distinguish the portion of information that you consider to be Tier 1-equivalent from that which is other Tier 2* information?
- 2. Would the proposal in the LAR, if correctly applied by the licensee, properly protect the information that you believe is Tier 1-equivalent in your review area?
- a. If not, what additional criteria would you suggest to ensure that Tier 1-equivalent information is properly screened?
68 3. Can you envision a case where the process propos ed by the LAR, when correctly applied by the licensee, could lead to an unacceptable outcome in your area?
From:Bradford,AnnaSent:Wednesday,February21,201811:18AMTo:DNRLCALResource<DNRLCAL.Resource@nrc.gov
>;Akstulewicz,Frank<Frank.Akstulewicz@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Hayes,Barbara<Barbara.Hayes@nrc.gov
>Cc:Patel,Chandu<Chandu.Patel@nrc.gov
>;Colaccino,Joseph<Joseph.Colaccino@nrc.gov
>
Subject:
Re:ProposedQuestionsforTechStaffRegardingLAR17 037,Tier2*DepartureProcess Don, Do we really need to meet on this? Jen and I were talking here at Vogtle and thinking maybe you could just send out the latest version and do it via email rather than waiting till next week? We need to get these questions out sooner rather than later.
Anna H. Bradford Deputy Director Division of New Reactor Licensing
U.S. Nuclear Regulatory Commission 401-415-1560 On: 21 February 2018 11:02, "DNRLCAL Resource" <
DNRLCAL.Resource@nrc.gov
> wrote:
Subject:
Proposed Questions for Tech Staff Regarding LAR 17-037, Tier 2* Departure Process Meeting Requested By: Don Habib Scheduled By: Christine Richie
69 Williams, Joseph From: Habib, Donald Sent: Thursday, February 22, 2018 4:28 PM To:Jung, Ian; Zhao, Jack; Mitchell, Matthew; Honcharik, John; Lupold, Timothy; Hansing, Nicholas; Scarbrough, Thomas; Samaddar, Sujit; Jain, Bhagwat; Park, Sunwoo; Patel, Pravin; Cranston, Gregory; Ashley, Clinton; Goel, Raj; Chien, Nan; Karas, Rebecca; Van
Wert, Christopher; Kent, Lauren; Green, Brian Cc:Segala, John; Williams, Joseph; Hayes, Barbara; Colaccino, Joseph; Patel, Chandu; Dixon-Herrity, Jennifer; Bradford, Anna; Akstulewicz, Frank
Subject:
Action: Questions to Technical Staff (Vogtle LAR 17-037)
Importance:High Follow Up Flag:Follow up Due By: Monday, February 26, 2018 1:00 PM Flag Status:
Completed Categories:
Red Category LAR17 037ReviewTeam-(ICE, MCB, MEB, SEB, SCVB, SRSB, HOIB) Pleasereviewandreplytothefollowingquestionsregardingyourbranch'sreviewareathatwouldbesubjecttotheproposedscreeningprocessforTier2*materialinSNC'sLAR17 037.ToapprovetheLAR,theaffectedtechnicalbrancheswillneedtosupportaconclusionthatthechangesproposedintheLA Rareacceptable.
PleaseplantoreplybyMarch9.Contactmeifyouhaveanyquestionsorneedadditionaltime. Thanks Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 1. For the Tier 2* information in your branch's review area, can you distinguish the portion of information that you consider to be Tier 1 equivalent from that which is other Tier 2* information?
- 2. For your branch's review area, do you agree with the analysis provided in Enclosure 5 of the SNC submittal (Tier 2* Matters Analysis Summary)? Why or why not? If not, what are your concerns?
- 3. Would the proposal in the LAR, if correctly applied by the licensee, properly protect the information that you believe is Tier 1 equivalent in your review area? Why or why not? If not, what additional criteria would you suggest to ensure that Tier 1 equivalent information in your review area is properly screened?
704. Can you envision a case where the process proposed by the LAR, when correctly applied by the licensee, could lead to an unacceptable outcome in your area?
71 Williams, Joseph From: Habib, Donald Sent: Monday, February 26, 2018 9:31 AM To: Williams, Joseph
Subject:
For Review: Brief for NRO-FO - LAR 17-037.docx Attachments:
Brief for NRO-FO - LAR 17-037.docx Follow Up Flag:Follow up Due By: Monday, February 26, 2018 1:00 PM Flag Status:
Completed Joe -
Can you please take a look at this 1-pager I am preparing for Fred Brown? I'd like to get your feedback at this time.
Thanks Don 72 Williams, Joseph From: Williams, Joseph Sent: Monday, February 26, 2018 3:24 PM To: Habib, Donald
Subject:
Brief for NRO-FO - LAR 17-037 JFW comments.docx Attachments:
Brief for NRO-FO - LAR 17-037 JFW comments.docx Don, Here are some comments on the briefing sheet for your consideration. Let me know if you have questions.
Joe
74OriginalAppointmentFrom:DNRLCALResourceSent:Wednesday,February21,201810:45AMTo:DNRLCALResource;Akstulewicz,Frank;Bradford,Anna;Habib,Donald;Williams,Joseph;Dixon Herrity,Jennifer;Hayes,Barbara;Cc:Patel,Chandu;Colaccino,Joseph;Segala,John
Subject:
AssociatedwithLAR17 037,Tier2*DepartureProcessWhen:Wednesday,Febru a ry28,20189:00AM10:00AM(UTC05:00)EasternTime(US&Canada).Where:Frank'sOfficeThe purpose of this meeting is to identify and gain alignment on regarding LAR 17-037 that would affect staff approval of the amendment.
Requested By: Don Habib
Scheduled By: Christine Richie
77 Williams, Joseph From: Habib, Donald Sent: Tuesday, March 13, 2018 1:31 PM To:Bradford, Anna; Kallan, Paul; Akstulewicz, Frank; Williams, Joseph; Segala, John Cc:Patel, Chandu; Dixon-Herrity, Jennifer
Subject:
FW: Discussion Topics for Vogtle Units 3 and 4, 3/15/18 Public Meeting (LAR 17-037, Tier 2* Departure Process)FYI - These are discussion topics from SCVB for this week's public meeting with SNC.
Thanks Don From:Habib,DonaldSent:Tuesday,March13,20181:28PMTo:'WASPARKM@southernco.com'<WASPARKM@southernco.com>;'ptapscot@southernco.com'<ptapscot@southernco.com>;'Chamberlain,AmyChristine'<ACCHAMBE@southernco.com>;'neil.haggerty@excelservices.com'<neil.haggerty@excelservices.com>;'Thomas,Corey(SNC)'<BRCThoma@southernco.com>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;Ashley,Clinton<Clinton.Ashley@nrc.gov>;Cranston,Gregory<Gregory.Cranston@nrc.gov>;VogtlePEmails<Vogtle.PEmails@nrc.gov>
Subject:
DiscussionTopicsforVogtleUnits3and4,3/15/18PublicMeeting(LAR17 037,Ti er2*De partureProcess)Wes et al. -
Below are discussion topics for the upcoming public meeting on 3/15/18. These topics pertain to LAR 17-037 Qualifying Criterion 4, "Adversely affects the debris screen design criteria," which was based upon 10 CFR Part 52 Appendix D, Paragraph VIII.B.6.b(7), "Screen design criteria."
Please contact me if you have any questions.
Don Habib
Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 Regarding VIII.B.6.b(7), "Screen design criteria," the analysis summary provided in LAR Enclosure 5 states "Paragraph VIII.B.5 may not work well in all cases
.." W hat is meant by "Paragraph VIII.B.5 may not work well in all cases
"? An example would be helpful. LAR Enclosure 1, page 12 of 19, provides detailed guidance for Qualifying Criterion 4. The detailed guidance consists of two parts: 1. An adverse change is any change that would be considered a non-conservative change of a debris value established in the UFSAR; 2. An adverse change would be any change that ch anges any element of the evaluations used to determine the design of the debris screens.
78 Explain how the detailed guidance was developed and why these two items are sufficient to assess whether a change is adverse in this safety significant area. Will the detailed guidance be incorporated into a procedure upon LAR approval? For item 1, What debris values established in the UFSAR are subject to Qualifying Criterion 4? What would be considered a non-conservative change of a debris value? What would be considered a conservative change of a debris value? Explain whether an increase or decrease in a debris value established in the UFSAR "would be considered a non-conservative change of a debris value established in the UFSAR" that would result in assessing the change as adverse. For item 2, What debris screens are subject to this criterion? What is considered to be an element of the evaluations used to determine the design of the debris screens? Explain whether a decrease or increase in strainer area (frontal face or screen surface) "would be considered a change to an element of the evaluations used to determine the design of the debris screens" that would result in assessing the change as adverse. Explain whether an increase or decrease in strainer mesh size "would be considered a change to an element of the evaluations used to determine the design of the debris screens" that would result in assessing the change as
adverse. Explain how changes to information associated with VIII.B.6.b item 7 contained in UFSAR section 6.3.2.2.7.1 (e.g., ZOI and use of MRI) would be assessed by this new process. Are these items considered to be an element of the evaluations used to determine the design of the debris screens? The CFR refers to "screen design criteria." The LAR refers to "-debris screen design criteria" (Qualifying Criterion 4). 1. Please explain why the word "debris" was added in the LAR description. 2. Detailed guidance (discussed above) refers to debris values and design of debris screens. However Qualifying Criteria 4 appears to be limited to "debris screen design." Why the difference? Should Qualifying Criteria 4 be updated to reflect these two areas (debris values and design of debris screens) that are expressed in the detailed guidance? LAR Enclosure 6 provides an example where a Tier 2* departure would not require prior NRC approval. In answering the question posed by Qualifying Criterion 4 (adversely affects the debris screen design criteria?), the LAR states that Qualifying Criterion 4 poses a question "regarding impacts- to the PXS recirculation screen design." Qualifying criterion 4 is more than just impacts to PXS recirculation screen design. It is also about debris values. Therefore, based on the "reviewers aid" provided in LAR Enclosure 6, if the process was applied as shown, could it lead to an unacceptable
outcome?
From:Habib,DonaldSent:Monday,March12,201810:34AMTo:'WASPARKM@southernco.com'<WASPARKM@southernco.com
>;'ptapscot@southernco.com'<ptapscot@southernco.com
>;'Chamberlain,AmyChristine'<ACCHAMBE@southernco.com
>;'neil.haggerty@excelservices.com'<neil.haggerty@excelservices.com
>;'Thomas,Corey(SNC)'<BRCThoma@southernco.com
>
Subject:
UpdateonLAR17 037(Tier2*DepartureProcess) 79Wes et al. -
This is just a heads-up that I expect to have a staff question ready to send to you in the next day or two, pertaining to this LAR, for discussion at the public teleconference this Thursday. The question(s) relate to criterion #4.
Thanks Don Don Habib
Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 80 Williams, Joseph From: Habib, Donald Sent: Wednesday, March 14, 2018 10:11 AM To: Williams, Joseph
Subject:
FW: Re: Discussion Topics for Vogtle Units 3 and 4, 3/15/18 Public Meeting (LAR 17-037, Tier 2* Departure Process)
FYI
Original Message-----
From: Habib, Donald Sent: Wednesday, March 14, 2018 10:07 AM To: Ashley, Clinton <Clinton.Ashley@nrc.gov>; Hoellman, Jordan <Jordan.Hoellman2@nrc.gov>
Cc: Kallan, Paul <Paul.Kallan@nrc.gov>; Dixon-Herrity, Jennifer <Jennifer.Dixon-Herrity@nrc.gov>; Patel, Chandu <Chandu.Patel@nrc.gov>
Subject:
FW: Re: Discussion Topics for Vogtle Units 3 and 4, 3/15/18 Public Meeting (LAR 17-037, Tier 2*
Departure Process)
Clint - See below. SNC won't be ready to discuss this topic this week, and is asking for a clarification call next
week.
Jordan - Please go ahead and take this item off the agenda for this week's public meeting.
I'll try to follow up with Jason Redd to get something nonpublic scheduled next week.
Thanks Don -----Original Message-----
From: Redd, Jason P. [1]
Sent: Wednesday, March 14, 2018 9:57 AM
To: Habib, Donald <Donald.Habib@nrc.gov>
Cc: Amundson, Theodore Edwin <X2TAMUNS@southernco.com>; Hicks, Thomas E. <X2TEHICK@southernco.com>; Haggerty, Neil <X2NHAGGE@SOUTHERNCO.COM>; Aughtman, Amy G. <AGAUGHTM@SOUTHERNCO.COM>; Sparkman, Wesley A. <WASPARKM@southernco.com>
Subject:
[External_Sender] Re: Discussion Topics for Vogtle Units 3 and 4, 3/15/18 Public Meeting (LAR 17-037, Tier 2* Departure Process)
Good morning Don, I just left you a VM but wanted to follow up with an email in case you're at the RIC this morning. Our team has reviewed the below questions and after internal discussions, request that SNC and the Staff have a clarification call Monday or Tuesday of next week before discussing these questions on the weekly public call. As always, we appreciate the Staff being so diligent in reviewing this LAR and offering a quick opportunity to discuss the Staff's questions.
I will be at the RIC today and Thursday; my cell at 205-329-4759 is the best way to reach me these two days.
Thank you Don.
-Jason Redd
81 Sent from my iPhone
On Mar 13, 2018, at 1:30 PM, Sparkman, Wesley A. <WASPARKM@southernco.com<mailto:WASPARKM@southernco.com>> wrote:
Sent from my iPhone
Begin forwarded message:
From: "Habib, Donald" <Donald.Habib@
nrc.gov<mailto:Donald.Habib@nrc.gov>> Date: March 13, 2018 at 1:27:41 PM EDT To: "WASPARKM@southernco.com<mailto:WASPARKM@southernco.com>" <WASPARKM@southernco.com<mailto:WASPARKM@southernco.com>>, "ptapscot@southernco.com<mailto:ptapscot@southernco.com>"
<ptapscot@southernco.com<mailto:ptapscot@southernco.com>>, "Chamberlain, Amy Christine"
<ACCHAMBE@southernco.com<mailto:ACCHAMBE@southernco.com>>,
"neil.haggerty@excelservices.com<mailto:neil.haggerty@excelservices.com>" <neil.haggerty@excelservices.com<mailto:neil.haggerty@excelservices.com>>, "Thomas, Corey (SNC)" <BRCThoma@southernco.com<mailto:BRCThoma@southernco.com>>
Cc: "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov<mailto:Jennifer.Dixon-Herrity@nrc.gov>>,
"Patel, Chandu" <Chandu.Patel@nrc.gov<mailto:C handu.Patel@nrc.gov>>, "Ashley, Clinton" <Clinton.Ashley@nrc.gov<mailto:Clinton.
Ashley@nrc.gov>>, "Cranston, Gregory" <Gregory.Cranston@nrc.gov<mailto:Gregory.Cranston@nrc.gov>>, Vogtle PEmails <Vogtle.PEmails@nrc.gov<mailto:Vogtle.PEmails@nrc.gov>>
Subject:
Discussion Topics for Vogtle Units 3 and 4, 3/15/18 Public Meeting (LAR 17-037, Tier 2* Departure
Process)
Wes et al. -
Below are discussion topics for the upcoming public meeting on 3/15/18. These topics pertain to LAR 17-037 Qualifying Criterion 4, "Adversely affects the debris screen design criteria," which was based upon 10 CFR Part 52 Appendix D, Paragraph VIII.B.6.b(7), "Screen design criteria."
Please contact me if you have any questions.
Don Habib
Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
- Regarding VIII.B.6.b(7), "Screen design criteria," the analysis summary provided in LAR Enclosure 5 states "Paragraph VIII.B.5 may not work well in all cases.."
- What is meant by "Paragraph VIII.B.5 may not work well in all cases"? An example would be helpful.
- LAR Enclosure 1, page 12 of 19, provides detailed guidance for Qualifying Criterion 4. The detailed guidance consists of two parts:
- 1. An adverse change is any change that would be considered a non-conservative change of a debris value established in the UFSAR;
822. An adverse change would be any change that changes any element of the evaluations used to determine the design of the debris screens.
§ Explain how the detailed guidance was developed and why these two items are sufficient to assess whether a change is adverse in this safety significant area. Will the detailed guidance be incorporated into a procedure upon LAR approval?
§ For item 1,
- What debris values established in the UFSAR are subject to Qualifying Criterion 4?
- What would be considered a non-conservative change of a debris value?
- What would be considered a conservative change of a debris value?
- Explain whether an increase or decrease in a debris value established in the UFSAR "would be considered a nonconservative change of a debris value established in the UFSAR" that would result in assessing the change as adverse.
§ For item 2,
- What debris screens are subject to this criterion?
- What is considered to be an element of the evaluations used to determine the design of the debris screens?
- Explain whether a decrease or increase in strainer area (frontal face or screen surface) "would be considered a change to an element of the evaluations used to determine the design of the debris screens" that would result in assessing the change as adverse.
- Explain whether an increase or decrease in strainer mesh size "would be considered a change to an element of the evaluations used to determine the design of the debris screens" that would result in assessing the change as adverse.
- Explain how changes to information associated with VIII.B.6.b item 7 contained in UFSAR section 6.3.2.2.7.1 (e.g., ZOI and use of MRI) would be assessed by this new process. Are these items considered to be an element of the evaluations used to determine the design of the debris screens?
- The CFR refers to "screen design criteria." The LAR refers to "-debris screen design criteria" (Qualifying Criterion 4).
- 1. Please explain why the word "debris" was added in the LAR description.
- 2. Detailed guidance (discussed above) refers to debris values and design of debris screens. However Qualifying Criteria 4 appears to be limited to "debris screen design." Why the difference? Should Qualifying Criteria 4 be updated to reflect these two areas (debris values and design of debris screens) that are expressed in the detailed guidance?
- LAR Enclosure 6 provides an example where a Tier 2* departure would not require prior NRC approval. In answering the question posed by Qualifying Criterion 4 (adversely affects the debris screen design criteria?), the LAR states that Qualifying Criterion 4 poses a question "regarding impacts- to the PXS recirculation screen design." Qualifying criterion 4 is more than just impacts to PXS recirculation screen design. It is also about debris values. Therefore, based on the "reviewers aid" provided in LAR Enclosure 6, if the process was applied as shown, could it lead to an unacceptable outcome?
83 From: Habib, Donald Sent: Monday, March 12, 2018 10:34 AM To: 'WASPARKM@southernco.com<mailto:WASPARKM@southernco.com>'
<WASPARKM@southernco.com<mailto:WASPARKM@southernco.com>>;
'ptapscot@southernco.com<mailto:ptapscot@southernco.com>' <ptapscot@southernco.com<mailto:ptapscot@southernco.com>>; 'Chamberlain, Amy Christine'
<ACCHAMBE@southernco.com<mailto:ACCHAMBE@southernco.com>>;
'neil.haggerty@excelservices.com<mailto:neil.haggerty@excelservices.com>'
<neil.haggerty@excelservices.com<mailto:neil.haggerty@excelservices.com>>; 'Thomas, Corey (SNC)' <BRCThoma@southernco.com<mailto:BRCThoma@southernco.com>>
Subject:
Update on LAR 17-037 (Tier 2* Departure Process)
Wes et al. -
This is just a heads-up that I expect to have a staff question ready to send to you in the next day or two, pertaining to this LAR, for discussion at the public teleconference this Thursday. The question(s) relate to criterion #4.
Thanks Don Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
84 Williams, Joseph From: Habib, Donald Sent: Thursday, March 22, 2018 8:14 AM To: Williams, Joseph Cc: Segala, John
Subject:
RE: RAI MeetingJoe -
OK. I am just return to the office. Before you write the RAI, you may wish to audit the SNC analysis. The SNC submittal states:
SNC performed an analysis of the Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c. The analysis examined each item in terms of the following criteria:
- Degree to which the Tier 2* information is not addressed in the following but meets Tier 1 inclusion criteria:
o VEGP 3 and 4 Plant-specific Tier 1 Design Control Document (DCD), or o VEGP 3 and 4 Combined License (COL), or o Applicable regulations, e.g., 10 CFR 50.46
- Degree to which Codes, standards, and design and qualification process, are relied upon for ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1 DCD
- Safety-significance
- Degree to which 10 CFR Part 52, Appendix D, Section VIII.B.5 would effectively evaluate a Tier 2* departure
Actually, I think that all of the affected branches should audit the analysis to make sure that we agree with it.
I would like to propose such an audit at the meeting today.
If we disagree with their analysis, then how can we be approving the LAR?
Thanks Don From:Williams,JosephSent:Tuesday,March20,20189:08PMTo:Habib,Donald<Donald.Habib@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>
Subject:
RAIMeeting Don, I'm afraid I won't be able to attend the RAI meeting on Thursday. I went to an EPRI meeting in Charlotte today, and had planned to fly home in the morning, but the storm has made me move that back a day. I won't be able to get to the office in time for your meeting. I can tell you that I'm planning to write an RAI following up on the acceptance letter text regarding how to distinguish Tier 1 equivalent info. I'm also thinking about one regarding the standardizati on issue, but I need to do some more research.
85 Joe
87 Passcode 271-5638#
OriginalAppointmentFrom:Kallan,PaulOnBehalfOfNRO_DNRL_LB4_CalResourceSent:Monday,March19,201810:47AMTo:Jung,Ian;Mitchell,Matthew;Samaddar,Sujit;Lupold,Timothy;Carpenter,Cynthia;Caldwell,Robert;Monninger,John;Karas,Rebecca;Cranston,Gregory;Segala,John;Kent,Lauren;McGinty,Tim;Krohn,Paul;Williams,Joseph;Dixon Herrity,Jennifer;Akstulewicz,Frank;Bradford,Anna;Zhao,Jack;Honcharik,Joh n;Hansing,Nicholas;Scarbrough,Thomas;Jain,Bhagwat;Ashley,Clinton;VanWert,Christopher;Green,Brian;Patel,Chandu;Coyne,Kevin;Nolan,Ryan;Royer,Deanna;Hayes,Barbara;Fetter,Allen;Habib,Donald;Kallan,PaulCc:Brown,Frederick;Ordaz,Vonna;Franovich,Mike
Subject:
UPDATE:AlignmentonRAIsforVogtleLARChangestoTier2*DepartureProcess(Attachment)When:Thursd ay,Marc h22,201810:30AM 11:30AM(UTC 05:00)EasternTime(US&Canada).Where:TWFN 06A1LAR 17-037 Review Team -
Attached for your review prior to the alignment meeting is a compilation of the branch responses to the DNRL
questions.
Also prior to the meeting, I plan on distributing a compilation of the draft and final RAIs.
Thanks for your support of this project. Please contact me if you have any questions.
Thanks Don
<< File: Compilation of Branch Responses LAR 17-037.docx >>
<<File:CompilationofRAIsbeingproposedforLAR17 037(Paul3 19 2018).docx>> Don Habibi Project Manager NRO/DNRL, Licensing Branch 4 O-8D13 301-415-1035
LAR 17-037 Review Team -
The purpose of this meeting is to ensure that th e RAIs for this LAR align with each other and with the general office direction.
For attendance, we are looking for sufficient representation from the technical branches responsible for Vogtle
Tier 2* information (MEB, ICE, MCB, SEB, SRSB, SCVB, and HOIB) and their technical division management so that the position and concerns of each branch can be represented.
ACTION: If your branch expects to issue an RAI for LAR 17-037, please send it to me prior to the meeting in time so that I can distribute it to the other involved branches.
Please contact me if you have any questions.
88 Thanks Don Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
90 << File: Compilation of Branch Responses LAR 17-037.docx >>
<<File:CompilationofRAIsbeingproposedforLAR17 037(Paul3 19 2018).docx>> Don Habibi Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
LAR 17-037 Review Team -
The purpose of this meeting is to ensure that the RAIs for this LAR align with each other and with the general office direction.
For attendance, we are looking for sufficient representation from the technical branches responsible for Vogtle Tier 2* information (MEB, ICE, MCB, SEB, SRSB, SCVB, and HOIB) and their technical division management so that the position and concerns of each branch can be represented.
ACTION: If your branch expects to issue an RAI for LAR 17-037, please send it to me prior to the meeting in time so that I can distribute it to the other involved branches.
Please contact me if you have any questions.
Thanks Don Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
91 Williams, Joseph From: Habib, Donald Sent: Thursday, March 22, 2018 2:01 PM To:Jung, Ian; Mitchell, Matthew; Samaddar, Su jit; Lupold, Timothy; Carpenter, Cynthia; Caldwell, Robert; Monninger, John; Karas, Rebecca; Cranston, Gregory; Segala, John; Kent, Lauren; McGinty, Tim; Krohn, Paul; Williams, Joseph; Dixon-Herrity, Jennifer; Akstulewicz, Frank; Bradford, Anna; Zhao, Jack; Honcharik, John; Hansing, Nicholas; Scarbrough, Thomas; Jain, Bhagwat; Ashley, Clinton; Van Wert, Christopher; Green, Brian; Patel, Chandu; Coyne, Kevin; Nolan, Ryan; Royer, Deanna; Brown, Frederick; Ordaz, Vonna; Hayes, Barbara; Fetter, Allen; Habib, Donald; Kallan, Paul; Taneja, Dinesh
Subject:
Path Forward on Vogtle LAR 17-037/Tier 2*
Follow Up Flag:Follow up Due By: Monday, March 26, 2018 8:00 AM Flag Status:
Completed Categories:
Red CategoryPath Forward on Vogtle LAR 17-037/Tier 2*
Review Team -
Thanks for everyone's insights at the meeting this morning. Based on the meeting discussion, here is our path
forward:
Public Meeting Questions: I will schedule a public meeting discussion if your branch has discussion topics or clarifications they need to address in a public teleconference with SNC, before finalizing their RAI. Please let me know whether you need a public meeting discussion, and send me your topics/questions so that we can schedule them.
RAIs: If your branch has already provided a draft RAI, please let me know if you want to change it based on today's meeting, or otherwise put a hold on it (e.g., to first have a public meeting discussion), or if I can proceed with processing it.
There may be a few cases (e.g., providing a definition for "material change" where multiple branches have a common interest. I plan to share these with other branches during the review process.
Don Habib
Project Manager NRO/DNRL, Licensing Branch 4 O-8D13 301-415-1035 92 Williams, Joseph From: Williams, Joseph Sent: Tuesday, April 03, 2018 6:33 AM To: Habib, Donald
Subject:
RAI Status Don, Apologies for the delay in relaying my RAIs to you. John Segala told me he still has them. I've talked to him about them a couple times, and made some adjustments per his suggestions, so I don't anticipate any
significant changes. It's just a matter of him having time to look at them.
Joe 93 Williams, Joseph From: Coyne, Kevin Sent: Friday, April 06, 2018 8:40 AM To: Williams, Joseph Cc: Segala, John
Subject:
RE: Vogtle Tier 2* LAR Proposed ARPB RAIsThanks Joe -
I can stop by (or vice versa) - I think we need to give SNC some sense of how they differ from the NEI guidance - even if it is a very high level discussion (e.g., "the process steps and specific screening questions appear to differ significantly from that proposed by NEI.." - just to give you an idea of the level of detail). For the 4 th question, my sense on any Vogtle LAR request is that aspirational questions are going to get kicked out - I think we're down to a "just the facts" approach with even Office Director level of engagement on the content of RAI questions. So, to save us one round of comments with DNRL, it would be better to cut out anything that isn't absolutely essential for the Vogtle review. To be honest, I think the comparison of the Vogtle approach to the NEI guidance could fit into the same "not essential" category, but given the generic implications you raise, I think I'd like to get that in the hopper and see if the question triggers any rethinking on SNC's part (acknowledging they could just answer with a "we didn't use that guidance" response-).
Kevin.
From:Williams,JosephSent:Friday,April06,20186:28AMTo:Coyne,Kevin<Kevin.Coyne@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>
Subject:
RE:VogtleTier2*LARProposedARPBRAIsKevin, Regarding the second question, there is no commonality at all between the LAR and the NEI first principles, so it's not a matter of incremental deviation that examples would illustrate. I can add the accession number.
I tried to phrase the request to apply the approach to all previous Tier 2* LARs as an aspirational goal that would be nice to have, but not mandatory. I'm personally not in a good position to identify specific examples, as I haven't been involved in any LARs. It would be a good question to pose to the staff, if DNRL is willing. My experience to date suggests they might not be very receptive to my suggestions, so such a proposal might need strong divisional management support.
Joe From:Coyne,KevinSent:Thursday,April05,20188:25PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
Re:VogtleTier2*LARProposedARPBRAIsThanksJoegreatquestions.
94 IknowJohnstillneedstoreview,butIhadtwoquestions/commentsforyourconsideration: Forthesecondquestion,canwepointtoanexampleortwowheretheSNCapproachdepartsfromtheNEIOfirstprinciplesdocument.Also,isthereanyADAMSMLreferencewecanprovideforthefirstprinciplesdocformNEI? Forthe4thquestion,IthinkhavingSNCtightenuptheexamplesthey'veprovidedtobetterillustratehowtheprocesswouldworkisagreatquestion.ButI'mwonderingifaskingSNCtorunallpriorLARsthroughthescreeningprocessmightbeabridgetoofarcanweeithereliminatethisbroaderportionoftherequestorprovideafewspecificpastLARexamp l eswherewemighthaveconcernstofocustheeffortabitmore?Thanks!
Kevin
On:05April201815:02,"Williams,Joseph"<Joseph.Williams@nrc.gov
>wrote:Kevin, Per our discussion, here are my proposed RAIs for the Vogtle Tier 2* LAR. Joe 95 Williams, Joseph From: Williams, Joseph Sent: Wednesday, April 11, 2018 12:34 PM To: Habib, Donald Cc: Segala, John
Subject:
RE: Schedule for Issuing RAIs for Vogtle LAR 17-037 Attachments:
ARPB RAIs.docx Categories:
Red Category Don, Here are my RAIs. They have been endorsed by DSRA management.
Joe From:Habib,DonaldSent:Tuesday,April10,20183:34PMTo:VanWert,Christopher<Christopher.VanWert@nrc.gov>;Green,Brian<Brian.Green@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Ashley,Clinton<Clinton.Ashley@nrc.gov>Cc:Cranston,Gregory<Gregory.Cranston@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Kent,Lauren<Lauren.Kent@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>
Subject:
ScheduleforIssuingRAIsforVogtleLAR17 037Tier 2* LAR Reviewers -
For the remaining RAIs to be issued, I propose the following schedule:
All draft RAIs to be provided to DNRL PM by COB Thursday, April 12 Technical branches to respond to comments from PM, management within 2 days
The goal is to have all RAIs finished with internal review and transmitted to SNC as draft by Friday, April 20.
Please let me know whether you can support this. Thanks for your support on this review.
Thanks Don
Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 96 Williams, Joseph From:Ashley, Clinton Sent: Friday, April 13, 2018 8:27 AM To:Van Wert, Christopher; Green, Brian; Williams, Joseph
Subject:
RE: Action/Question: Coordina tion of Tier 2* RAI Questi ons: (1) Removing Detail and (2) Defining "Adverse"I think Criterion 4's use of adverse is defined in the LAR by pointing to 50.59 guidance. I think that pointer works for SCVB.
Clint From:VanWert,ChristopherSent:Friday,April13,20186:40AMTo:Green,Brian<Brian.Green@nrc.gov>;Ashley,Clinton<Clinton.Ashley@nrc.gov>
Subject:
RE:Action/Question:CoordinationofTier2*RAIQuestions:(1)RemovingDetailand(2)Defining"Adverse"Hi Brian, I've attached the RAIs that I sent to Don. My Question 4 is related to "adverse" but I didn't specifically make it general. I know the situation is a little different between Clint and I because Criterion 4 actually does sort of define adverse (by pointing to an NEI document) and Criterion 3 does not. I haven't looked to see what it says in the other sections. Similarly, my Question 3 is related to removing detail. I didn't specifically coordinate with others in the drafting of this question either.
I am more than happy to tailor my question in a more general way if it would help, or if you have a more general one already drafted which you think would cover my area, I'm happy to get rid of mine Thanks!
Chris From:Green,BrianSent:Thursday,April12,20183:39PMTo:Ashley,Clinton<Clinton.Ashley@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>
Subject:
FW:Action/Question:CoordinationofTier2*RAIQuestions:(1)RemovingDetailand(2)Defining"Adverse" Hi Clinton & Christopher,
I haven't seen any discussion on this topic. I have been working on a draft RAI that addresses some of these concerns, but it is specific to the human factors modifications/process. Do either of you have drafts that are more general?
Brian From:Habib,DonaldSent:Monday,April09,20187:27AMTo:Ashley,Clinton<Clinton.Ashley@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Green,Brian<Brian.Green@nrc.gov
>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Kent,Lauren<Lauren.Kent@nrc.gov
>;Cranston,Gregory<Gregory.Cranston@nrc.gov
>
Subject:
Action/Question:CoordinationofTier2*RAIQuestions:(1)RemovingDetailand(2)Defining"Adverse" 97Chris and Clint and Brian -
Can you please check with each other about whether it makes sense to combine certain RAI questions that your respective branches are interested in?
Among your three branches, the SRSB draft RAI is furthest along, and I am sharing the current draft with you.
Specifically:
"Removing Detail" (SRSB and HOIB) o SRSB draft question 3 asks about "removing detail" not being a material change in SNC guidance for Criterion 3. HOIB has a similar concern about removing detail, as it is mentioned for SNC's guidance for Criterion 2.
"Adverse" (SRSB and SCVB) o SRSB draft question 4 asks about the definition of "adverse" in the SNC guidance for Criterion 3. SCVB has a similar concern about the meaning of "adverse" as it is used in SNC's guidance
for Criterion 4.
ACTION: Please let me know if you'd prefer that I set up or attend the meetings between you to address these questions
. If not, go ahead and communicate directly with each other and let me know the outcome.
This issue should be addressed before the RAIs are issued.
Thanks Don
Don Habib
Project Manager NRO/DNRL, Licensing Branch 4 O-8D13 301-415-1035 98 Williams, Joseph From: Habib, Donald Sent: Monday, April 16, 2018 2:41 PM To: Williams, Joseph
Subject:
ARPB RAIs 4-11 PM Comments-More.docx Attachments:
ARPB RAIs 4-11 PM Comments-More.docx Categories:
Red CategoryJoe - Please use this version. I added one more (important) comment.
Thanks Don 99 Williams, Joseph From: Habib, Donald Sent: Monday, April 16, 2018 4:08 PM To:Jung, Ian Cc:Zhao, Jack; Dixon-Herrity, Jennifer; Williams, Joseph
Subject:
RE: INFO/Question: Questions on SNC Tier 2* LAR (ICE and ARPB)
Attachments:
ARPB RAIs 4-11 PM Comments-More.docxMy thoughts:
PUBLIC MEETING. I will need to see about getting this topic on the public meeting agenda for this Thursday morning. There are already some topics, and I'd need to see if there is room for one more. For the public meeting discussion, I'll need you to provide a topic that we can send to SNC in advance of the meeting (i.e., by close of business tomorrow.) At the end of the public meeting discussion, we'd need to align with SNC on a path forward. E.g., whether SNC is understands the issue sufficiently to proceed with a voluntary submittal, or whether an RAI is needed. We would also need to be in agreement about the schedule. If an RAI resulted, then this might be the last of the RAIs.
ARPB RAI. The ARPB RAI is still being worked and needs to be approved. If it makes sense to do so, we could adjust it to accommodate your question. I set up a meeting with Joe Williams to get the ball rolling, or please feel free to work with Joe Williams directly, since people's schedule are pretty full. I sent the attached
markup to Joe this morning.
Thanks Don
From:Jung,IanSent:Monday,April16,20183:43PMTo:Habib,Donald<Donald.Habib@nrc.gov>Cc:Zhao,Jack<Jack.Zhao@nrc.gov>
Subject:
INFO/Question:QuestionsonSNCTier2*LARAfter considering and other proposed/issued RAIs, we are evaluating the need for an RAI for ICE. ARPB's RAIs appear to encompass our 2 nd question on dealing with safety significant Tier 2* information in WCAPs. For the 1 st question (on scope and consistency between systems listed versus WCAPs), it may be more efficient to have a clarification call with SNC and have them voluntarily revise the information we need. Any thoughts? Thanks. - Ian
From:Zhao,JackSent:Monday,April16,20183:34PMTo:Jung,Ian<Ian.Jung@nrc.gov
>
Subject:
DraftEmailtoDonAfter further discussi ons, we decided to remove the second question in our original RAI because it seems that this specific question has been envelop ed by the general RAI question raised by Joe.
100 As for the 1st question in our RAI, we are thinking if the licensee can clarify it on a teleconference call, we may not need to issue this RAI. So, is it possible to arrange a clarification call with the licensee?
HaveaGreatDay!JackY.Zhao,PELoc.T7J7 ,MST7E18MNRO/DE/ICE1,USNRC301 4154021(O)301 4155397(fax) 101 Williams, Joseph From: Williams, Joseph Sent: Tuesday, April 17, 2018 8:56 AM To: Segala, John
Subject:
FW: INFO/Question: Questions on SNC Tier 2* LAR (ICE and ARPB)
Attachments:
ARPB RAIs 4-11 PM Comments-More.docx John, FYI. The attached file provides DNRL feedback on my Tier 2* RAIs.
The comment on the first question is very interesting, as I think it takes the question farther than I had expected. I think it would be very beneficial if SNC described exactly what information it considers Tier 1-equivalent (i.e., "true" Tier 2*), and what is not. We would need to know how they came to that conclusion, though, so the RAI would need to also ask for a description of the process and criteria they used to make that determination. I think it's a good question, but I also doubt SNC is prepared to answer it, as I think it pretty much exactly what they are trying to avoid; they don't want to do any sort of detailed evaluation until they have a specific need identified. Otherwise, they are expending resources for something they might not need.
I don't object to the second and third questions being discussed in a public meeting, assuming there is some sort of substantial description of that discussion documented in the meeting summary. +
Don has scheduled a meeting this morning at 11 to discuss coordinating my RAI with ICE, so I'll let you know what comes out of that discussion.
Joe From:Habib,DonaldSent:Monday,April16,20184:08PMTo:Jung,Ian<Ian.Jung@nrc.gov>Cc:Zhao,Jack<Jack.Zhao@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
RE:INFO/Question:QuestionsonSNCTier2*LAR(ICEandARPB)My thoughts:
PUBLIC MEETING. I will need to see about getting this topic on the public meeting agenda for this Thursday morning. There are already some topics, and I'd need to see if there is room for one more. For the public meeting discussion, I'll need you to provide a topic that we can send to SNC in advance of the meeting (i.e., by close of business tomorrow.) At the end of the public meeting discussion, we'd need to align with SNC on a path forward. E.g., whether SNC is understands the issue sufficiently to proceed with a voluntary submittal, or whether an RAI is needed. We would also need to be in agreement about the schedule. If an RAI resulted, then this might be the last of the RAIs.
ARPB RAI. The ARPB RAI is still being worked and needs to be approved. If it makes sense to do so, we could adjust it to accommodate your question. I set up a meeting with Joe Williams to get the ball rolling, or please feel free to work with Joe Williams directly, since people's schedule are pretty full. I sent the attached markup to Joe this morning.
Thanks Don 102 From:Jung,IanSent:Monday,April16,20183:43PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Zhao,Jack<Jack.Zhao@nrc.gov
>
Subject:
INFO/Question:QuestionsonSNCTier2*LARAfter considering and other proposed/issued RAIs, we are evaluating the need for an RAI for ICE. ARPB's RAIs appear to encompass our 2 nd question on dealing with safety significant Tier 2* information in WCAPs. For the 1 st question (on scope and consistency between systems listed versus WCAPs), it may be more efficient to have a clarification call with SNC and have them voluntarily revise the information we need. Any thoughts? Thanks. - Ian
From:Zhao,JackSent:Monday,April16,20183:34PMTo:Jung,Ian<Ian.Jung@nrc.gov
>
Subject:
DraftEmailtoDonAfter further discussi ons, we decided to remove the second question in our original RAI because it seems that this specific question has been envelop ed by the general RAI question raised by Joe.
As for the 1st question in our RAI, we are thinking if the licensee can clarify it on a teleconference call, we may not need to issue this RAI. So, is it possible to arrange a clarification call with the licensee?
HaveaGreatDay!JackY.Zhao,PELoc.T7J7 ,MST7E18MNRO/DE/ICE1,USNRC301 4154021(O)301 4155397(fax) 103 Williams, Joseph From: Habib, Donald Sent: Wednesday, April 18, 2018 9:47 AM To: WASPARKM@southernco.com Cc: neil.haggerty@excelservices.com; Hoellman, Jordan; x2nhagge@southernco.com; Patel, Chandu; Dixon-Herrity, Jennifer; Amundso n, Theodore Edwin; Hicks, Thomas E.;
Williams, Joseph
Subject:
RE: Question for licensee on LAR 17-037, related to emergency preparedness (EP)Wes et al. -
Below is another additional topic regarding LAR 17-037 that the staff would like to address at the public meeting this Thursday:
Please advise if you can support the discussion topic.
Later today, I expect to send you additional topics related to that LAR for the public meeting.
Thanks
Don Habib
Project Manager NRO/DNRL, Licensing Branch 4 O-8D13 301-415-1035 TheLARstatesthattheproposedprocessis"functionallyconsistentwithdepartureevaluationprocessesappliedbycurrentapplicationsforthecertificationofdesignsthatcontainnoTier2*information."Thedepartureevaluationprocessdoesnotapplyuntiladesigniscertifiedandalicensereferencesthatce rtification,soitisnotclearwhatprocessSNCisreferringto,orwhytheclaimeds imilarityispertinenttothisplantspecificLAR.Further,designscurrentlyunderreviewdiffersignificantlyfromAP1000,withsubstantiallydifferentapproachestoensuringsafety,soprocessesthatmightapplytoonedesignmaynotberelevanttoanotherdesign.Therefore,SNCisrequestedtoidentifyanddescribetheprocessbeingrefe rredtoandit srelevancetotheLAR. From:Habib,DonaldSent:Wednesday,April18,20188:16AMTo:'WASPARKM@southernco.com'<WASPARKM@southernco.com>Cc:'neil.haggerty@excelservices.com'<neil.haggerty@excelservices.com>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;'x2nhagge@southernco.com'<x2nhagge@southernco.com>;Patel,Chandu<Chandu.Patel@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;'Amundson,TheodoreEdwin'<X2TAMUNS@southernco.com>;Hicks,ThomasE.<X2TEHICK@southernco.com>;Barss,Dan<Dan.Barss@nrc.gov>
Subject:
QuestionforlicenseeonLAR17 037,relatedtoemergencypreparedness(EP)Wes et al. -
Below is a discussion topic the staff would like to address at the public meeting this Thursday, related to LAR 17-037.
Later today, I expect to send you additional topics related to that LAR for the public meeting.
104 Please advise if you can support the discussion topic.
Thanks Don Habib
Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
The AP 1000 DCD, in the introduction section, in Table 1-1, "Index of AP1000 Tier 2 Information Requiring NRC Approval for Change" identifies Tier 2 References 18.
8.2, 18.8.3.5, and 18.8.6. These references are to emergency preparedness items such as the location of the technical support center (TSC), TSC Interfaces, TSC Habitability, and other requirements for emergency response capabilities. Though these references point to the human factors sections where these items are addressed at a high level, more specific details are found in Section 13.3 of the Vogtle 3&4 UFSAR, and even more specifically in the site emergency plan which is a separate licensing document. Change to EP information is controlled by the requirements in 10 CFR 50.54(q). This section has criteria for what can and cannot be changed without prior NRC approval for EP
matters.
How would EP matters, controlled by 10 CFR 50.54(q), screen out using the proposed screening criteria that LAR 17-037 proposes?
105 Williams, Joseph From: Williams, Joseph Sent: Wednesday, April 18, 2018 10:40 AM To: Habib, Donald
Subject:
RE: Action/Question for Public Meeting Discussion (LAR 17-037)
Don, The issue is that Tier 2* is supposed to have safety significance equivalent to Tier 1, but there's no objective definition for Tier 1. SECY-17-0075 includes this text:
The NRC staff obtained additional stakeholder feedback in a public meeting on June 9, 2016. The staff's presentation discussed advantages and disadvantages of potential alternative approaches for use of the Tier 2* designation and any supporting activities. NEI and other industry representatives at the meeting indicated their support for ending use of the Tier 2* designation for future design certifications, reiterating views expressed in NEI's December 19, 2014, letter. NEI and industry stakeholders agreed that objective guidance should be developed to assist in identifying Tier 1 and Tier 2 content. NEI representatives stated that the Tier 1 "first principles" described in proposed guidance in NEI 15-02, "Industry Guideline for the Development of Tier 1 and ITAAC under 10 CFR Part 52,"11 provide a starting point for that effort. [emphasis added]
Would incorporating text along these lines do the trick?
Joe From:Habib,DonaldSent:Wednesday,April18,20189:57AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
Action/QuestionforPublicMeetingDiscussion(LAR17037)Joe -
I sent your question 3 to SNC because it was straightforward to convert it into a discussion topic.
For question 2, I did not send it because, now that I am looking at it closer, it needs to have a clearer nexus to the LAR.
In particular, the first principles document, as discussed in the question, addresses Tier 1 information while the LAR addresses Tier 2*. Based on this difference, it is immediately evident that there is a disconnect. Can you revise it to provide a clear connection? If we identify the connection, we could ask whether SNC considered it and, if so, how.
Thanks Don 106 Williams, Joseph From: Williams, Joseph Sent: Wednesday, April 18, 2018 11:17 AM To: Habib, Donald
Subject:
Revised ARPB RAI 2 Attachments:
Revised ARPB RAI 2.docx Don, What do you think of this revision?
Joe 107 Williams, Joseph From: Habib, Donald Sent: Wednesday, April 18, 2018 1:02 PM To: WASPARKM@southernco.com Cc: neil.haggerty@excelservices.com; Hoellman, Jordan; x2nhagge@southernco.com; Patel, Chandu; Dixon-Herrity, Jennifer; Amundso n, Theodore Edwin; Hicks, Thomas E.; Williams, Joseph; Jung, Ian; Zhao, Jack; Barss, Dan; Vogtle PEmails
Subject:
One More Additional Question for licensee on LAR 17-037Wes et al. - Below is the 3 rd and final discussion topic for tomorrow's public meeting related to LAR 17-037.
This email trail captures all 3 of the topics for LAR 17-037.
Thank you
Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035
Topic: Clarify the Use of Proposed Criterion 2 on Design Processes for I&C including Component Interface Module (CIM) and Diverse Actuation Systems (DAS)
Only the following five technical or topical reports, as a whole, are designated as Tier 2* items:
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-16097-P-A, "Common Qualified Platform," Rev. 0 WCAP-16096-NP-A, "Software Program Manual for Common Q Systems," Rev. 01A (1) The staff is not aware of any Tier 2* information for the DAS, including its design process. The staff notices that there is a discussion in the LAR of the DAS including "-this new criterion does not allow any material change to a design process" on Page 11 of 19. Is there any Tier 2* information in any of the WCAPs above for the DAS that the staff is not aware of?
(2) Does Criterion 2 also cover the design processes for the CIM? This clarification is helpful, although the CIM design process is briefly discussed in Tier 1 under the PMS description, WCAP-17179 indicates that the CIM interfaces with the PMS and other systems indicating that it is separate from the PMS. The staff understands that the CIM design process is different from that for the PMS.
108From:Habib,DonaldSent:Wednesday,April18,20189:47AMTo:'WASPARKM@southernco.com'<WASPARKM@southernco.com>Cc:'neil.haggerty@excelservices.com'<neil.haggerty@excelservices.com>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;'x2nhagge@southernco.com'<x2nhagge@southernco.com>;Patel,Chandu<Chandu.Patel@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;'Amundson,TheodoreEdwin'<X2TAMUNS@southernco.com>;'Hicks,ThomasE.'<X2TEHICK@southernco.com>;Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
RE:QuestionforlicenseeonLAR17 037,relatedtoemergencypreparedness(EP)Wes et al. -
Below is another additional topic regarding LAR 17-037 that the staff would like to address at the public meeting this Thursday:
Please advise if you can support the discussion topic.
Later today, I expect to send you additional topics related to that LAR for the public meeting.
Thanks
Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 TheLARstatesthattheproposedprocessis"functionallyconsistentwithdepartureevaluationprocessesappliedbycurrentapplicationsforthecertificationofdesignsthatcontainnoTier2*information."Thedepartureevaluationprocessdoesnotapplyuntiladesigniscertifiedandalicensereferencesthatce rtification,soitisnotclearwhatprocessSNCisreferringto,orwhytheclaimeds imilarityispertinenttothisplantspecificLAR.Further,designscurrentlyunderreviewdiffersignificantlyfromAP1000,withsubstantiallydifferentapproachestoensuringsafety,soprocessesthatmightapplytoonedesignmaynotberelevanttoanotherdesign.Therefore,SNCisrequestedtoidentifyanddescribetheprocessbeingrefe rredtoandit srelevancetotheLAR. From:Habib,DonaldSent:Wednesday,April18,20188:16AMTo:'WASPARKM@southernco.com'<WASPARKM@southernco.com
>Cc:'neil.haggerty@excelservices.com'<neil.haggerty@excelservices.com
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;'x2nhagge@southernco.com'<x2nhagge@southernco.com
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;'Amundson,TheodoreEdwin'<X2TAMUNS@southernco.com
>;Hicks,ThomasE.<X2TEHICK@southernco.com
>;Barss,Dan<Dan.Barss@nrc.gov
>
Subject:
QuestionforlicenseeonLAR17 037,relatedtoemergencypreparedness(EP)Wes et al. -
Below is a discussion topic the staff would like to address at the public meeting this Thursday, related to LAR 17-037.
Later today, I expect to send you additional topics related to that LAR for the public meeting.
Please advise if you can support the discussion topic.
109 Thanks Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 The AP 1000 DCD, in the introduction section, in Table 1-1, "Index of AP1000 Tier 2 Information Requiring NRC Approval for Change" identifies Tier 2 References 18.
8.2, 18.8.3.5, and 18.8.6. These references are to emergency preparedness items such as the location of the technical support center (TSC), TSC Interfaces, TSC Habitability, and other requirements for emergency response capabilities. Though these references point to the human factors sections where these items are addressed at a high level, more specific details are found in Section 13.3 of the Vogtle 3&4 UFSAR, and even more specifically in the site emergency plan which is a separate licensing document. Change to EP information is controlled by the requirements in 10 CFR 50.54(q). This section has criteria for what can and cannot be changed without prior NRC approval for EP matters.
How would EP matters, controlled by 10 CFR 50.54(q), screen out using the proposed screening criteria that LAR 17-037 proposes?
110 Williams, Joseph From: Habib, Donald Sent: Wednesday, April 18, 2018 1:10 PM To: Williams, Joseph
Subject:
Revised ARPB RAI 2.docx Attachments:
Revised ARPB RAI 2.docxJoe -
Was this intended to be for the public meeting? If so, please let me know. I made a minor edit assuming that was the case. Can you please look at it?
Or was this intended to be an RAI?
Thanks Don 111 Williams, Joseph From: Williams, Joseph Sent: Wednesday, April 18, 2018 1:14 PM To: Habib, Donald
Subject:
RE: Revised ARPB RAI 2.docx Don, I intended it for the public meeting. The edit looks OK to me.
Joe From:Habib,DonaldSent:Wednesday,April18,20181:10PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
RevisedARPBRAI2.docxJoe -
Was this intended to be for the public meeting? If so, please let me know. I made a minor edit assuming that was the case. Can you please look at it?
Or was this intended to be an RAI?
Thanks Don
113 Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>
Subject:
Tier2*LAR Attached is another RAI for LAR 17-037 that
Thanks Don From:Williams,JosephSent:Wednesday,April18,20188:19AMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Jung,Ian<Ian.Jung@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>
Subject:
SNCTier2*LARRevisedARPBRAI1Don, Per our conversation yesterday, here is a revised RAI reflecting your feedback. In addition to your comment suggesting we ask for identification of specific Tier 2* information considered to be Tier 1 equivalent, I added text requesting for a description of the methodology used to make that determination. A description of the method is important because it helps ensure the staff understands exactly what we are buying into. If we agree the method is good, then the staff can use it to better understand the potential outcomes. It also provides a basis for further discussion with SNC when there are discrepancies between their evaluation and
ours.
Joe
124 Williams, Joseph From: Habib, Donald Sent: Thursday, April 26, 2018 7:33 AM To:Bradford, Anna; Dixon-Herrity, Jennifer Cc:Taylor, Robert; Williams, Joseph
Subject:
RE: Revised ARPB RAI 1 4-25-18 to DNRL.docx Anna -
It is based principally on SECY-17-0075, and the discussion in the SECY about controls on Tier 1 and Tier 2*
information.
Don From:Bradford,AnnaSent:Wednesday,April25,20185:19PMTo:Habib,Donald<Donald.Habib@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>Cc:Taylor,Robert<Robert.Taylor@nrc.gov>
Subject:
RE:RevisedARPBRAI14 25 18toDNRL.docxAnd what is the regulatory basis for this RAI?
Anna H. Bradford Deputy Director Division of New Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1560
From:Habib,DonaldSent:Wednesday,April25,20184:00PMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>Cc:Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
RE:RevisedARPBRAI14 25 18toDNRL.docxAnna -
The intent of the RAI, I believe, is to provide more substance on the docket about why SNC's criteria are sufficient, based on the SNC identified in their submittal. The description of what they did is pretty high-level. The submittal states:
SNC performed an analysis of the Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c. The analysis examined each item in terms of the following criteria:
- Degree to which the Tier 2* information is not addressed in the following but meets Tier 1 inclusion criteria:
o VEGP 3 and 4 Plant-specific Tier 1 Design Control Document (DCD), or o VEGP 3 and 4 Combined License (COL), or o Applicable regulations, e.g., 10 CFR 50.46
- Degree to which Codes, standards, and design and qualification process, are relied upon for ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1 125DCD
- Safety-significance
- Degree to which 10 CFR Part 52, Appendix D, Section VIII.B.5 would effectively evaluate a Tier 2* departure
From there, SNC states that they identified the 4 criteria, and which are the substance of the LAR.
Don
From:Bradford,AnnaSent:Wednesday,April25,20183:15PMTo:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
RE:RevisedARPBRAI14 25 18toDNRL.docxJen and Don, Does this RAI make sense to you? It says to "provide a discussion of how the process described in the proposed amendment clearly differentiates between Tier 2* information with safety significance commensurate with Tier 1 and other information which does not warrant the same level of control."
Isn't the point of the entire LAR itself to explain this very point? I guess I'm not sure exactly what more we are asking SNC to provide to satisfy this RAI.
Anna H. Bradford Deputy Director Division of New Reactor Licensing U.S. Nuclear Regulatory Commission 301-415-1560 From:Dixon Herrity,JenniferSent:Wednesday,April25,201811:06AMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
FW:RevisedARPBRAI14 25 18toDNRL.docxAnna, here is the RAI from ARPB. Please let Don know if he can go ahead and forward it or if you see issues. Thank you, Jen From:Habib,DonaldSent:Wednesday,April25,201810:55AMTo:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>
Subject:
RevisedARPBRAI14 25 18toDNRL.docxJen -
This RAI has been and is ready for your/Anna's review.
Thanks 126 Don
128From:Habib,DonaldSent:Wednesday,April25,20184:39PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Taylor,Robert<Robert.Taylor@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>
Subject:
RE:RevisedARPBRAI14 25 18toDNRL.docxJoe - Please read the concern below, and my response. Do you want to add anything?Don From:Habib,DonaldSent:Wednesday,April25,20184:00PMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>;Dixon Herrity,JenniferJennifer.DixonHerrity@nrc.govCc:Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
RE:RevisedARPBRAI14 25 18toDNRL.docx Anna - The intent of the RAI, I believe, is to provide more substance on the docket about why SNC's criteria are sufficient, based on the SNC identified in their submittal. The description of what they did is pretty high-level. The submittal states: SNC performed an analysis of the Tier 2* matters listed in 10 CFR Part 52, Appendix D,Section VIII paragraphs B.6.b and B.6.c. The analysis examined each item in terms of thefollowing criteria:* Degree to which the Tier 2* information is not addressed in the following but meets Tier 1inclusion criteria:o VEGP 3 and 4 Plant-specific Tier 1 Design Control Document (DCD), oro VEGP 3 and 4 Combined License (COL), oro Applicable regulations, e.g., 10 CFR 50.46* Degree to which Codes, standards, and design and qualification process, are relied uponfor ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1DCD* Safety-significance* Degree to which 10 CFR Part 52, Appendix D, Section VIII.B.5 would effectively evaluatea Tier 2* departure From there, SNC states that they identified the 4 criteria, and which are the substance of the LAR. Don From:Bradford,AnnaSent:Wednesday,April25,20183:15PMTo:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
RE:RevisedARPBRAI14 25 18toDNRL.docxJen and Don, 129Does this RAI make sense to you? It says to "provide a discussion of how the process described in the proposed amendment clearly differentiates between Tier 2* information with safety significance commensurate with Tier 1 and other information which does not warrant the same level of control." Isn't the point of the entire LAR itself to explain this very point? I guess I'm not sure exactly what more we are asking SNC to provide to satisfy this RAI. Anna H. Bradford Deputy DirectorDivision of New Reactor LicensingU.S. Nuclear Regulatory Commission 301-415-1560 From:Dixon Herrity,JenniferSent:Wednesday,April25,201811:06AMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
FW:RevisedARPBRAI14 25 18toDNRL.docxAnna, here is the RAI from ARPB. Please let Don know if he can go ahead and forward it or if you see issues. Thank you, Jen From:Habib,DonaldSent:Wednesday,April25,201810:55AMTo:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>
Subject:
RevisedARPBRAI14 25 18toDNRL.docxJen - This RAI has been and is ready for your/Anna's review. ThanksDon 130 Williams, Joseph From: Bradford, Anna Sent: Thursday, April 26, 2018 8:31 AM To:Habib, Donald; Williams, Joseph Cc: Taylor, Robert; Dixon-Herrity, Jennifer; Segala, John; Monninger, John; Coyne, Kevin
Subject:
Re: Revised ARPB RAI 1 4-25-18 to DNRL.docx then I am ok with it. Thanks.
Anna H. Bradford Deputy Director Division of New Reactor Licensing
U.S. Nuclear Regulatory Commission 301-415-1560 On: 26 April 2018 08:28, "Habib, Donald" <
Donald.Habib@nrc.gov
> wrote: We had a few emails back and forth, with a number of comments and edits. In the end, the entire RAI was found acceptable, but I can get those emails, if needed. From:Bradford,AnnaSent:Thursday,April26,20188:21AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>Cc:Taylor,Robert<Robert.Taylor@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>
Subject:
Re:RevisedARPBRAI14 25 18toDNRL.docx Anna H. BradfordDeputy DirectorDivision of New Reactor LicensingU.S. Nuclear Regulatory Commission301-415-1560 On: 26 April 2018 07:33, "Williams, Joseph" <Joseph.Williams@nrc.gov> wrote:
132 Don From:Bradford,AnnaSent:Wednesday,April25,20183:15PMTo:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
RE:RevisedARPBRAI14 25 18toDNRL.docxJen and Don, Does this RAI make sense to you? It says to "provide a discussion of how the process described in the proposed amendment clearly differentiates between Tier 2* information with safety significance commensurate with Tier 1 and other information which does not warrant the same level of control." Isn't the point of the entire LAR itself to explain this very point? I guess I'm not sure exactly what more we are asking SNC to provide to satisfy this RAI. Anna H. Bradford Deputy DirectorDivision of New Reactor LicensingU.S. Nuclear Regulatory Commission 301-415-1560 From:Dixon Herrity,JenniferSent:Wednesday,April25,201811:06AMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>Cc:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
FW:RevisedARPBRAI14 25 18toDNRL.docxAnna, here is the RAI from ARPB. Please let Don know if he can go ahead and forward it or if you see issues. Thank you, Jen From:Habib,DonaldSent:Wednesday,April25,201810:55AMTo:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>
Subject:
RevisedARPBRAI14 25 18toDNRL.docxJen - This RAI has been and is ready for your/Anna's review. ThanksDon 133 Williams, Joseph From: Habib, Donald Sent: Friday, April 27, 2018 10:26 AM To: WASPARKM@southernco.com Cc: Patel, Chandu; ptapscot@southernco.com; Chamberlain, Amy Christine; Vogtle PEmails; Dixon-Herrity, Jennifer; Williams, Joseph; Amundson, Theodore Edwin; Hicks, Thomas E.; x2nhagge@southernco.com; neil.hagger ty@excelservices.com; Segala, John
Subject:
Draft RAI Related to Vogtle Units 3 and 4 LAR 17-037 Regarding Tier 2* Departure Process Attachments:
ARPB - RAI_9544 for LAR 17-037 Draft to SNC.docx Categories:
Red Category To All -
Attached is a draft RAI related to Vogtle Units 3 and 4 LAR 17-037 regarding the Tier 2* departure process.
If you would like to schedule a clarification conference call to discuss this RAI, please let me know before Noon on Wednesday, May 2, 2018. If no request for a conference call is received, this RAI will be issued as final.
Don Habib Project Manager NRO/DNRL, Licensing Branch 4
301-415-1035 134 Williams, Joseph From: Habib, Donald Sent: Monday, April 30, 2018 10:40 AM To:Barss, Dan; Williams, Joseph; Zhao, Jack Cc: Hoellman, Jordan
Subject:
For Review: Input to Summary of Ap ril 19 2018 Public Meeting - LAR 17-037Dan, Joe, and Jack -
Please review and edit the information below that is to be included in the meeting summary of the April 19, 2018, public meeting.
Thanks Don The third topic discussed involved three discussion topics related to LAR 17-037-emergency planning (EP), the overall process to be used by the licensee, and instrumentation and control.
EMERGENCY PLANNING.
Regarding the Emergency Planning (EP) discussion topic, the question posed to the licensee was: how would emergency plan changes, controlled by 10 CFR 50.54(q),
screen out using the proposed screening criteria that LAR 17-037 proposes? SNC indicated that proposed changes are first screen through an "applicability determination process" to identify appropriate requirements that would apply to the intended changes. Through this screening, items related to EP would be determined to be governed by 10 CFR 50.54(q) and the applicable site process for such EP changes would be used, and not the proposed screening process in LAR 17-037 for Tier 2*
items. The staff noted that SNC's response clarified how emergency plan changes would be screened and handled using existing licensee processes to identify the applicable regulatory requirements of 10 CFR 50.54(q), for such EP changes and not the screening criteria that LAR 17-037 proposes. The staff had no additional questions on this discussion topic.
TIER 2* PROCESS.
Regarding how the process proposed in LAR 17-037 is consistent with the process being used for current applications for design ce rtifications that contain no Tier 2* information, SNC indicated that the language used in the LAR could be more clear and noted that the intention of the statement is that the outcomes of applying the proposed processes, whatever the processes would
be, would result in similar outcomes for information of safety significance that requires NRC approval. The staff noted that they understood SNC's response, but noted that the statement in the submittal is confusing and cannot be used by the staff to support its safety finding. The staff noted that it would consider whether a request for additional information (RAI) is necessary.
I&C. Regarding the instrumentation and controls (I&C) discussion topic, the staff asked about how the design processes for the Diverse Actuation Systems (DAS) and Component Interface Module (CIM) would be addressed under the proposed license condition proposed in LAR 17-037. SNC noted that (1) the DAS was addressed in AP1000 Tier 1 information, and (2) SNC had considered the CIM to be part of the Protection and Safety Monitoring System (PMS), which they had previously identified as a design process covered by the license condition. The staff responded that it would proceed to issue this question as an RAI. Thanks!Jordan 135
136 Williams, Joseph From: Habib, Donald Sent: Tuesday, May 01, 2018 12:32 PM To: Williams, Joseph
Subject:
RE: Revised ARPB - RAI_9544 for LAR 17-037 Draft to SNCLooks good. Thanks!
From:Williams,JosephSent:Tuesday,May01,201810:55AMTo:Habib,Donald<Donald.Habib@nrc.gov>
Subject:
RevisedARPBRAI_9544forLAR17 037DrafttoSNCDon, Edits in redline/strikeout in the attached file. Look OK to you?
Joe 137 Williams, Joseph From: Habib, Donald Sent: Thursday, May 03, 2018 11:29 AM To:Zhao, Jack; Williams, Joseph; Green, Brian Cc:Jung, Ian; Segala, John; Kent, Lauren; Dixon-Herrity, Jennifer; Bradford, Anna
Subject:
Final RAIs issued for Vogtle Tier 2* LAR (ML18121A437)
Categories:
Red Category Jack, Joe, and Brian -
Here is the ADAMS link for the Final RAIs we issued (ICE, ARPB, HOIB, LB4).
As a result of the clarification call about the HOIB, ARPB, and LB4 draft RAIs, we proceeded to issue the final RAIs. (Note that SNC did not request a clarification on the ICR draft RAI.)
The ICE and HOIB RAIs are unchanged from the drafts. The ARPB and LB4 RAIs incorporate revisions discussed in the clarification call.
I'll keep you appraised on the receipt of any draft or final responses.
Don
View ADAMS Properties ML18121A437 Open ADAMS Document (2018/05/01 Vogtle COL Docs - RAI Transmittal for Vogtle 3 and 4 LAR 17-037 (RAI LAR 17-037-5, -6, -7, and -8))
138 Williams, Joseph From: Habib, Donald Sent: Friday, May 04, 2018 3:16 PM To: Williams, Joseph
Subject:
RE: Tier 2* Policy QuestionJoe -
Regarding the Fred Brown briefing, my understanding is that, once we make a decision about approving (or not approving) the LAR, then we'll schedule a briefing with Fred to discuss how the decision will be communicated to the Commission, and I will definitely include you in that.
As for the relationship between NEI First Principles and the LAR, I recall (vaguely) we discussed it at the public teleconference you attended, but I can't recall the details. I would need to check my notes. I should also mention that Frank AZ mentioned it at the public meeting yesterday, but there was not a substantive discussion on that topic. Frank just to advised Russ Bell that NRC was looking forward to the next interaction with NEI to make progress on that front. Something like that . . .
Please call me if you wish to discuss.
Thanks Don From:Williams,JosephSent:Friday,May04,20182:46PMTo:Habib,Donald<Donald.Habib@nrc.gov>
Subject:
RE:Tier2*PolicyQuestionDon, Any update regarding a briefing to address the policy issues?
Also, I've lost track of where we are going with the RAI I wrote regarding examples of how the criteria would for all Tier 2* amendments. I've also lost track of whatever is planned regarding the relationship between the NEI First Principles and the LAR; it's my recollection we planned to discuss that in a public meeting.
Joe From:Habib,DonaldSent:Wednesday,April25,20182:02PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
RE:Tier2*PolicyQuestionWill do! From:Williams,JosephSent:Wednesday,April25,20181:17PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>
Subject:
RE:Tier2*PolicyQuestion 139Don, Please keep me informed of plans for briefing Fred, and include me in the invitation. I'd also like to know if there has been any discussion with him about the policy question beforehand.
Joe From:Habib,DonaldSent:Wednesday,April25,201812:49PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>
Subject:
RE:Tier2*PolicyQuestionJoe -
I deferred the meeting with Fred because I wasn't clear what our briefing message would be. However, this was my action and, though my management has not been pressing me for the meeting, I need to follow up with them. And if appropriate, get something on Fred's calendar in the near term.
Don From:Williams,JosephSent:Wednesday,April25,201812:43PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
RE:Tier2*PolicyQuestionDon, Based upon the discussion with Frank, et al., several weeks ago, it was my understanding that a briefing for Fred would be scheduled to solicit an office-level decision. I will be very disappointed if DNRL has changed its mind and now plans to proceed without thoroughly vetting the policy question. Is that the case?
Joe From:Habib,DonaldSent:Wednesday,April25,201810:28AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
RE:Tier2*PolicyQuestionJoe -
I sense we are moving in the direction of approving this LAR, but it is too early to tell. We are not there yet.
I see the approval decision as tied to the preparation of the SER, and expect that to begin (for me) in late May.
At least, that is my current thinking.
Thanks Don From:Williams,JosephSent:Wednesday,April25,20189:43AM 140 To:Habib,Donald<Donald.Habib@nrc.gov
>
Subject:
Tier2*PolicyQuestionDon, When do you plan to address the question regarding the need to write a Commission paper regarding the
LAR?
Joe 141 Williams, Joseph From:Monninger, John Sent: Monday, May 14, 2018 11:40 AM To:Williams, Joseph; Segala, John; Coyne, Kevin
Subject:
RE: Decision Regarding Ti er 2* Commission Paper Categories:
Red Category Joe, Thanks for flagging the issue. I believe last week you mentioned the forthcoming meeting with Fred, and I was under the impression you were attending. Can you drop by to provide any additional insights you have on the meeting (who attended, agenda, topics discussed)?
- Thanks, John From:Williams,JosephSent:Monday,May14,201811:13AMTo:Segala,John<John.Segala@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>
Subject:
DecisionRegardingTier2*CommissionPaperImportance:HighI had a message from Don Habib where he informed me that Anna Bradford had a conversation with Fred Brown about how to engage the Commission on issues associated with the Vogtle Tier 2* LAR. Don tells me that Fred has decided to conduct a CA briefing, as opposed to writing a Commission paper on the topic. Fred was apparently informed that some staff could have concerns about this decision, and he replied that they are free to communicate with him via the Open Door policy.
I am very disappointed in how this topic has been handled. In cases where I identified specific potential policy questions many months ago, I shouldn't have to use the Open Door policy to bring those issues to my management's attention and express my views in my own words on an equal footing. DNRL staff and management were well aware of my concerns, and well aware of my interest in participating in any management discussion. I have been extremely patient awaiting an opportunity to engage office level management on this topic. That patience has been rewarded with an end run discussion where I have no confidence my views were fairly represented.
This episode is a prime example of a cultural issue along the lines of what I tried to describe at the DSRA all hands meeting last week. It is frankly a high-handed management approach, deeply disrespectful of staff views. It is contrary to our values of openness and cooperation, and inconsistent with Speed of Trust principles we are supposedly embracing.
I am considering how I'm going to respond to this decision and the associated process, and welcome any feedback you may have.
Thanks. Joe 142 Williams, Joseph From: Hoellman, Jordan Sent: Thursday, May 17, 2018 4:32 PM To:Williams, Joseph; Van Wert, Christopher; Nolan, Ryan; Green, Brian Cc:Segala, John; Karas, Rebecca; Kent, Lauren; Habib, Donald; Patel, Chandu; Dixon-Herrity, Jennifer
Subject:
FW: Draft RAI responses for LAR-17-037, Chan ges to Tier 2* Departure Evaluation Process Attachments:
RAI LAR 17-037-5_eRAI 9514_HOIB (Draft to NRC-051718).pdf; RAI LAR 17-037-6_eRAI 9542_LB4 (Draft to NRC-051718).pdf; RAI LAR 17-037-7_eRAI 9544_ARPB (Draft to
NRC-051718).pdf; RAI LAR 17-037-9_eRAI 9524_SRSB (Draft to NRC-051718).pdf Follow Up Flag:Follow up Due By: Tuesday, May 29, 2018 8:00 AM Flag Status:
Completed Joe,Chris,Ryan,andBrian-PleaseseeSNC'sdraftRAIresponsestoyourRAIsforVogtleLAR17 037.WearescheduledtodiscussthesedraftRAIresponsesduringnextweek'spublicmeetingonMay24 thfrom9am 12pm(youshouldhavealreadyreceivedthescheduler).
PleasereviewthedraftresponsesandletmeknowifthedraftresponsesaddressyourRAIquestionsoryouhaveanyconcerns.Ifyouhaveanyquestions,pleaseletmeknow.Thankyou,Jordan
From:Haggerty,Neil[2]Sent:Thursday,May17,20184:19PMTo:Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>Cc:Habib,Donald<Donald.Habib@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;Sparkman,WesleyA.<WASPARKM@southernco.com>;Aughtman,AmyG.<AGAUGHTM@SOUTHERNCO.COM>;Amundson,TheodoreEdwin<X2TAMUNS@southernco.com>;Hicks,ThomasE.<X2TEHICK@southernco.com>;Redd,JasonP.<JPREDD@southernco.com>
Subject:
[External_Sender]DraftRAIresponsesforLAR 17 037,ChangestoTier2*DepartureEvaluationProcessJordan, 143 The attached draft responses are provided for Staff revi ew. These are in response to RAIs issued by the staff to support their review of LAR-17-037, Changes to Tier 2*
Departure Evaluation Process.
Please provide these response to the appropriate st aff to allow their review in advance of next Thursday's Public meeting/call.
If the staff reviewers find that the response is sufficient to allow their review to continue, please provide this feedback to us, and we exclude it fr om the list of topics to be discussed in next Thursday's meeting/call.
I will likely have one or two more draft RAIs to provide to you in the next couple of days.
Please let me know if you have any questions or comments regarding t hese draft responses. Thank you, Neil Haggerty NeilHaggertylSouthernNuclearOperatingCompanyNuclearDevelopmentRegulatoryAffairs-VEGP3&4LicensingSNCInverness:205.992.7047loffice:301.874.8537lmobile:240.566.2442x2nhagge@southernco.comneil.haggerty@excelservices.comThis e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and may contain proprietary and confidential information. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.
144 Williams, Joseph From: Habib, Donald Sent: Thursday, May 31, 2018 1:30 PM To:Green, Brian; Williams, Joseph; Lupold, Timothy; Hoellman, Jordan
Subject:
Action/Review: Tier 2* LAR: Summa ry of 5/31 Public Meeting Discussion Tim, Joe, and Brian -
For the 5/31 public meeting regarding Tier 2* matters, please review the material below which I propose to include in the meeting summary. Please reply with any changes, and include a cc to Jordan Hoellman.
The staff discussed three aspects of SNC's LAR 17-037:
Code Compliance. The staff made general remarks about the how future code alternatives should be handled in light of potential approval of LAR 17-037. The staff does not object to making the reference to the code material Tier 2 from Tier 2*, but we want to emphasize that if SNC intends to deviate from ASME Section III code requirements, then it will need to follow the process established in 10 CFR 50.55a for alternatives and relief requests, and not apply the 50.59 like process. The language in the supplemental RAI response related to the example using the words "adverse" raises a concern. In the instance used, this would be associated with the B31.1 Code, which does not fall under the purview of 10 CFR 50.55a. In this case, while using the 50.59 like process to deviate would be acceptable, this approach would not be the same for ASME Section III, where the 10 CFR 50.55a regulations would apply.
RAI 17-037-7 Draft Response. The staff provided feedback on SNC's 5/22 draft response to RAI 17-037-7. In response, SNC indicated it planned to revise and resend a draft response to NRC that would address the following items: 1. How SNC's application of guidance regarding a "material change" under Criteria 2 and 3 would ensure information with safety significance commensurate with Tier 1 is not modified without prior NRC approval. 2. An explanation of the basis for how the guidance for Criteria 1, 2, and 3 achieves consistency. 3. How the criteria determine the safety significance of a change
- 4. How the LAR conforms to or deviates with justification from Commission-approved positions in SECY papers, including SECYs90-241, 90-377, and 95-023 5. How proposed future changes to Tier 2* information could be determined to be safety significant at this time without knowing what the future changes would be SNC also advised that (1) the analysis identified as underlying the LAR was not a formal analysis that is auditable, and (2) the draft response information for RAI 17-037-7 represents a clarification of and not a revision to the original LAR.
RAI 17-037-5 (human factors engineering) Draft Response. The staff provided feedback on SNC's 5/22 draft response to RAI 17-037-5. In response, SNC indicated it planned to revise and resend a draft response to NRC that would clarify the bullet referring to "final safety evaluation report" referred to all applicable safety evaluation reports, including those for the AP1000 DCD and Vogtle ESP and COLs, and any applicable LARs.
The staff indicated that it may have further feedback on other aspects of SNC's 5/22 draft response.
145 Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 146 Williams, Joseph From: Williams, Joseph Sent: Thursday, May 31, 2018 2:24 PM To: Habib, Donald; Green, Brian; Lupold, Timothy; Hoellman, Jordan Cc: Segala, John
Subject:
RE: Action/Review: Tier 2* LAR: Su mmary of 5/31 Public Meeting Discussion Don, Some suggested edits shown below.
There was one minor editorial item that I missed this morning. On page 4, in the paragraph that starts "Regarding Enclosure 5," the next-to-last line says "-was not necessary or appropriate." I recommend deleting "or appropriate." That word doesn't add anything, in my opinion, and is a little gratuitous. It's sufficient for the purposes of the LAR to just say "was not necessary." I can address that item when we discuss the revised response, unless you want to pass it along beforehand.
It troubles me that there doesn't seem to be a good paper trail for the analysis SNC describes, as that documentation could have been useful to better understand how the various Tier 2* matters were dispositioned and the additional screening criteria developed.
Joe From:Habib,DonaldSent:Thursday,May31,20181:30PMTo:Green,Brian<Brian.Green@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Lupold,Timothy<Timothy.Lupold@nrc.gov>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>
Subject:
Action/Review:Tier2*LAR:Summaryof5/31PublicMeetingDiscussionTim, Joe, and Brian -
For the 5/31 public meeting regarding Tier 2* matters, please review the material below which I propose to include in the meeting summary. Please reply with any changes, and include a cc to Jordan Hoellman.
The staff discussed three aspects of SNC's LAR 17-037:
Code Compliance. The staff made general remarks about the how future code alternatives should be handled in light of potential approval of LAR 17-037. The staff does not object to making the reference to the code material Tier 2 from Tier 2*, but we want to emphasize that if SNC intends to deviate from ASME Section III code requirements, then it will need to follow the process established in 10 CFR 50.55a for alternatives and relief requests, and not apply the 50.59 like process. The language in the supplemental RAI response related to the example using the words "adverse" raises a concern. In the instance used, this would be associated with the B31.1 Code, which does not fall under the purview of 10 CFR 50.55a. In this case, while using the 50.59 like process to deviate would be acceptable, this approach would not be the same for ASME Section III, where the 10 CFR 50.55a regulations would apply.
RAI 17-037-7 Draft Response. The staff provided feedback on SNC's 5/22 draft response to RAI 17-037-7. In response, SNC indicated it planned to revise and resend a draft response to NRC that
would address the following items:
1471. How SNC's application of guidance regarding a "material change" under Criteria 2 and 3 would ensure information with safety significance commensurate with Tier 1 is not modified without prior NRC approval. 2. An explanation of the basis for how the guidance for Criteria 1, 2, and 3 achieves consistency. 3. How the criteria SNC determines "safety significance" as described in the LAR, including how it was determine d that changes to a set of Tier 2* information would not have the safety significance of a change commensurate with a change.
- 4. How the LAR conforms to or deviates with justification from Commission-approved positions in SECY papers, including SECYs90-241, 90-377, and 95-023. SNC was advised that a publicly-available ADAMS package providing design certification regulatory history documents (ADAMS accession number ML003761550) would be a useful reference.
- 5. How proposed future changes to Tier 2* information could be determined to be safety significant at this time without knowing what the future changes would be How it was determined that unknown future changes to a set of Tier 2* information do not have safety significance commensurate with a change to Tier 1 without knowing what the future changes will be.
SNC also advised that (1) the analysis identified as underlying the LAR was not a formal analysis that is auditable, and (2) the draft response information for RAI 17-037-7 represents a clarification of and not a revision to the original LAR.
A representative of the Nuclear Energy Institute acknowledged the relationship between the proposed LAR and ongoing efforts regarding the Tier 1 "First Principles," noting that that effort has effects beyond the scope of this LAR.
RAI 17-037-5 (human factors engineering) Draft Response. The staff provided feedback on SNC's 5/22 draft response to RAI 17-037-5. In response, SNC indicated it planned to revise and resend a
draft response to NRC that would clarify the bullet referring to "final safety evaluation report" referred to all applicable safety evaluation reports, including those for the AP1000 DCD and Vogtle ESP and COLs, and any applicable LARs.
The staff indicated that it may have further feedback on other aspects of SNC's 5/22 draft response.
Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 148 Williams, Joseph From: Williams, Joseph Sent: Tuesday, June 05, 2018 8:22 AM To: Habib, Donald
Subject:
RE: Questions on Feedback on Tier 2*
Don, Nothing to add beyond the feedback I've already provided.
We have an advanced reactor public stakeholder meeting on the 14 th where I'm leading a presentation on environmental reviews, so I won't be available to discuss the revised draft response until the week of the
18 th. I'll be out of the office the following two weeks, so if that date doesn't work, it will be July before we can discuss it.
Separately, can you tell me what happened to my RAI regarding examples?
Joe From:Habib,DonaldSent:Monday,June04,20181:01PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
QuestionsonFeedbackonTier2*Joe - 1. Do you have any additional feedback to SNC on their Tier 2* draft submittal?
If so, please provide it to me by tomorrow.
SNC plans to provide an updated draft response to us on ~Thursday, June 7, and would like to have our feedback on the second submittal on June 14. This is to ensure that everything known to date is incorporated into the June 7 draft.
- 2. Will this schedule work for you?
Don Habib Project Manager NRO/DNRL, Licensing Branch 4
O-8D13 301-415-1035 149 Williams, Joseph From: Williams, Joseph Sent: Wednesday, June 13, 2018 1:28 PM To: Cc: Segala, John
Subject:
RE: Reply Requested: Schedule for Comp letion of SER for Vogtle Tier 2* LAR (Tentative)
Attachments:
RE: Schedule for Issuing RA Is for Vogtle LAR 17-037 ; ARPB RAIs 4-11 PM Comments-More.docx I've looked through my email and I haven't found any feedback regarding the 4 th RAI I provided in the attached message on April 11. A markup you provided on April 16 (also attached) provided feedback that RAIs 2 and 3 would be better addressed as public meeting discussion topics. I agreed with that approach. Your markup also provided feedback regarding RAI 1, and we exchanged several messages regarding that item to before that RAI was issued. However, no feedback was received regarding RAI 4, so action is needed to issue that RAI, as well.
Regarding completing the SE, it is difficult to commit to a completion schedule without having a better idea of what's expected. For instance, what is the table of contents/outline with review responsibilities? What are the acceptance criteria staff are supposed to use?
Joe From:Sent:Monday,June11,201810:26AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>;Cc:
Subject:
ReplyRequested:ScheduleforCompletionofSERforVogtleTier2*LAR(Tentative) Below is the tentative schedule for completion of the SE for the Tier 2* LAR, under the scenario that the staff approves the LAR. More specific dates will be given when we get submittal dates from SNC.
Staff provides SE inputs to LB4: RAI response + 3 weeks LB4 combines SER inputs and puts document into concurrence: + 2 weeks after last SE input Concurrence completed and SE issued: + 6 weeks For your SE input, I will get guidance out to you as soon as I can, but in general you should try to address the substantive issues in your RAIs.
Please reply to let me know if this is reasonable for you, or if you think this will be a challenge, or if you have any questions.
151 Williams, Joseph From: Sent: Wednesday, June 13, 2018 3:04 PM To: Williams, Joseph Cc: Segala, John
Subject:
RE: Reply Requested: Schedule for Comp letion of SER for Vogtle Tier 2* LAR (Tentative)Joe -
I also looked through my email, and I could not find a record of why we did not process question number 4. However, I will keep looking.
From:Williams,JosephSent:Wednesday,June13,20181:28PMTo:Cc:Segala,John<John.Segala@nrc.gov>
Subject:
RE:ReplyRequested:ScheduleforCompletionofSERforVogtleTier2*LAR(Tentative) I've looked through my email and I haven't found any feedback regarding the 4 th RAI I provided in the attached message on April 11. A markup you provided on April 16 (also attached) provided feedback that RAIs 2 and 3 would be better addressed as public meeting discussion topics. I agreed with that approach. Your markup also provided feedback regarding RAI 1, and we exchanged several messages regarding that item to before that RAI was issued. However, no feedback was received regarding RAI 4, so action is needed to issue that RAI, as well.
Regarding completing the SE, it is difficult to commit to a completion schedule without having a better idea of what's expected. For instance, what is the table of contents/outline with review responsibilities? What are the acceptance criteria staff are supposed to use?
Joe From:Sent:Monday,June11,201810:26AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Cc:
Subject:
ReplyRequested:ScheduleforCompletionofSERforVogtleTier2*LAR(Tentative)
153 Williams, Joseph From: Coyne, Kevin Sent: Monday, June 18, 2018 9:42 AM To: Bradford, Anna Cc:Monninger, John; Segala, John
Subject:
Tier 2* LAR for Vogtle Attachments:Tier 2* RAIs Importance:High ADAMSAccessionNumber:
ML18248A040 ADAMSVersionSeriesId:
{5B70B32F-3349-4F36-B621-25A20F0CF712}
Hi Anna -
John and I circled back with Joe following our conversation on Friday. Joe will be reaching out to Don Habib, but I wanted to give you a heads up on the issues Joe is concerned with:
It would be good if SNC was prepared to talk about both (1) Joe's RAI (on how their method comports with previous Commission guidance on Tier 2*) and (2) how the various examples provided with the application were selected and if they fully address the method that SNC is proposing to apply to Tier 2*
information. The second issue is basically Joe's 4 th RAI that was not issued but instead was deferred to a public meeting discussion. I've attached an early version of Joe's questions for reference - my understanding is that only the first one was issued with some modifications; questions 2 and 3 were discussed at a previous public meeting (though there may still be some need for additional dialogue), and question #4 on the examples in the LAR fell off the radar and is still awaiting discussion (and we hope this can be added to Thursday's agenda). Since Joe will be out of the office for two weeks starting on Friday, it would be best if we could cover both SNC's approach on the RAI as well as a discussion of the LAR examples. However, Joe would need any materials SNC intends to reference ahead of time (i.e., within the next day) in order to adequately prepare for the discussion.
We still need alignment on the overall basis for the staff's regulatory finding on the LAR. Joe has some thoughts, so it would be good if Don and other key parties could meet this week to try to make headway on what ultimately would be the basis for approving the LAR (e.g., what would the conclusion of the SE ultimately state). One of the main issues is that we still lack objective guidance on what constitutes Tier 1 information - this ultimately is what the Vogtle LAR should be protecting (in other words, in order for the process laid out by SNC to protect Tier 1 equivalent information, we need to have a shared, objective understanding of what Tier 1 information is). This was a "to do" item noted in SECY 17-0075, but since this LAR has moved ahead of the queue, we need to make sure whatever precedent we set with this amendment will be consistent with our ultimate thinking of what is Tier 1 information.
As noted, Joe will be reaching out to Don, but I wanted to put this on your radar since it looks like a number of things need to fall into place this week to make headway on Joe's issues.
Thanks!
Kevin 154 Williams, Joseph From: Williams, Joseph Sent: Monday, June 18, 2018 2:34 PM To:Monninger, John; Coyne, Kevin
Subject:
Fwd: Status: Follow-Up on ARPB RAI John and Kevin,
FYI.
Joe From:
Subject:
RE: Status: Follow-Up on ARPB RAI Date: 18 June 2018 14:00 To: "Williams, Joseph" <Joseph.Williams@nrc.gov
> Cc: Joe - Following is helpful information on the path forward: SNC advised that they would be able to discuss the other Tier 2* evaluations they have performed at the public meeting on 6/21. This is intended to address the ARPB question #4. SNC also advised that they plan to provide a formal response (rather than another draft) that would respond to a number of RAIs, including yours, updated based on verbal feedback we gave them at previous public meetings. The soonest we would receive this is COB today. I will keep you appraised of its receipt. After we receive the SNC response and you have had a chance to look at it, you can update me on whether further discussion with SNC is needed. Delaying until early/mid-July may impact the overall project schedule, so please work with your management to consider options for how work can proceed while you are out of the office. Thanks From:Williams,JosephSent:Monday,June18,201810:07AMTo:Cc:
Subject:
RE:Status:Follow UponARPBRAI 155My notes from the May 31 meeting indicate that, to respond to the first ARPB RAI, SNC agreed to comprehensively examine the set of relevant Commission correspondence and update their response to describe how their proposal is consistent with Commission-approved staff positions, or why deviation from those positions is acceptable. SNC also agreed to revisions to address aspects of the RAI which weren't included in their original draft. I need their revised draft response by the end of the day today so that I have
adequate time to prepare for the meeting Thursday. Preparation is not a trivial task. To give you an idea of the scope of information involved, the three Commission papers I mentioned at the meeting total over 400 pages. As I said at the meeting, those three items aren't the only correspondence to consider. I will not be able to support a meeting this week if SNC's feedback is not available by COB today. I also need to know by the end of the day today if the agenda will include discussion of the fourth ARPB RAI. If so, I also need any documentation SNC plans to use by COB today. If the fourth RAI is not going to be discussed this week, my first availability will be after I return to the office the week of July 9. Regarding "the appropriate time to address" the fourth RAI, there's nothing in the record indicating any concern from DNRL/DLSE that would preclude issuing that question, so it was reasonable for me to assume it would be issued. I don't wish to sound defensive, but I think it's important for you to understand my view. There has been a lot of confusion and miscommunication regarding many aspects of this LAR review, not just the RAIs. Going forward, I plan to document our verbal discussions in an email to to be sure we have a common understanding of the outcomes. I talked this morning with John Monninger and Kevin Coyne regarding their conversation with Anna Bradford. It is my understanding from that discussion that DLSE plans to solicit my assistance to develop guidance for completing the safety evaluation. My availability this week is somewhat limited, especially if I need to spend time to prepare for the Thursday meeting, so please let me know as soon as possible if you want to plan that discussion within the next few days. I'm going to be in a meeting most of the rest of the day, so email may be the best way to contact me. Joe From:Sent:Friday,June15,20187:49AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:
Subject:
RE:Status:Follow UponARPBRAIJoe - To clarify, I understood that our interaction on June 21 was originally intended for SNC to give feedback to us about the other screening evaluations they may have done. If we receive their response in time such that you have an opportunity to provide feedback on June 21, that would be ideal. SNC advised yesterday that they thought they would provide their formal response "midweek," so it is possible that can occur. Thanks From:Williams,JosephSent:Friday,June15,20187:36AMTo:Cc:
Subject:
RE:Status:Follow UponARPBRAI 156 I'm available on June 21, assuming I receive the revised draft response by COB Monday so I have adequate time to prepare for the discussion. I'm out of the office for two weeks starting June 25, returning on July 9. I spoke to Kevin Coyne and John Monninger about the RAI. Kevin said he intended to talk to Anna Bradford about it. I don't know if he has had an opportunity to do so yet. I'm on my way to an advanced reactor meeting at EPRI's offices in DC today. I'll be back in the office Monday. Joe From:Sent:Wednesday,June13,20183:58PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:
Subject:
Status:Follow UponARPBRAIJoe - I found no record in my emails of how the ARPB question 4 was dispositioned. I recall that whe n we discussed it ~1 week ago, we decided to handle it as a public meeting discussion topic. Prior to that, my memory is fuzzy. However, the question 4 must have been dispositioned in some fashion long ago because it was not included in the ARPB RAI that was issued on May 1. That would have been the appropriate time to address it. If you want to pursue this question as an RAI at this time, it would need to be escalated to the division
director level.
As we discussed, I identified this question to SNC at last Friday's public meeting as a topic that we would like SNC to discuss at a future public meeting (i.e., the next one that you are available to attend), and SNC was agreeable to this. SNC can speak to this, but their preliminary comments at the public meeting suggested that they did not have detailed evaluations prepared for other Tier 2* changes. I believe that the question #4 should only proceed as an RAI if the response would be needed to come to an approval decision on the LAR, and that connection is not apparent to me. Let's discuss when you have a chance. Also, can you please remind me which public meeting you will be able to attend? I recall it was on 6/21, but I'm not sure.
Thanks From:Sent:Wednesday,June13,20183:04PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:
Subject:
RE:ReplyRequested:ScheduleforCompletionofSERforVogtleTier2*LAR(Tentative)Joe - I also looked through my email, and I could not find a record of why we did not process question number 4. However, I will keep looking.
159 Williams, Joseph From: Habib, Donald Sent: Monday, June 18, 2018 8:17 PM To: Williams, Joseph Cc:Dixon-Herrity, Jennifer; Patel, Chandu
Subject:
Fw: FW: General Form Submission (24095) Received Attachments:
ND-18-0646_LAR-17-037S3_RAI_FINAL.pdf JoeAttachedistheSNCsubmittalthatincludestheirresponsetoyourRAI.Let'sdiscussthepathforwardsometimeonTuesday.MygoalisforyoutodeterminetheacceptabilityoftheirresponseintimetoprovidethemfeedbackbythisThursday'spublicmeeting.
ThanksDonFrom:Haggerty,Neil<X2NHAGGE@SOUTHERNCO.COM>Sent:Monday,June18,20187:28PMTo:Habib,DonaldCc:Patel,Chandu;Sparkman,WesleyA.;Aughtman,AmyG.;Amundson,TheodoreEdwin;Hicks,ThomasE.
Subject:
[External_Sender]FW:GeneralFormSubmission(24095)Received
- Don, Asdiscussed,SNCletterND 18 0646(LAR 17 037S3)isattached.IthasbeenassignedADAMSAccessionNumber[ML18169A431].
ThisletterprovidesthefinalresponsestoRAIs LAR 17 037 5(HOIB), LAR 17 037 6(NRO LB4), LAR 17 037 7(ARPB), LAR 17 037 8(ICE),and LAR 17 037 9(SRSB).
Pleasecontactme,oranyofthoseondistribution,ifyouhaveanyquestionsregardingtheinformationinthisletter.
Thankyou,NeilHaggerty__________________
________________NeilHaggertylSouthernNuclearOperatingCompanyNuclearDevelopmentRegulatoryAffairs-VEGP3&4Licensing 160 SNC Inverness:205.992.7047loffice:301.874.8537lmobile:240.566.2442x2nhagge@southernco.comneil.haggerty@excelservices.comThise mailandanyattachmentstheretoareintendedonlyfortheusebytheaddressee(s)namedhereinandmaycontainproprietaryandconfidentialinformation.Ifyouhavereceivedthisemailinerror,pleaseimmediatelynotifymebytelephoneandpermanentlydeletetheoriginalandanycopyofanye mailandanyprintoutthereof.
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Subject:
FW:GeneralFormSubmission(24095)Received ML#forND 18 0646 OriginalMessage From:mshd.resource@nrc.gov[3]Sent:Monday,June18,20185:37PMTo:Spears,LisaJ.<LJSPEARS@southernco.com>
Subject:
GeneralFormSubmission(24095)ReceivedTheNRCreceivedyourGeneralFormsubmissionon:06/18/2018at06.37PM.ItisbeingtrackedassubmissionID#24095.
Ifitisa'PubliclyAvailable'submissionafter6workdaysfromtodaythesubmission'sattacheddocument(s)willbeavaila bleforviewinganddownloadfromtheAgency'sPublicWebBasedADAMSwebsite(https://urldefense.proofpoint.com/v2/url?u=http3A__adams.nrc.gov_wba&d=DwICAg&c=AgWC6Nl7Slwpc 9jE7UoQH1_Cvyci3SsTNfdLP4V1RCg&r=59zh6cGZFmOoYcVGpTyyDXJBpmT8lY6q7sRimpsrSGI&
m=TEPAwCdgyGF4Kzu8LGMp_SXTZ9sK90HD_A aRDhsS4&s=oal5HwdUgJPbeIyGqbchucAjHv2SdjS2WucZ9dO3Sgk&e=)bysearchingforthefollowingdocumentaccessionnumber(s):[ML18169A431]
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162 LAR 17 037 7(ARPB), LAR 17 037 8(ICE),and LAR 17 037 9(SRSB).Pleasecontactme,oranyofthoseondistribution,ifyouhaveanyquestionsregardingtheinformationinthisletter.Thankyou,NeilHaggerty__________________________________NeilHaggertylSouthernNuclearOperatingCompanyNuclearDeve lopmentRegulatoryAffairs-VEGP3&4Lice nsingSNCInverness:205.992.7047loffice:301.874.8537lmobile:240.566.2442x2nhagge@southernco.comneil.haggerty@excelservices.comThise mailandanyattachmentstheretoareintendedonlyfortheusebytheaddressee(s)namedhereinandmaycontainproprietaryandconfidentialinformation.Ifyouhavereceivedthise mailinerror,pleaseimmediatelynotifymebytelephoneandpermanentlydeletetheoriginalandanycopyofanye mailandanyprintoutthereof.
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>;Chamberlain,AmyChristine<ACCHAMBE@southernco.com
>;Agee,StephanieY.<SYAGEE@southernco.com
>;Sparkman,WesleyA.<WASPARKM@southernco.com
>
Subject:
FW:GeneralFormSubmission(24095)Received ML#forND 18 0646 OriginalMessageFrom:mshd.resource@nrc.gov[4]Sent:Monday,June18,20185:37PMTo:Spears,LisaJ.<LJSPEARS@southernco.com>
Subject:
GeneralFormSubmission(24095)Received TheNRCreceivedyourGeneralFormsubmissionon:06/18/2018at06.37PM.ItisbeingtrackedassubmissionID#24095.
Ifitisa'Publi clyAvailable'submissionafter6workdaysfromtodaythesubmission'sattacheddocument(s)willbeavailableforviewinganddownloadfromtheAgency'sPublicWebBasedADAMSwebsite(https://urldefense.proofpoint.com/v2/url?u=http3A__adams.nrc.gov_wba&d=DwICAg&c=AgWC6Nl7Slwpc9jE7UoQH1_Cvyci3SsTNfdLP4V1RCg&r=59zh6cGZFmOoYcVGp TyyDXJBpmT8lY6q7sRimpsrSGI&m=TEPAwCdgyGF4Kzu8LGMp_SXTZ9sK90HD_AaRDhsS4&s=oal5HwdUgJPbeIyGqbchucAjHv2SdjS2WucZ9dO3Sgk&e=)bysearchingforthefollowingdocumentaccessionnumber(s):[ML18169A431].Ifthisisa'NonPublicAvailable'submissionthesubmission'sattachment(s)willberetainedinNRC'sdocumentmanagementsystem(ADAMS)andwillnotbepublishedtothepublicwebsite.
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165 NuclearDevelopmentRegulatoryAffairs-VEGP3&4LicensingSNCInverness:205.992.7047loffice:301.874.8537lmobile:240.566.2442x2nhagge@southernco.comneil.haggerty@excelservices.comThise mailandanyattachmentstheretoareintendedonlyfortheusebytheaddressee(s)namedhereinandmaycontainproprietaryandconfidentialinformation.Ifyouhavereceivedthise mailinerror,pleaseimmediatelynotifymebytelephoneandpermanentlydeletetheoriginalandanycopyofanye mailandanyprintoutthereof.
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>;Chamberlain,AmyChristine<ACCHAMBE@southernco.com
>;Agee,StephanieY.<SYAGEE@southernco.com
>;Sparkman,WesleyA.<WASPARKM@southernco.com
>
Subject:
FW:GeneralFormSubmission(24095)ReceivedML#forND 18 0646 OriginalMessageFrom:mshd.resource@nrc.gov[5]Sent:Monday,June18,20185:37PMTo:Spears,LisaJ.<LJSPEARS@southernco.com>
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GeneralFormSubmission(24095)ReceivedTheNRCreceivedyourGeneralFormsubmissionon:06/18/2018at06.37PM.ItisbeingtrackedassubmissionID#24095.Ifitisa'Publi clyAvailable'submissionafter6workdaysfromtodaythesubmission'sattacheddocument(s)willbeavailableforviewinganddownloadfromtheAgency'sPublicWebBasedADAMSwebsite(https://urldefense.proofpoint.com/v2/url?u=http3A__adams.nrc.gov_wba&d=DwICAg&c=AgWC6Nl7Slwpc9jE7UoQH1_Cvyci3SsTNfdLP4V1RCg&r=59zh6cGZFmOoYcVGp TyyDXJBpmT8lY6q7sRimpsrSGI&m=TEPAwCdgyGF4Kzu8LGMp_SXTZ9sK90HD_AaRDhsS4&s=oal5HwdUgJPbeIyGqbchucAjHv2SdjS2WucZ9dO3Sgk&e=)bysearchingforthefollowingdocumentaccessionnumber(s):[ML18169A431].Ifthisisa'NonPublicAvailable'submissionthesubmission'sattachment(s)willberetainedinNRC'sdocumentmanagementsystem(ADAMS)andwillnotbepublishedtothepublicwebsite.
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Note:TheHelpDeskisstaffeddailyfrom9:00AMto7:00PMEaster nTi meMondaythroughFriday(exceptforFederalholidays) 166 Williams, Joseph From: Habib, Donald Sent: Wednesday, June 20, 2018 12:50 PM To: Williams, Joseph Cc:Segala, John; Dixon-Herrity, Jennifer
Subject:
FW: Support info for discussion of Tier 2* LAR Attachments:
Pages from ND-17-1726_LAR-17-037_.Fin al.pdf; 2018-06-21_Tier 2-star LAR__Presentation_Slides.pptx Follow Up Flag:Follow up Due By: Tuesday, July 10, 2018 7:30 AM Flag Status:
CompletedJoe -
Attached are two documents from SNC dealing with previous evaluations of Tier 2* changes. They may already be in ADAMS, and may contain information relevant to the Tier 2* LAR.
Don From:Haggerty,Neil[6]Sent:Wednesday,June20,201812:37PMTo:Habib,Donald<Donald.Habib@nrc.gov>Cc:Amundson,TheodoreEdwin<X2TAMUNS@southernco.com>;Hicks,ThomasE.<X2TEHICK@southernco.com>;Sparkman,WesleyA.<WASPARKM@southernco.com>
Subject:
[External_Sender]SupportinfofordiscussionofJoeWilliams'questionDon, You asked about whether we looked at how use of the Tier 2* evaluation process would have impacted the need for LARs in previous changes. T here are two items we will be prepared to discuss during the public meeting tomorrow. First, there is the discussion of the application of the current Tier 2* evaluation process for changes that were previously submitted as LA Rs in the original LA R-17-037 (ND-17-1726, Encl. 1, pages 4 - 5). Second, there was a presentation that was provided in a Public meeting prior to submittal of the earlier LAR regarding the Tier 2* Departure Evaluation process. This presentation (Slides
21 - 35) assesses the use of LARs for 15 Tier 2* LARs that were submitted prior to the October 23, 2014 meeting. The conclusions from this presentation are still valid, although the quantity of LARs has increased in the subsequent 3-1/2 years.
These two documents provide a summary of the revi ew that was performed to assess the use of LARs for changes to Tier 2* information. This is the information we wanted to provide in response to Mr. Williams' comment. Please provided this to him in advance of the call tomorrow.
These documents are already available to the Public. Thank you, 167 Neil Haggerty NeilHaggertylSouthernNuclearOperatingCompanyNuclearDevelopmentRegulatoryAffairs-VEGP3&4LicensingSNCInverness:205.992.7047loffice:301.874.8537lmobile:240.566.2442x2nhagge@southernco.comneil.haggerty@excelservices.comThis e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and may contain proprietary and confidential information. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.
168 Williams, Joseph From: Coyne, Kevin Sent: Thursday, June 21, 2018 3:20 PM To:Williams, Joseph; Monninger, John Cc: Segala, John
Subject:
RE: Tier 2* LAR Guidance and SE ScheduleJoe -
I'm sorry that this LAR has played out the way it has - you've raised great issues that need to be considered/addressed in this review to ensure we maintain the consistency and regulatory stability that is central to Part 52. We'll continue to press at our level and I appreciate the time you took to yesterday and this morning to provide some initial feedback on what the SE for the LAR ultimately needs to address. If you check to see if John can cover the meeting next week, it will ensure that we can at least represent your issues.
Sorry that this is the start to your vacation, but I do hope you have a good time on your well-deserved leave -
Kevin From:Williams,JosephSent:Thursday,June21,20183:08PMTo:Monninger,John<John.Monninger@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>
Subject:
Tier2*LARGuidanceandSEScheduleJohn and Kevin, tells me that he has been tasked with developing guidance for the review of the Vogtle Tier 2* amendment by next Monday, June 25. has also been tasked with scheduling a meeting with the reviewers next week to discuss the guidance. Apparently, safety evaluation inputs are to be scheduled for completion by mid-July.
It is interesting to note that this tasking comes exactly 6 months after the initial submittal. I have documentary records that I recommended such guidance be developed at least as early as February, and I'm sure I expressed such thoughts verbally before that.
DLSE has been persistently resistant to my input on this and other aspects of the review, and has repeatedly shown no consideration for my circumstances to ensure my participation in important discussions. My interactions with Don have been reasonable, but the organization has a whole has not behaved in a manner consistent with NRC's organization values, with no apparent accountability for such behavior. The organization has not demonstrated integrity, cooperation, openness, or respect so far as I'm concerned. Just yesterday, I picked up the brochure on "The NRC Leadership Model." Some excerpts:
Listen without pre-judgement, encourage participation, and consider ideas offered Seek to develop and preserve personal and organizational relationships Demonstrate active listening and a willingness to set aside persona biases Model the NRC Values and hold ourselves accountable for our actions
169These are just some examples where I feel DLSE has failed to emulate best practices, based on about 5 minutes looking at the various items. I can only imagine what I would come up with if I went through "Speed of Trust."
Beyond informing you of the near term task milestones, probably the only use of this message is to give me an opportunity to vent. I don't know that there is any action you can take to mitigate this situation. I told Kevin earlier today that I appreciate the support I have received within DSRA, and I am dismayed that I have so often distracted you with these issues. I can say that there has been only one other time in the course of my NRC career where I was treated so shabbily and I was so disappointed in the agency's behavior.
Joe 170 Williams, Joseph From: Habib, Donald Sent: Friday, June 22, 2018 4:59 PM To: Green, Brian; Nist, Lauren; Jung, Ian; Zhao, Jack; Van Wert, Christopher; Nolan, Ryan; Karas, Rebecca; Ashley, Clinton; Jackson, Diane; Hansing, Nicholas; Scarbrough, Thomas; Lupold, Timothy; Mitchell, Matthew; Honcharik, John; Segala, John; Williams, Joseph; Dixon-Herrity, Jennifer; Hoellman, Jordan; Samaddar, Sujit; Patel, Pravin; Thomas, Vaughn Cc:Patel, Chandu
Subject:
Info: LAR-17-037 - Draft Reviewer's Aid - Ro ll-up of Original LAR plus supplements Attachments:
LAR-17-037_Roll-up of Changes in S1 - S3_NRC Copy.pdf Categories:
Red Category Described below and attached is a rollup of all previous formally submitted supplements to the Tier 2* LAR, submitted informally by SNC as a reviewers aid. This will be useful for reviewers where RAIs from multiple branches resulted in changes to the same criterion.
If you find a concern or conflict, please let me know. The formal submittals under oath take precedence over this submittal.
Please contact me if you have any questions.
Thanks Don From:Haggerty,Neil[7]Sent:Friday,June22,20184:17PMTo:Habib,Donald<Donald.Habib@nrc.gov>Cc:Sparkman,WesleyA.<WASPARKM@southernco.com>;Redd,JasonP.<JPREDD@southernco.com>;Hicks,ThomasE.<X2TEHICK@southernco.com>;Amundson,TheodoreEdwin<X2TAMUNS@southernco.com>
Subject:
[External_Sender]LAR 17 037DraftReviewer'sAidRoll upofOriginalLARplussupplementsDon, On December 21, 2017, SNC submitted LAR-17-037, which included a total of eight Enclosures providing the LAR, Exempti on Request, licensing basis markups, commitments, and various reviewer's aids. NRC has provided nine RAIs, of wh ich SNC has submitted responses to eight RAIs in three supplements (S1, S2 & S3). The RA I responses also included marked up text to be incorporated into the eight Enclosures in the original LAR.
A s we discussed over the past few weeks, the NRC staff reviewers have requested an aid to help provide a comprehensive understanding of
how all of the markups in the RAI responses will be shown in the LAR (and other Enclosures).
In response to the Staff's request, we have prepared an aid to facilitate the reviewers' understanding of how the changes are "rolled up" into the original 8 enclosures. The attached Reviewer's Aid shows the incorporation of the changes pr ovided in the 3 supplements submitt ed to date, using typical Track Changes font (blue, underlined font for inserted text; r ed, strike-out font for del eted text). In addition, 171 Comments are provided in the ri ght-hand margin describing the origin of each change (i.e., SNC letter number, Enclosure, page number and the number of the RAI resu lting in the change).
Note that during the preparation of this Reviewer
's Aid, it was determi ned that some additional changes (beyond those specifically identified in the RAI responses) were required to completely and accurately depict the changes described in the RA I response. The comments pointing to these changes identify the changes as "conforming changes" and refer to the RAI response to which they conform. Also, note that the responses to three RA Is [#3 (MCB), #4 (SCVB), and #9 (SRSB)] will result in changes to Enclosure 4, which provides a flow diagram depict ing the proposed departure evaluation process. This version of the Reviewer's Aid only identifi es that the flow diagram, and does not show the actual changes, because it is anticipated that additional changes will be needed when the response to the last RAI (RAI LAR-17-03 7-2 from SEB) is submitted and agreed upon.
It is not anticipated that this Reviewer's Aid will be revised again until it is provided in final form as updated (as appropriate) enclosures to the next, and final, supplement, LAR-17-037S4.
Please provide this document to the Staff reviewer s to facilitate their review of the LAR. This document does not contain SUNSI, and may be made available to the Public in ADAMS. There is no new technical information in this Reviewer's Aid that has not already been provided to the NRC Staff in the RAI responses in S1 - S3.
Please contact me if you have any questions regarding this message or its contents. Thank you, Neil Haggerty NeilHaggertylSouthernNuclearOperatingCompanyNuclearDevelopmentRegulatoryAffairs-VEGP3&4LicensingSNCInverness:205.992.7047loffice:301.874.8537lmobile:240.566.2442x2nhagge@southernco.comneil.haggerty@excelservices.comThis e-mail and any attachments thereto are intended only for the use by the addressee(s) named herein and may contain proprietary and confidential information. If you have received this e-mail in error, please immediately notify me by telephone and permanently delete the original and any copy of any e-mail and any printout thereof.
172 Williams, Joseph
Subject:
Updated: Guidance and Schedule for Preparing Vogtle Tier 2* LAR Location: HQ-OWFN-07B06-12p Start: Wed 06/27/2018 10:00 AM End: Wed 06/27/2018 11:30 AM Show Time As:Tentative Recurrence:(none)Meeting Status:
Not yet responded Organizer:
Habib, Donald Required Attendees:
Habib, Donald; Green, Brian; Nist, Lauren; Jung, Ian; Zhao, Jack; Van Wert, Christopher; Nolan, Ryan; Karas, Rebecca; Ashley, Clinton; Jackson, Diane; Hansing, Nicholas; Scarbrough, Thomas; Lupold, Timothy; Mitchell, Matthew; Honcharik, John; Segala, John; Williams, Joseph; Dixon-Herrity, Jennifer; Hoellman, Jordan; Samaddar, Sujit; Patel, Pravin; Thomas, Vaughn; Bradford, Anna; Monninger, John; Coyne, Kevin; Helton, Shana; Campbell, Andy; Caldwell, Robert; Taylor, Robert; Krohn, Paul; McGinty, Tim; Kavanagh, Kerri; Prescott, Paul; Patel, Ch andu; NRO_DNRL_LB4_Cal Resource; Rivera-Varona, Aida; Optional Attendees:
Betancourt, Luis; Basturescu, Sergiu Update: The guidance was updated The meeting location was added Call-In Info: 877-915-0208, passcode: 271-5638 Project Team for Tier 2* LAR -
The purpose of this meeting is to review guidance and schedule for technical staff preparation of SE inputs for the Vogtle Tier 2* License Amendment Request.
Attached are: Draft Guidance Inventory of Tier 2* information in AP1000 DCD (ML11171A303)
The key schedule milestones for the tech staff are:
Provide SE input to LB4 - 7/13 for all branches except SEB Provide SE input to LB4 - 7/20, SEB assumes a cceptable response from licensee provided by 7/12
Please contact me if you have any questions.
Thanks
Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13
175 OriginalAppointmentFrom:Habib,DonaldSent:Friday,June22,20184:39PMTo:Habib,Donald;Green,Brian;Nist,Lauren;Jung,Ian;Zhao,Jack;VanWert,Christopher;Nolan,Ryan;Karas,Rebecca;Ashley,Clinton;Jackson,Diane;Hansing,Nicholas;Scarbrough,Thomas;Lupold,Timothy;Mitchell,Matthew;Honcharik,John;Segala,John;Williams,Joseph;Dixon Herrity,Jennifer;Hoellman,Jordan;Samaddar,Sujit;Patel,Prav in;Thomas,Vaughn;Bradford,Anna;Monninger,John;Coyne,Kevin;Helton,Shana;Campbell,Andy;Caldwell,Robert;Taylor,Robert;Krohn,Paul;McGinty,Tim;Kavanagh,Kerri;Prescott,Paul;Patel,Chandu;NRO_DNRL_LB4_CalResource;Rivera Varona,Aida;Cc:Betancourt,Luis;Basturescu,Sergiu
Subject:
Updated:GuidanceandScheduleforPreparingVogtleTier2*LA RWhen:Wednesday,June27,201810:00AM 11:30AM(UTC 05:00)EasternTime(US&Canada).Where:HQOWFN 07B06 12pUpdate: The guidance was updated The meeting location was added Call-In Info: 877-915-0208, passcode: 271-5638 Project Team for Tier 2* LAR -
The purpose of this meeting is to review guidance and schedule for technical staff preparation of SE inputs for the Vogtle Tier 2* License Amendment Request.
Attached are: Draft Guidance Inventory of Tier 2* information in AP1000 DCD (ML11171A303)
The key schedule milestones for the tech staff are:
Provide SE input to LB4 - 7/13 for all branches except SEB Provide SE input to LB4 - 7/20, SEB assumes a cceptable response from licensee provided by 7/12 Please contact me if you have any questions.
Thanks Don Habib Project Manager NRO/DLSE, Licensing Branch 4
O-8D13 301-415-1035<<File:DCDIntrowithTable1 1ML11 171A303.pdf>><<File:ProposedGuidanceforTech nicalStaffInputsRequestedforLAR170376 23.docx>>
176 Williams, Joseph From: Williams, Joseph Sent: Monday, July 09, 2018 3:25 PM To: Habib, Donald Cc: Segala, John
Subject:
20170221 Tier 2star LAR feedback ML17017A414.pdf Don, I've started looking at your proposed guidance for technical staff for the LAR 17-037 SER. Some initial comments that have occurred to me are below. John Segala is out of the office this week, so I haven't yet had any feedback from within DSRA regarding discussions over the past couple weeks. Overall, I'm still not clear on what is expected from me or how you think whatever is provided is going to mesh with technical staff inputs.
Section 3.1.2 Technical Evaluation of Proposed Changes o What do you envision for "acceptability of proposed process?" I think this is a fundamental piece of the SE, as it should describe the necessary and sufficient attributes of an adequate process that the technical staff can refer to in their own evaluations. As you know, I consider the ability to clearly discriminate between Tier 2* information that is Tier 1-equivalent and less significant information to be a key attribute. This means the SE should describe the characteristics of Tier 1, which is not an easy thing to do.
o The SE needs to describe why the four criteria given starting at the bottom of page 1 of your June 27 outline are necessary and sufficient to judge the adequacy of the process. It seems to me that it is difficult to ask the staff to complete their evaluations using these criteria when we do not yet have a basis confirming that they are sufficient (which is why the "acceptability of proposed process" is so important.) Some thoughts about the criteria themselves: The first criterion, that a change would also affect Tier 1, appears to be incomplete, because it is possible that a Tier 2* change to Tier 1-equivalent information might not affect Tier 1. Per the regulatory history, at least part of the reason Tier 2* was created was to reduce the amount of information in Tier 1, while providing adequate regulatory control of changes. Evaluation of the second criterion, that a change would trip at least one 50.59-like criterion, should consider evidence from the set of completed Tier 2* license amendments. The attached memo provides some preliminary feedback from staff regarding their perception of how good a job 50.59 would do when applied to the various Tier 2* amendments. The purpose of the memo was to provide documentation for the "NRC Staff Assessment" section in SECY-17-0075, starting on page 5 of that paper. For the purposes of the Commission paper, we needed to identify and characterize the various bins amendments would fall into, as opposed to reaching a final position on any specific amendment, so the views expressed in the memo are preliminary staff-level feedback. However, it's worth noting quite a few of the amendments are relevant to LAR 17-037. It would be information to know whether staff agree that the proposed process would yield a result consistent with SNC's view. Based on my quick review of the memo and some of the statements in the SE, I think there are likely to be inconsistencies. For example, the memo characterizes the basemat thickness amendment as one that would trip 50.59 and so would require prior NRC approval, but the LAR suggests SNC has a different opinion. It isn't clear what is intended by the last criterion.
177 It's worth remembering that the staff acknowledged in the regulatory history that it was likely there would be Tier 2* changes that aren't significant, but they'd nonetheless lead to amendments where the public could weigh in. Section 3.2 Evaluation of Exemption: I can't remember exactly where it is at the moment, but there's text somewhere in the record where the Commission acknowledges that it may not be practical to quantify decreased safety due to reduced standardization. I can help you find that text if it would be useful to you. It's a minor editorial point, but I don't think the process evaluation in section 3.1.2 is really "technical."
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors Office of New Reactors 301.415.1470 178 Williams, Joseph From: Habib, Donald Sent: Monday, July 09, 2018 4:38 PM To: Williams, Joseph Cc:Dixon-Herrity, Jennifer; Segala, John
Subject:
For Comment: Briefing to EDO on Vogtle LAR 17-037.docx Attachments:
Briefing to EDO on Vogtle LAR 17-037.docxJoe -
Attached for your comment is a draft briefing to the EDO about the Tier 2* LAR.
I don't think the briefing will be given for a few weeks, Please get back to me with your comments by COB Wednesday.
Thanks Don 179 Williams, Joseph From: Coyne, Kevin Sent: Tuesday, July 10, 2018 8:54 AM To:Monninger, John; Williams, Joseph Cc: Segala, John
Subject:
RE: Tier 2* LAR FeedbackJust a little more info - based on the DLSE input at the weekly meeting yesterday, no briefing had been scheduled yet. Projects is developing a one pager on the amendment that will be provided to Mike Johnson through Fred. Once Mike has a chance to review the one pager, he will decide if further engagement is
needed. Kevin From:Monninger,JohnSent:Tuesday,July10,20187:00AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>
Subject:
RE:Tier2*LARFeedbackYesterday Anna mentioned that a briefing for Mike Johnson had been requested; however, no date was mentioned.
Also, From:Williams,JosephSent:Tuesday,July10,20186:44AMTo:Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
RE:Tier2*LARFeedbackJohn, I've been communicating with Don, and will meet with him this morning to work on clarifying the SE guidance he has provided. I've heard there's going to be an EDO briefing at some point, so I was curious if you had heard anything about that or other feedback from the past couple weeks.
Thanks.
Joe From:Monninger,JohnSent:Monday,July09,20185:02PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
RE:Tier2*LARFeedbackJoe, 180I understand that there was a meeting among the projects and tech staff to discuss and align on the SE while you were out of the office. I believe John Segala may have attended, though he is out of the office this week. If you are not receiving any input from Don, please reach out to Jennifer for the guidance discussed.
Thanks, John From:Williams,JosephSent:Monday,July09,20183:25PMTo:Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
Tier2*LARFeedbackJohn and Kevin, Have either one of you received any feedback regarding guidance being provided to the staff for review of the Vogtle Tier 2* LAR? I've written to Don Habib indicating that I'm still not clear on what LB4 expects from me. More broadly, it's my understanding that there has been an emphasis from LB4 that the various SE inputs focus on the RAI responses. This approach seems problematic, as the RAIs were written without definition of the criteria to be applied to determine the acceptability of the proposal or any outline of an SE, so there can't be high confidence that all issues were identified and communicated in the RAIs.
Apologies for reaching out to you on this subject. Ordinarily, I'd talk to John Segala about this, but he's out this week and there's no one else in the branch that's cognizant of the issues associated with the LAR.
Thanks.
Joe
182 O-8D13 301-415-1035 183 Williams, Joseph From: Williams, Joseph Sent: Wednesday, July 11, 2018 11:09 AM To: Brown, Frederick; Ordaz, Vonna; Taylor, Robert; Bradford, Anna; Monninger, John; Coyne, Kevin Cc:Segala, John; Dixon-Herrity, Jennifer; Patel, Chandu; Habib, Donald
Subject:
Open Door Meeting with Mike Johns on Regarding Vogtle Tier 2* LAR Attachments:
20180711 Mike Johnson Open Door POP.docx Categories:
Red CategoryI want to make you aware that I met this morning with Mike Johnson to discuss my views regarding process issues associated with the Vogtle Tier 2* LAR. I did not discuss the merits of the LAR itself; we only discussed it to the extent that it was pertinent to context and the process-oriented issues. A copy of the notes I gave to
Mike are attached for your information.
In brief, I told Mike that I am concerned that the amendment review process has not yet adequately defined the target for completing the staff's safety evaluation, and that I do not believe the potential policy issues associated with deviation from Commission-approved positions have been fully vetted and communicated. I also told Mike that I raised these issues several months ago, but I have perceived considerable resistance and reluctance to address them. I expressed a view that my experience might be at least a weak signal of cultural issues that need management attention.
Mike asked me what I would suggest for an approach for the LAR review going forward. I said that a clear standard analogous to the SRP for what would constitute an acceptable proposal needs to be established, and vetted by management and OGC. Staff would then be tasked with writing draft safety evaluations. Any gaps in those evaluations could lead to additional RAIs. This approach contrasts strongly with experience to date, where RAIs were solicited before the target for the review was established.
Mike indicated he will be following up with NRO management on these issues.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 184 Williams, Joseph From: Habib, Donald Sent: Thursday, July 12, 2018 7:30 PM To: Green, Brian; Zhao, Jack; Ashley, Clinton; Hansing, Nicholas; Scarbrough, Thomas; Van Wert, Christopher; Nolan, Ryan; Honcharik, John; Prescott, Paul; Patel, Pravin; Thomas, Vaughn Cc: Rivera-Varona, Aida; Betancourt, Luis; Jackso n, Diane; Lupold, Timothy; Karas, Rebecca; Mitchell, Matthew; Kavanagh, Kerri; Samaddar, Sujit; Dixon-Herrity, Jennifer; Patel, Chandu; Hoellman, Jordan; Williams, Joseph; Segala, John
Subject:
INFO: NRC Staff Proposed Revision to Vogtle Units 3 and 4 LAR 17-037 License Condition for Tier 2star Screening Attachments:NRC Staff Proposed Revision to SNC License Condition for Tier 2star Screening 7-12-2018.pdfLAR 17-037 Review Team -
Attached is the NRC staff revision of SNC's proposed Tier 2* license conditions.
This version includes all provisions except those involving critical sections, which will be added when they are
ready. The language reflects that I distributed for staff review previously this week, plus minor changes from the staff responses.
I expect SNC to provide us feedback in a future public meeting, and will inform you if SNC advises of particular issues with any of the language relevant to your technical area.
Please contact me if you have any questions.
Thanks
Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13 301-415-1035
From:Habib,DonaldSent:Thursday,July12,20187:17PMTo:'Haggerty,Neil'<X2NHAGGE@SOUTHERNCO.COM>Cc:'Aughtman,AmyG.'<AGAUGHTM@SOUTHERNCO.COM>;'Redd,JasonP.'<JPREDD@southernco.com>;'Hicks,ThomasE.'<X2TEHICK@southernco.com>;'Amundson,TheodoreEdwin'<X2TAMUNS@southernco.com>;'Clough,Ken'<X2KCLOUG@SOUTHERNCO.COM>;Baker,TodH'(bakerth@westinghouse.com)'<bakerth@westinghouse.com>;'ZachHarper(WEC)'<harperzs@westinghouse.com>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>
Subject:
NRCStaffProposedRevisiontoVogtleUnits3and4LAR17 037LicenseConditionforTier2starScreeningTo All -
185Attached for review and discussion at a future public meeting is a staff revision to the Tier 2* license condition, except for the provisions involving critical sections, which are still under review.
Thank you
Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13 301-415-1035 186 Williams, Joseph From: Habib, Donald Sent: Thursday, July 12, 2018 7:57 PM To: Williams, Joseph
Subject:
RE: SE ThoughtsJoe -
There is a lot in here.
One point I am seeing is that it seems to me that we have previously accepted or acknowledged the notion that we'll have some LARs that will be not safety significant, and we've acknowledged the fact that there will be a hearing opportunity for those LARs.
Anyway, I will do what I can . . .
Thanks Don From:Williams,JosephSent:Thursday,July12,20182:19PMTo:Habib,Donald<Donald.Habib@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>
Subject:
SEThoughtsDon, Here are some thoughts regarding the SE content for your consideration. It is my understanding that the basic point of view I describe (i.e., clear differentiation of Tier 1-equivalent from less significant information) is in line with feedback John Segala gave at your meeting a couple weeks ago. He tells me that he thought the meeting participants were aligned with that view. The outline probably needs some work, but I think it's a reasonable starting point.
Joe 187 Williams, Joseph From: Habib, Donald Sent: Thursday, July 12, 2018 8:04 PM To: Williams, Joseph
Subject:
RE: Clarification: For Comment: Brie fing to EDO on Vogtle LAR 17-037.docx Joe Thanks also for your feedback on this. Some things I can address now. Other things later, when the review is further along.
The briefing is not scheduled. In my view, it would be appropriate to do after the staff reaches a decision, and under an approval scenario, after we get I think it would be appropriate for you to be present and, under an approval scenario, to give a countervailing view.
Thanks Don
From:Williams,JosephSent:Thursday,July12,20189:36AMTo:Habib,Donald<Donald.Habib@nrc.gov>
Subject:
RE:Clarification:ForComment:BriefingtoEDOonVogtleLAR17 037.docxDon, Here are my comments on the briefing material. Do you plan to provide anything else, like copies of the submittals? When is the briefing scheduled?
Joe From:Habib,DonaldSent:Monday,July09,20184:40PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
Clarification:ForComment:BriefingtoEDOonVogtleLAR17 037.docxJoe -
I think you will have an opportunity to comment later, but I need to get an early version to management this
week. We can discuss Tuesday morning.
The SER input has priority over the briefing.
Thanks Don 188 From:Habib,DonaldSent:Monday,July09,20184:38PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>
Subject:
ForComment:BriefingtoEDOonVogtleLAR17 037.docxJoe -
Attached for your comment is a draft briefing to the EDO about the Tier 2* LAR.
I don't think the briefing will be given for a few weeks, Please get back to me with your comments by COB Wednesday.
Thanks Don 189 Williams, Joseph From: Habib, Donald Sent: Friday, July 13, 2018 2:42 PM To: Bradford, Anna Cc:Dixon-Herrity, Jennifer; Patel, Chandu; Hoellman, Jordan; Williams, Joseph; Segala, John
Subject:
Emailing: Briefing to EDO on Vogtle LAR 17-037 Attachments:
Briefing to EDO on Vogtle LAR 17-037 JFW comments.docx; DRAFT Briefing to EDO on Vogtle LAR 17-037 Post-JFW CLEAN.docx Follow Up Flag:Follow up Due By: Monday, July 16, 2018 7:30 AM Flag Status:
Completed Categories:
Red Category Anna - Attached is the DEDO briefing for the Tier 2* LAR. Attached are: (1) a clean version and (2) a version with comments from Joe Williams that I have responded to and (partially) addressed. This will need to be updated later when the review is nearer complete. The sections to be updated are marked. I think this version is about ready for Rob Taylor.
One issue I need help figuring out is why we could approve this amendment now after we previously had messaged to SNC that something like this should be addressed in a rulemaking rather than a LAR. (what is
different this time?)
Thanks Don
190 Williams, Joseph From: Coyne, Kevin Sent: Friday, July 13, 2018 3:21 PM To: Bradford, Anna Cc:Williams, Joseph; Segala, John; Karas, Rebecca; Jackson, Diane; Monninger, John; Habib, Donald
Subject:
Vogtle Tier 2* LAR - Request for Staff Alignment Meeting on SE Hi Anna -
We very much appreciate the efforts Don Habib has made in providing some SE guidance for the Vogtle Tier 2* LAR and reaching out to the staff to help bring some consistency to the overall staff approach on this review. I know Don had a meeting about two weeks ago on his SE template. Now that staff are preparing their SE inputs based on this template and sending them to Don, I think it might be a good idea to get the group together again and make sure that there is consistency in the SE approach and logic across the various technical areas being reviewed (i.e., the approval basis for the fuels information is not at odds with the basis used for structural).
The other aspect of the review that I think needs to be highlighted in the SE is that the staff's review was highly dependent on the scope of Tier 2* items in the AP1000 DC. In other words, I believe most of the branches reviewed the SNC approach based on both the method proposed by SNC but also full knowledge of the population of Tier 2* this approach would be applied to. In other words, the review was not done on a "generic" basis but was done in the context of the specific Tier 2* information in the AP1000 DC. This point needs to come across in the SE so that the limitations/constraints of the applicability of the SNC approach are well
communicated.
Thanks for your consideration -
Kevin
191 Williams, Joseph From: Bradford, Anna Sent: Friday, July 13, 2018 4:18 PM To: Coyne, Kevin Cc:Williams, Joseph; Segala, John; Karas, Rebecca; Jackson, Diane; Monninger, John; Habib, Donald; Taylor, Robert
Subject:
Re: Vogtle Tier 2* LAR - Request for Staff Alignment Meeting on SE Kevin,Thanksforthethoughts.TheduedatefortheSEinputsistoday(exceptforSEB)andIbelievewealreadyhavesomeofthem.OneofthenormalPMfunctionsistomakesuretherearenotinconsistenciesinapproachesfromvariouscontributors.Ifweseeproblems,wewillsetupameetingthen(ifneeded).
IagreewithyouthattheSEshouldaddr essthefa ctthatthisisspecifictotheAP1000.
AnnaH.BradfordDeputyDirectorDivisionofLicensing,Siting,andEnvironmentalAnalysis(DLSE)U.S.NuclearRegulatoryCommission301 4151560On:13July201815:20,"Coyne,Kevin"<Kevin.Coyne@nrc.gov
>wrote:Hi Anna - We very much appreciate the efforts Don Habib has made in providing some SE guidance for the Vogtle Tier 2* LAR and reaching out to the staff to help bring some consistency to the overall staff approach on this review. I know Don had a meeting about two weeks ago on his SE template. Now that staff are preparing their SE inputs based on this template and sending them to Don, I think it might be a good idea to get the group together again and make sure that there is consistency in the SE approach and logic across the various technical areas being reviewed (i.e., the approval basis for the fuels information is not at odds with the basis used for structural). The other aspect of the review that I think needs to be highlighted in the SE is that the staff's review was highly dependent on the scope of Tier 2* items in the AP1000 DC. In other words, I believe most of the branches reviewed the SNC approach based on both the method proposed by SNC but also full knowledge of the population of Tier 2* this approach would be applied to. In other words, the review was not done on a "generic" basis but was done in the context of the specific Tier 2* information in the AP1000 DC. This point needs to come across in the SE so that the limitations/constraints of the applicability of the SNC approach are well
communicated.
Thanks for your consideration - Kevin 192 Williams, Joseph From: Habib, Donald Sent: Friday, July 13, 2018 5:07 PM To: Taylor, Robert Cc:Bradford, Anna; Dixon-Herrity, Jennifer; Hoellman, Jordan; Segala, John; Williams, Joseph; Patel, Chandu; Kallan, Paul
Subject:
Info: Draft Briefing to DEDO on Tier 2* LAR Attachments:DRAFT Briefing to EDO on Vogtle LAR 17-037 Post-JFW CLEAN.docx; DRAFT Briefing to
EDO on Vogtle LAR 17-037 JFW comments.docx Rob - Attached is the draft DEDO briefing for the Tier 2* LAR. Attached are: (1) a clean version and (2) the same version showing a number of substantive comments from Joe Williams that I have responded to and (partially) addressed. This will need to be updated later when the review is nearer complete. The sections to be updated are marked.
Please contact me if you would like to discuss.
Thanks Don Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13 301-415-1035
194 Williams, Joseph From: Williams, Joseph Sent: Monday, July 16, 2018 10:15 AM To: Patel, Chandu; Bradford, Anna; Habib, Donald Cc: Dixon-Herrity, Jennifer; Hoellman, Jordan
- Segala, John; Taylor, Robert; Monninger, John; Coyne, Kevin
Subject:
RE: Emailing: Briefing to EDO on Vogtle LAR 17-037 Attachments:
Briefing to EDO on Vogtle LAR 17-037 JF W reply to DLSE c omment response.docxSome thoughts for your consideration:
Chandu indicates that the staff decision on the previous amendment was communicated to the Commission, which sets a precedent in this case. I wouldn't be surprised if the earlier case was dealt with informally, and such an approach might be fine when the staff decision is already in line with Commission-approved positions. This case significantly deviates from those positions, so it is appropriate to communicate more formally. It also seems reasonable to contrast the two situations (i.e., why did we do one thing before and something different now).
SNC's December 15, 2014 letter withdrawing the previous amendment includes the text "NRC staff members indicated that SNC's request had implications beyond Vogtle 3 and 4 and therefore, SNC's proposal would more appropriately be pursued through a proposed rulemaking."
I don't think Chandu meant it this way, but his note could be read to imply "urgency during the construction" is a basis to approve this amendment. Such urgency might be a factor in the schedule for review, but has no bearing on the safety decision.
Regarding the briefing sheets themselves, I disagree strongly that the proposed process doesn't need to make clear differentiation between Tier 1-equivalent and other Tier 2* information. If the safety evaluation does not confirm that such a distinction can be reliably made, it would not conform with Commission-approved positions.
I also take exception to the point regarding the staff's views. My opinion is that a consistent and coherent standard has not been established for staff review even to this day. Even if one accepts that the guidance provided to staff was sufficient, it was not provided until many weeks after the RAI milestone had come and gone. For some period of time, direction to staff for SE content was "address your RAIs," which might be necessary, but is not sufficient to support a safety finding. My interactions with staff suggest there has been far more confusion than clarity throughout this review, so I'll be surprised if the end products have somehow managed to converge around a consistent standard. I can withhold judgement until I see the completed SE, but my experience to date is not encouraging.
The attached file provides my reply to some of Don's comment responses. See comments 19, 23, and
- 29.
Joe
195From:Patel,ChanduSent:Sunday,July15,20184:45PMTo:Bradford,Anna<Anna.Bradford@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Taylor,Robert<Robert.Taylor@nrc.gov>
Subject:
RE:Emailing:BriefingtoEDOonVogtleLAR17 037Hi, IwasnotinvolvedinalldecisionmakingprocessbecauseIstartedwithVogtleattheendof2014bu tthepreviousLARincludedremovalofallTier2*.IunderstandthatitwasrunthroughallthelevelsupCommissionandmessagewassentverballythatwewerenotgoingtoapprovetherequestjustlikewhatwerecentlydidforIA R.So,licenseewithdrewtherequestinDecember2014.AtleastthistimewehavebetterdefinitionoftherequestandanotherthingasAnnapointedoutisthatwehadSummer,Levy,LeeandTPactiveatthattime.So,onecanmakeanargumentthatthistimeitislittlediffer entifweapproveonlyforVogtlebecauseoftheurgencyduringtheconstruction.Thanks,ChanduFrom:Bradford,AnnaSent:Friday,July13,20183:06PMTo:Habib,Donald<Donald.Habib@nrc.gov
>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
RE:Emailing:BriefingtoEDOonVogtleLAR17 037Thanks Don.
I wasn't in DNRL in 2014 when the feedback to SNC was that it would be better handled in rulemaking so I don't know why we said that (although I don't see a letter saying that so maybe it was just verbal?). Maybe
Chandu or the PM at the time would remember?
In any case, when I look at their 2014 submittal, the criteria seem quite vague and high-level; for example, they would get NRC approval for anything that would "Result in more than a minimal increase in the consequences of an accident previously evaluated in the plant-specific DCD." The more recent submittal is much more specific; for example, they will get NRC approval for things that "adversely affect the containment debris limits or debris screen design criteria." So it seems to me that this most recent LAR proposes specific items that we feel comfortable with.
In addition, we generally don't do rulemaking for something that affects only a small number of applicants/licensees. It may be that in 2014, we were still expecting larger (at least, larger than the current 2)
AP1000's to be built and so wanted to handle it in a more generic fashion, while today a site-specific fix is more resource efficient.
Does that help?
Anna H. Bradford Deputy Director Division of Licensing, Siting, and Environmental Analysis U.S. Nuclear Regulatory Commission 301-415-1560
196From:Habib,DonaldSent:Friday,July13,20182:42PMTo:Bradford,Anna<Anna.Bradford@nrc.gov
>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>
Subject:
Emailing:BriefingtoEDOonVogtleLAR17 037Anna -
Attached is the DEDO briefing for the Tier 2* LAR. Attached are: (1) a clean version and (2) a version with comments from Joe Williams that I have responded to and (partially) addressed. This will need to be updated later when the review is nearer complete. The sections to be updated are marked. I think this version is about ready for Rob Taylor.
One issue I need help figuring out is why we could approve this amendment now after we previously had messaged to SNC that something like this should be addressed in a rulemaking rather than a LAR. (what is different this time?)
Thanks Don
197 Williams, Joseph From: Taylor, Robert Sent: Monday, July 16, 2018 12:44 PM To: Brown, Frederick Cc:Bradford, Anna; Monninger, John; Coyne, Kevin; Segala, John; Williams, Joseph; Dixon-Herrity, Jennifer; Habib, Donald; McGinty, Tim
Subject:
DRAFT Tier 2* One-pager Attachments:
DRAFT One-pager on Vogtle LAR 17-037 - Tier 2-star.docx Fred, Per your request, attached is the draft one-pager on the Tier 2* LAR. It is an 80/20 product as it is still undergoing internal review and discussion. You will see a few places where information still needs to be added, is marked TENTATIVE, or an attachment is planned. In addition, Joe Williams provided additional perspectives and comments this morning that we have not had a chance to digest and evaluate to determine whether further revisions are necessary. We are continuing to make progress, including in public engagements with SNC on the scope and content of license conditions, taking into consideration differing internal viewpoints.
Please let us know if there is anything additional you need.
Rob Robert M. Taylor
,DirectorDivisionofLicensing,SitingandEnvironmentalAnalysis(DLSE)OfficeofNewReactorsUSNRC(office)301415 1634 198 Williams, Joseph From: Williams, Joseph Sent: Monday, July 16, 2018 12:48 PM To: Taylor, Robert; Brown, Frederick Cc:Bradford, Anna; Monninger, John; Coyne, Kevin; Segala, John; Dixon-Herrity, Jennifer; Habib, Donald; McGinty, Tim
Subject:
RE: DRAFT Tier 2* One-pager Attachments:RE: Emailing: Briefing to EDO on Vogtle LAR 17-037For anyone who hadn't seen it earlier, the attached message is the feedback I provided to DLSE earlier today.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 From:Taylor,RobertSent:Monday,July16,201812:44PMTo:Brown,Frederick<Frederick.Brown@nrc.gov>Cc:Bradford,Anna<Anna.Bradford@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>;McGinty,Tim<Tim.McGinty@nrc.gov>
Subject:
DRAFTTier2*One pagerFred, Per your request, attached is the draft one-pager on the Tier 2* LAR. It is an 80/20 product as it is still undergoing internal review and discussion. You will see a few places where information still needs to be added, is marked TENTATIVE, or an attachment is planned. In addition, Joe Williams provided additional perspectives and comments this morning that we have not had a chance to digest and evaluate to determine whether further revisions are necessary. We are continuing to make progress, including in public engagements with SNC on the scope and content of license conditions, taking into consideration differing internal viewpoints.
Please let us know if there is anything additional you need.
Rob Robert M. Taylor
,DirectorDivisionofLicensing,Si tingandEnvironmentalAnalysis(DLSE)OfficeofNewReactorsUSNRC(office)301415 1634 199 Williams, Joseph From: Williams, Joseph Sent: Monday, July 16, 2018 2:30 PM To:Monninger, John; Coyne, Kevin Cc: Segala, John
Subject:
Ravi Joshi Comments on Vogtle Tier 2* LAR Attachments:
Ravi Joshi Comments_on_LAR_17-037.docxI was made aware today that Ravi Joshi submitted the attached comments on the Vogtle Tier 2* LAR back in early April. Ravi is a highly respected former PM with deep knowledge and experience regarding the Vogtle COL and NRC's licensing processes. His comments are based upon the original submittal, and so do not reflect RAI and responses, or other updates made by SNC since that time. I have only read through his comments quickly, but I believe his views largely align with mine. I have highlighted text that might be of
interest to you.
Ravi submitted his comments via regulations.gov, and they can be found here. I'm dismayed that DLSE did not inform me that NRC had received these comments.
Joe 200 Williams, Joseph From: Williams, Joseph Sent: Monday, July 16, 2018 2:53 PM To:Monninger, John; Coyne, Kevin; Segala, John
Subject:
FW: Ravi Joshi Comments on LAR 17-037FYI. We have a problem with our interface with members of the public if LB4 didn't know the comments existed in the first place, From:Hoellman,JordanSent:Monday,July16,20182:48PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Habib,Donald<Donald.Habib@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;Kallan,Paul<Paul.Kallan@nrc.gov>
Subject:
RE:RaviJoshiCommentsonLAR17 037HiJoe-Iwasnotawareofthecomments.I'veincludedothersinmybranchoncctomakesurethattheyareappropriatelyaddressed.
Thanks,JordanFrom:Willia ms,JosephSent:Monday,July16,20182:44PMTo:Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>
Subject:
RaviJoshiCommentsonLAR17 037Jordan, Is your branch aware of comments submitted by Ravi Joshi on the Tier 2* LAR? https://www.regulations.gov/document?D=NRC-2018-0021-0003
Joe 201 Williams, Joseph From: Williams, Joseph Sent: Tuesday, July 17, 2018 11:07 AM To:Johnson, Michael
Subject:
Ravi Joshi Comments on Vogtle Tier 2* LAR Attachments:
Ravi Joshi Comments_on_LAR_17-037.docxMike, I discovered yesterday that Ravi Joshi submitted comments on the Vogtle Tier 2* LAR through regulations.gov in early April. I've attached a copy of his comments for your information. The highlights text in the text are mine, and show some areas where Ravi's thoughts align with mine.
This information is pertinent to the process concerns I discussed with you last week, as DNRL/DLSE did not share Ravi's input with me.
Thanks again for meeting with me last week.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors Office of New Reactors 301.415.1470 202 Williams, Joseph From: Brown, Frederick Sent: Tuesday, July 17, 2018 3:50 PM To:Taylor, Robert; Dixon-Herrity, Jennifer; Habib, Donald; Williams, Joseph Cc:Bradford, Anna; Monninger, John; Coyne, Kevin; Segala, John; McGinty, Tim;
Subject:
RE: DRAFT Tier 2* One-pagerSorry, I've been behind in my e-mail.
Can we please have a meeting this week (after Thursday's call with SNC on the LAR) to talk through where we are at with this review?
Some of the points Joe raises are ones that he has already discussed with me, but others may have evolved since we last talked.
I would like to talk through the issues in an orderly wa y to ensure that we aren't missing anything from a safety or regulatory process standpoint.
- Thanks, Fred From:Williams,JosephSent:Monday,July16,201812:48PMTo:Taylor,Robert<Robert.Taylor@nrc.gov>;Brown,Frederick<Frederick.Brown@nrc.gov>Cc:Bradford,Anna<Anna.Bradford@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>;McGinty,Tim<Tim.McGinty@nrc.gov>
Subject:
RE:DRAFTTier2*One pagerFor anyone who hadn't seen it earlier, the attached message is the feedback I provided to DLSE earlier today.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors Office of New Reactors 301.415.1470
From:Taylor,RobertSent:Monday,July16,201812:44PMTo:Brown,Frederick<Frederick.Brown@nrc.gov
>Cc:Bradford,Anna<Anna.Bradford@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;McGinty,Tim<Tim.McGinty@nrc.gov
>
Subject:
DRAFTTier2*One pagerFred, 203Per your request, attached is the draft one-pager on the Tier 2* LAR. It is an 80/20 product as it is still undergoing internal review and discussion. You will see a few places where information still needs to be added, is marked TENTATIVE, or an attachment is planned. In addition, Joe Williams provided additional perspectives and comments this morning that we have not had a chance to digest and evaluate to determine whether further revisions are necessary. We are continuing to make progress, including in public engagements with SNC on the scope and content of license conditions, taking into consideration differing internal viewpoints.
Please let us know if there is anything additional you need.
Rob Robert M. Taylor
,DirectorDivisionofLicensing,SitingandEnvironmentalAnalysis(DLSE)OfficeofNewReactorsUSNRC(office)301415 1634 204 Williams, Joseph From:Monninger, John Sent: Wednesday, July 18, 2018 7:16 AM To: Hoellman, Jordan; Bradford, Anna Cc:Williams, Joseph; Coyne, Kevin
Subject:
RE: Tier 2* Status of Vogtle LAR 17-037 Anna, Jordan
Do we have an agenda or know how this meeting is going to be conducted? Is DLSE going to present something? Is Joe or DSRA expected to present something? Are we in a listening mode from Fred ?
We just want to make sure we are prepared and responsive.
- Thanks, John OriginalAppointmentFrom:Hoellman,JordanSent:Tuesday,July17,20184:06PMTo:Brown,Frederick;Taylor,Robert;Williams,Joseph;Bradford,Anna;Monninger,John;Coyne,Kevin;Segala,John;McGinty,TimCc:Dixon Herrity,Jennifer;Habib,Donald;Patel,Chandu;Kallan,Paul
Subject:
Tier2*StatusofVogtleLA R17 037When:Thursday,July19,20182:30PM 3:30PM(UTC 05:00)EasternTime(US&Canada).Where:HQOWFN 11B04 25p Meeting requested by Fred to discuss where we are with the review of Vogtle LAR 17-037, Changes to the Tier 2* Departure Evaluation Process.
205 Williams, Joseph From: Bradford, Anna Sent: Wednesday, July 18, 2018 7:19 AM To:Monninger, John; Hoellman, Jordan Cc:Williams, Joseph; Coyne, Kevin
Subject:
Re: Tier 2* Status of Vogtle LAR 17-037I will talk through the one pager we provided to Fred on Monday. Joe isn't expected to present anything but is welcome to chime in.
Anna H. Bradford Deputy Director Division of Licensing, Siting, and Environmental Analysis (DLSE)
U.S. Nuclear Regulatory Commission 301-415-1560 On: 18 July 2018 07:15, "Monninger, John" <
John.Monninger@nrc.gov
> wrote: Anna, Jordan Do we have an agenda or know how this meeting is going to be conducted? Is DLSE going to present something? Is Joe or DSRA expected to present something? Are we in a listening mode from Fred ?
We just want to make sure we are prepared and responsive.
Thanks, John OriginalAppointmentFrom:Hoellman,JordanSent:Tuesday,July17,20184:06PMTo:Brown,Frederick;Taylor,Robert;Williams,Joseph;Bradford,Anna;Monninger,John;Coyne,Kevin;Segala,John;McGinty,TimCc:Dixon Herrity,Jennifer;Habib,Donald;Patel,Cha ndu;Kallan,Paul
Subject:
Tier2*StatusofVogtleLA R17 037When:Thursday,July19,20182:30PM 3:30PM(UTC 05:00)EasternTime(US&Canada).Where:HQOWFN 11B04 25p Meeting requested by Fred to discuss where we are with the review of Vogtle LAR 17-037, Changes to the Tier 2* Departure Evaluation Process.
206 Williams, Joseph From: Hoellman, Jordan Sent: Friday, July 20, 2018 9:14 AM To: Green, Brian; Zhao, Jack; Ashley, Clinton; Hansing, Nicholas; Scarbrough, Thomas; Van Wert, Christopher; Nolan, Ryan; Honcharik, John; Prescott, Paul; Patel, Pravin; Thomas, Vaughn Cc: Rivera-Varona, Aida; Betancourt, Luis; Jackso n, Diane; Lupold, Timothy; Karas, Rebecca; Mitchell, Matthew; Kavanagh, Kerri; Samaddar, Sujit; Dixon-Herrity, Jennifer; Patel, Chandu; Hoellman, Jordan; Williams, Joseph; Segala, John; Dixon-Herrity, Jennifer; Habib, Donald
- Patel, Chandu; Bradford, Anna; Taylor, Robert
Subject:
Tier 2* Vogtle LAR 17-037 Status
Dearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,
DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,includingtheinformat ionthatDLSEdevelopedregardinghowthereviewwasconducted.PleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforreviewbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecess arychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.Haveagreatweekend!
207 Williams, Joseph From: Williams, Joseph Sent: Monday, July 23, 2018 8:09 AM To: Hoellman, Jordan; Green, Brian; Zhao, Jack; Ashley, Clinton; Hansing, Nicholas; Scarbrough, Thomas; Van Wert, Christopher; Nolan, Ryan; Honcharik, John; Prescott, Paul; Patel, Pravin; Thomas, Vaughn Cc:Coyne, Kevin; Segala, John; Bradford, Anna; Dixon-Herrity, Jennifer; Habib, Donald; Patel, Chandu; Hoellman, Jordan
Subject:
Vogtle Tier 2* LAR FeedbackOver the past couple weeks, I met with Mike Johnson, Fred Brown, and others to describe concerns I have regarding the Vogtle Tier 2* LAR. I have said that I am not confident that staff involved with the review have been given sufficient guidance to determine questions to be addressed by RAIs or complete their reviews, and that policy questions associated with the review have not been adequately vetted or communicated. I also expressed concern about a chilling effect I have felt, as it has been very difficult for me to get any attention to these issues. It is my understanding that DLSE will be following up with you to determine if the guidance provided has been sufficient, so when you hear from them, that's the context of the inquiry. If you don't have any concerns with the guidance provided and process followed, that's great. On the other hand, if you share any of my concerns, by all means speak up.
Some people have asked if I plan to non-concur in the amendment. I won't make a decision until I see what the SE says.
Feel free to call or email me, or drop by my office (T-9F28B) if you would like to hear more.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 208 Williams, Joseph From: Williams, Joseph Sent: Monday, July 23, 2018 8:19 AM To: Coyne, Kevin Cc:Segala, John; Monninger, John
Subject:
RE: Fred Brown Briefing Attachments:
Tier 2* Vogtle LAR 17-037 Status Kevin, FYI, DLSE sent the attached email on Friday morning. I don't think it quite aligns with the meeting outcome you describe, but I guess I have to wait and see how things play out. You'll also see that I've written to the other reviewers to inform them of my meetings with Johnson and Brown so they have an appreciation of the full context of DLSE's inquiries. I also want to do some rumor control, as some people have asked me if I plan
to non-concur.
Joe From:Coyne,KevinSent:Friday,July20,201810:05AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>
Subject:
RE:FredBrownBriefing Joe - Thank you again for bringing your concerns forward and providing a candid discussions of the issues and challenges you identified in the review of the Vogtle Tier 2* license amendment request. We will continue to work with DLSE to make sure that the actions discussed at the meeting are completed (i.e., confirm reviewers considered guidance provided by DLSE, that the SNC process is capable of identifying items that require prior NRC approval, and future development of guidance on Tier 1 and Tier 2).
Both John and I very much appreciate and support you in bringing your concerns forward - so please let us know if there is anything we can do to make sure your issues continue to be heard and considered as we move forward. In addition, the NRC's Open Door Policy described in MD 10.160
(http://www.internal.nrc.gov/polic y/directives/catalog/md10.160.pdf ) identifies a number of available resources for addressing an y chilling issues you may have experienced during this process. These resources include:
Your immediate supervisor; Another supervisor or manager (in accordance with the Open Door Policy); Office of the Chief Human Capital Officer (OCHCO); NRC OIG; Negotiated grievance procedure described in the Collective Bargaining Agreement Between the NRC and the National Treasury Employees Union (see http://www.internal.nrc.gov/HR/pdf/cba.pdf ); The administrative grievance procedure described in MD 10.101, "Employee Grievances" (https://www.nrc.gov/docs/ML1807/ML18073A286.pdf ) The Department of Labor, Occupational Safety and Health Administration, Office of Whistleblower Protection (Complaints must be filed within 180 days. More information is available at http://www.whistleblowers.gov/ ); and The U.S. Office of Special Counsel. (More information is available at http://www.osc.gov/ )
209In addition, the MD 10.158 NRC Non-Concurrence Process (https://www.nrc.gov/docs/ML1807/ML18073A296.pdf ) and the MD 10.159 Differing Professional Opinion Process (https://www.nrc.gov/docs/ML1807/ML18073A298.pdf ) provide other avenues to express your views.
Thanks again -
Kevin
From:Williams,JosephSent:Thursday,July19,20184:29PMTo:Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>
Subject:
FredBrownBriefing The outcome of the meeting was probably better than expected, though not what I would have hoped for. There was a bit of progress with regard to the LAR (again, not as much as I'd hope, but I wasn't going to be surprised if there was none at all), but none re garding policy questions, and little res ponse to the chilling effect feedback.
I appreciate the support and perspectives you have provided. We'll see where the SE goes.
Joe 210 Williams, Joseph From: Hoellman, Jordan Sent: Monday, July 23, 2018 9:22 AM To: Williams, Joseph Cc: Habib, Donald
Subject:
RE: DEDO Briefing Sheet Attachments:
Briefing to EDO on Vogtle LAR 17-037 jph.docx HiJoe-Here'sthelatestversion.Letmeknowifyouneedanythingelse.
Thanks,JordanFrom:Williams,JosephSent:Monday,July23,20189:09AMTo:Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>
Subject:
DEDOBriefingSheetJordan, Can you send me an electronic version of the briefing sheet you provided at the meeting last Thursday, or a more current version, if one exists?
Thanks.
Joe 211 Williams, Joseph From: Habib, Donald Sent: Thursday, July 26, 2018 7:37 AM To: Hoellman, Jordan; Green, Brian; Zhao, Jack; Ashley, Clinton; Hansing, Nicholas; Scarbrough, Thomas; Van Wert, Christopher; Nolan, Ryan; Honcharik, John; Prescott, Paul; Patel, Pravin; Thomas, Vaughn Cc: Rivera-Varona, Aida; Betancourt, Luis; Jackso n, Diane; Lupold, Timothy; Karas, Rebecca; Mitchell, Matthew; Kavanagh, Kerri; Samaddar, Sujit; Dixon-Herrity, Jennifer; Patel, Chandu; Williams, Joseph; Segala, John; Dixon-Herrity, Jennifer; Patel, Chandu; Bradford, Anna; Taylor, Robert; Williams, Joseph
Subject:
Action: For Review: Tier 2* Vogtle LAR 17-037 Status Attachments:
2018-07-25 Safety Evaluation - LAR 17-037.docx; PROPOSED REVISION TO SNC
LICENSE CONDITION 2.D.(13).pdf Importance:High Categories:
Red Category LAR 17-037 Technical Reviewers -
I need your assistance to finish the SE for this LAR, attached, which contains all of the inputs you have provided, plus much of the DLSE-generated content, which we are still working on.
ACTION: By COB Friday, please take a look at it and confirm that the DLSE-generated discussions are accurate and applicable for your specific review area. This should include the discussion at the beginning of Section 3.1 and for the exemption evaluation in Section 3.2. Additionally, please affirm that the screening criteria will ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval. The license condition language has had minor changes since the previous (July 12) version. You may also wish to compare your branch input to those from other branches. Some minor editorial changes were made to the inputs (ML#s, licensee vs SNC, etc.)
After we have heard back from the tech branches, made any necessary changes, and received SNC's final submittal, then we will send the SE back to you for formal concurrence. Please let me know if you have questions.
Thanks to all for your efforts on this LAR. Please advise me if you need additional time.
Don Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13 301-415-1035
From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;
212 Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037StatusDearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevi e wbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.
Haveagreatweekend!
From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov>;Zhao,Jack<Jack.Zhao@nrc.gov>;Ashley,Clinton<Clinton.Ashley@nrc.gov>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov>;VanWert,Christopher<Christopher.VanWert@nrc.gov>;Nolan,Ryan<Ryan.Nolan@nrc.gov>;Honcharik,John<John.Honcharik@nrc.gov>;Prescott,Paul<Paul.Prescott@nrc.gov>;Patel,Pravin<Pravin.Patel@nrc.gov>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov>;Betancourt,Luis<Luis.Betancourt@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>
- Lupold,Timothy<Timothy.Lupold@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Segala,John<John.Segala@nrc.gov>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>;Patel,Chandu 213<Chandu.Patel@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>;Taylor,Robert<Robert.Taylor@nrc.gov>
Subject:
Tier2*VogtleLAR17 037Status
Dearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,
DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocum ent,includingtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatit em sthatneedtocomebacktotheagencyforreviewbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleas eletusknowifyouhavequestions.Thanksagain.
Haveagreatweekend!
214 Williams, Joseph From: Williams, Joseph Sent: Friday, July 27, 2018 9:32 AM To:Monninger, John; Coyne, Kevin; Segala, John
Subject:
SECY-18-0060 Transformation FYI, I was directed to the following text that appears in the transformation paper:
One of the driving factors behind the decision to implement distinct change processes in Parts 50 and 52 was the Commission's goal of maintaining standardization. Revising the Part 52 change process
would be a policy shift [emphasis added] away from standardization.
The Vogtle LAR affects Part 52 change processes, so draw your own conclusions.
Joe 215 Williams, Joseph From:Ashley, Clinton Sent: Friday, July 27, 2018 1:46 PM To: Williams, Joseph
Subject:
FW: Action: For Review: Tier 2* Vogtle LAR 17-037 Status Attachments:
2018-07-25 Safety Evaluation - LAR 17-037.docx; PROPOSED REVISION TO SNC LICENSE CONDITION 2.D.(13).pdf Importance:High Joe, I am curious to read your thoughts about the SE conclusion and it's association to GDC 1. It's the first I have seen this. Thought you might have some insight.
Clint 3.1.9
SUMMARY
OFTECHNICALEVALUATION Forthereasonsdiscussedabove,thestafffindsthattheproposedTier2*departureevaluationprocessandscreeningcriteriainLicenseCondition2.D.(13)providereasonableassurancethatanyfuturesafety significantdeparturesfromTier2*informationwillcontinuetorequirepriorNRCapproval.Basedonthesefindings,thestaffconcludesthatthereisreasonableassurancethattherequirementsofGDC1ofAppendixAto10CFRPart50willcontinuetobemet.Therefore,thestafffindstheproposedchangestobeacceptable.Aspreviouslynoted,thestaffreviewandconclusionsarespecifictotheVogtleUnits3and4.Thestaffdidnotconsider,andtheconclusionsofthereviewdonotapplyto,otherdesignscertifiedandothercombinedlicensesissuedunder10CFRPart52,includingotherAP1000combinedlicenses. From:Habib,DonaldSent:Thursday,July26,20187:37AM
Subject:
Action:ForReview:Tier2*VogtleLAR17 037StatusImportance:HighLAR 17-037 Technical Reviewers -
I need your assistance to finish the SE for this LAR, attached, which contains all of the inputs you have provided, plus much of the DLSE-generated content, which we are still working on.
ACTION: By COB Friday, please take a look at it and confirm that the DLSE-generated discussions are accurate and applicable for your specific review area. This should include the discussion at the beginning of Section 3.1 and for the exemption evaluation in Section 3.2. Additionally, please affirm that the screening criteria will ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval. The license condition language has had minor changes since the previous (July 12) version. You may also wish to compare your branch input to those from other branches. Some minor editorial changes were made to the inputs (ML#s, licensee vs SNC, etc.)
After we have heard back from the tech branches, made any necessary changes, and received SNC's final submittal, then we will send the SE back to you for formal concurrence. Please let me know if you have questions.
216 Thanks to all for your efforts on this LAR. Please advise me if you need additional time.
Don Don Habib
Project Manager NRO/DLSE, Licensing Branch 4
O-8D13 301-415-1035
From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037StatusDearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevie wbeforetheyarechangedbySN Careappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.
Haveagreatweekend!
217 From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037Status
Dearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,
DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevi e wbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.Haveagreatweekend!
218 Williams, Joseph From: Williams, Joseph Sent: Friday, July 27, 2018 2:33 PM To:Ashley, Clinton
Subject:
RE: Action: For Review: Tier 2* Vogtle LAR 17-037 StatusI confirmed that there's no mention of GDC 1 in the review guidance provided on June 27.
From:Ashley,ClintonSent:Friday,July27,20182:12PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>
Subject:
RE:Action:ForReview:Tier2*VogtleLAR17 037StatusThanks. I asked Don earlier today about this and he said he would get back with me-Not sure who originated the conclusion. I did not see any discussion in the tech eval section that warranted such a conclusion. Murky is an apt description.
Clint From:Williams,JosephSent:Friday,July27,20182:06PMTo:Ashley,Clinton<Clinton.Ashley@nrc.gov
>
Subject:
RE:Action:ForReview:Tier2*VogtleLAR17 037StatusClint, My initial reaction is that GDC 1 doesn't say anything about what does or doesn't require NRC approval, so the relationship between that conclusion and the previous sentence is murky, at best. I also don't see any discussion of GDC 1 in any of the individual topics (I haven't read them all yet).
The previous sentence is also inaccurate, in my opinion, in that it should say something along the lines that any future Tier 2* departures for Tier 1-equivalent information will continue to require NRC review and approval. For one thing, we review non-safety significant changes all the time; that's not an unexpected outcome of many LAR and other licensing action reviews. Rather, often what we are doing is confirming that a change to a safety significant thing is still within acceptable bounds; we want to be sure licensees are screwing
up something important.
I think Section 2.0 should clearly articulate what needs to happen to find the LAR acceptable, and that the individual topic areas need to demonstrate how they conform to that standard. That's not how the SE is written, though.
I may come up with more thoughts, but that's pretty much the first thing that comes to mind. I'll be sending out some general comments to everyone by the end of the day.
Joe From:Ashley,ClintonSent:Friday,July27,20181:46PM 219 To:Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
FW:Action:ForReview:Tier2*VogtleLAR17 037StatusImportance:HighJoe, I am curious to read your thoughts about the SE conclusion and it's association to GDC 1. It's the first I have seen this. Thought you might have some insight.
Clint 3.1.9
SUMMARY
OFTECHNICALEVALUATION Forthereasonsdiscussedabove,thestafffindsthattheproposedTier2*departureevaluationprocessandscreeningcriteriainLicenseCondition2.D.(13)providereasonableassurancethatanyfuturesafety significantdeparturesfromTier2*informationwillcontinuetorequirepriorNRCapproval.Basedonthesefindings,thestaffconcludesthatthereisreasonableassurancethattherequirementsofGDC1ofAppendixAto10CFRPart50willcontinuetobemet.Therefore,thestafffindstheproposedchangestobeacceptable.Aspreviouslynoted,thestaffreviewandconclusionsarespecifictotheVogtleUnits3and4.Thestaffdidnotconsider,andtheconclusionsofthereviewdonotapplyto,otherdesignscertifiedandothercombinedlicensesissuedunder10CFRPart52,includingotherAP1000combinedlicenses. From:Habib,DonaldSent:Thursday,July26,20187:37AM
Subject:
Action:ForReview:Tier2*VogtleLAR17 037StatusImportance:HighLAR 17-037 Technical Reviewers -
I need your assistance to finish the SE for this LAR, attached, which contains all of the inputs you have provided, plus much of the DLSE-generated content, which we are still working on.
ACTION: By COB Friday, please take a look at it and confirm that the DLSE-generated discussions are accurate and applicable for your specific review area. This should include the discussion at the beginning of Section 3.1 and for the exemption evaluation in Section 3.2. Additionally, please affirm that the screening criteria will ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval. The license condition language has had minor changes since the previous (July 12) version. You may also wish to compare your branch input to those from other branches. Some minor editorial changes were made to the inputs (ML#s, licensee vs SNC, etc.)
After we have heard back from the tech branches, made any necessary changes, and received SNC's final submittal, then we will send the SE back to you for formal concurrence. Please let me know if you have questions.
Thanks to all for your efforts on this LAR. Please advise me if you need additional time.
Don Don Habib Project Manager NRO/DLSE, Licensing Branch 4
O-8D13 301-415-1035 220 From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037Status
Dearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,
DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevi e wbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.Haveagreatweekend!
From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>
221 Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037StatusDearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevie wbeforetheyarechangedbySN Careappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.
Haveagreatweekend!
222 Williams, Joseph From: Williams, Joseph Sent: Friday, July 27, 2018 3:21 PM To: Habib, Donald; Hoellman, Jordan; Green, Brian; Zhao, Jack; Ashley, Clinton; Hansing, Nicholas; Scarbrough, Thomas; Van Wert, Christopher; Nolan, Ryan; Honcharik, John; Prescott, Paul; Patel, Pravin; Thomas, Vaughn Cc: Rivera-Varona, Aida; Betancourt, Luis; Jackso n, Diane; Lupold, Timothy; Karas, Rebecca; Mitchell, Matthew; Kavanagh, Kerri; Samaddar, Sujit; Dixon-Herrity, Jennifer; Patel, Chandu; Segala, John; Dixon-Herrity, Jennifer; Patel, Chandu; Bradford, Anna; Taylor, Robert; Monninger, John; Coyne, Kevin; McGovern, Denise
Subject:
Initial Feedback on Tier 2* LAR Safety Evaluation Categories:
Red CategoryI am still reviewing the draft safety evaluation and will provide more comments early next week. In the meantime, here are some initial observations for your consideration.
The SE does not adequately address policy questions introduced by this request.
o The LAR is a significant deviation from the Commission-approved fundamental structure of a design certification rule and change controls for safety significant information. The "Regulatory History Package on Design Certification," (ML003761550) provides extensive documentation of Commission decisions associated with certified design change controls, including Tier 2*. Page 9 of Enclosure 5 to SECY-18-0060, "Achieving Modern Risk-Informed Regulation" (the so-called "transformation paper") appears to support my view, as shown by this text: "One of the driving factors behind the decision to implement distinct change processes in Parts 50 and 52 was the Commission's goal of maintaining standardization. Revising the Part 52 change process would be a policy shift [emphasis added] away from standardization."
o Statements regarding generic implications for other AP1000 COLs and other design centers are incomplete, at best. No basis is given for staff statements that the conclusions don't apply to any other licensee. It may be only that the application is only on the Vogtle dockets, but that's not really the point. This review sets a precedent for all other AP1000 COLs, both current and future. There is no obvious reason another AP1000 licensee couldn't submit an identical LAR and expect a different outcome.
o The SE does not describe how the proposal conforms to all pertinent Commission positions (which it doesn't, in my opinion), or why deviation from those positions is acceptable or appropriate.
o The SE does not address rulemaking issues. A previous LAR of similar scope was withdrawn due to staff feedback that such an item should be addressed by rulemaking, but the SE does not address why a different approach is appropriate in this case. Approval of this request also constitutes de facto rulemaking, as the staff would have no basis to deny a similar LAR to any other AP1000.
o Public comments received from Ravi Joshi also suggest a need to address policy issues, but it is not apparent that the SE intends to address his statements in this regard.
223 Section 2.0 should clearly articulate what needs to happen to find the LAR acceptable, and that the individual topic areas need to demonstrate how they conform to that standard. That's not how the SE is written, though.
o The draft SE does not articulate the standard described in Don Habib's July 26 email where he tasked the staff with affirming "that the screening criteria will ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval." The proposed process must clearly differentiate between Tier 2* information that is equivalent to Tier 1 and any Tier 2* content of lesser significance. Otherwise, NRC can't reach the stated conclusion. This is a fundamental criterion which must be demonstrated to ensure the integrity of Tier 2* information. The evaluation of each Tier 2* topic must address this point.
o The conclusion that "the staff finds that the proposed Tier 2* departure evaluation process and screening criteria in License Condition 2.D.(13) provide reasonable assurance that any future safety-significant departures from Tier 2* information will continue to require prior NRC approval" is inaccurate, in that it needs to say something along the lines that any future Tier 2* departures for Tier 1-equivalent information will continue to require NRC review and approval. The staff must say that change controls for Tier 1-equivalent information will be consistently, reliably, and predictably preserved.
o The reliance on GDC 1 in the conclusion is new to me. It was not part of the proposed SE guidance provided to the staff on June 27. Examples from completed amendments need to be evaluated.
o The discussion of examples cited by the applicant is very limited, merely reiterating the applicant's claims without any evaluation. The staff should describe its views on how the proposed amendment would have applied to any previous Tier 2* amendment within the scope of the present request. The staff should determine if its assessment aligns with the licensee's views, and document that outcome.
o The safety evaluation should examine all existing Tier 2* LARs affecting topics within the scope of this amendment to determine if the proposed process would reliably yield an acceptable
outcome. Successful demonstration would increase confidence in the adequacy of the proposal. One or more unsuccessful tests would reveal deficiencies that must be addressed.
o Information needed to conduct such an evaluation was the intent of an ARPB RAI which was never sent to the licensee. The SE appears to accept the false premise that an amendment is unnecessary if it is determined to have minimal effect on or improve safety. See, for example, text in the last full paragraph on page 3.
o NRC routinely approves such licensing changes because it is necessary for the regulator to confirm that a change to a safety significant aspect of a facility is appropriate.
o If done correctly, such changes can certainly be safety neutral or improve safety.
o However, if they are not done properly, the effects can be negative. The staff should review implementing procedures before the amendment is issued, consistent with what I believe was the staff approach for NEI 96-07 when 10 CFR 50.59 was modified.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 224 Williams, Joseph From: Habib, Donald Sent: Friday, July 27, 2018 3:29 PM To: Williams, Joseph
Subject:
RE: Initial Feedback on Tier 2* LAR Safety Evaluation Joe -
Thanks for the comments.
At this time, my intent is to address all of your comments by including the appropriate discussions in the SER. Your comments give me a good framework for tackling the discussions.
We can discuss next week.
Don From:Williams,JosephSent:Friday,July27,20183:21PMTo:Habib,Donald<Donald.Habib@nrc.gov>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;Green,Brian<Brian.Green@nrc.gov>;Zhao,Jack<Jack.Zhao@nrc.gov>;Ashley,Clinton<Clinton.Ashley@nrc.gov>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov>;VanWert,Christopher<Christopher.VanWert@nrc.gov>;Nolan,Ryan<Ryan.Nolan@nrc.gov>;Honcharik,John<John.Honcharik@nrc.gov>;Prescott,Paul<Paul.Prescott@nrc.gov>;Patel,Pravin<Pravin.Patel@nrc.gov>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov>Cc:RiveraVarona,Aida<Aida.Rivera Varona@nrc.gov>;Betancourt,Luis<L uis.Betancourt@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>;Lupold,Timothy<Timothy.Lupold@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov>;Patel,Chandu<Chandu.Patel@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>;Taylor,Robert<Robert.Taylor@nrc.gov>;Monninger,John<John.Monninger@nr c.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>;McGovern,Denise<Denise.McGovern@nrc.gov>
Subject:
InitialFeedbackonTier2*LARSafetyEvaluationI am still reviewing the draft safety evaluation and will provide more comments early next week. In the meantime, here are some initial observations for your consideration.
The SE does not adequately address policy questions introduced by this request.
o The LAR is a significant deviation from the Commission-approved fundamental structure of a design certification rule and change controls for safety significant information. The "Regulatory History Package on Design Certification," (ML003761550) provides extensive documentation of Commission decisions associated with certified design change controls, including Tier 2*. Page 9 of Enclosure 5 to SECY-18-0060, "Achieving Modern Risk-Informed Regulation" (the so-called "transformation paper") appears to support my view, as shown by this text: "One of the driving factors behind the decision to implement distinct change processes in Parts 50 and 52 was the Commission's goal of maintaining standardization. Revising 225the Part 52 change process would be a policy shift [emphasis added] away from standardization."
o Statements regarding generic implications for other AP1000 COLs and other design centers are incomplete, at best. No basis is given for staff statements that the conclusions don't apply to any other licensee. It may be only that the application is only on the Vogtle dockets, but that's not really the point. This review sets a precedent for all other AP1000 COLs, both current and future. There is no obvious reason another AP1000 licensee couldn't submit an identical LAR and expect a different outcome.
o The SE does not describe how the proposal conforms to all pertinent Commission positions (which it doesn't, in my opinion), or why deviation from those positions is acceptable or appropriate.
o The SE does not address rulemaking issues. A previous LAR of similar scope was withdrawn due to staff feedback that such an item should be addressed by rulemaking, but the SE does not address why a different approach is appropriate in this case. Approval of this request also constitutes de facto rulemaking, as the staff would have no basis to deny a similar LAR to any other AP1000.
o Public comments received from Ravi Joshi also suggest a need to address policy issues, but it is not apparent that the SE intends to address his statements in this regard. Section 2.0 should clearly articulate what needs to happen to find the LAR acceptable, and that the individual topic areas need to demonstrate how they conform to that standard. That's not how the SE is
written, though.
o The draft SE does not articulate the standard described in Don Habib's July 26 email where he tasked the staff with affirming "that the screening criteria will ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval." The proposed process must clearly differentiate between Tier 2* information that is equivalent to Tier 1 and any Tier 2* content of lesser significance. Otherwise, NRC can't reach the stated conclusion. This is a fundamental criterion which must be demonstrated to ensure the integrity of Tier 2* information. The evaluation of each Tier 2* topic must address this point.
o The conclusion that "the staff finds that the proposed Tier 2* departure evaluation process and screening criteria in License Condition 2.D.(13) provide reasonable assurance that any future safety-significant departures from Tier 2* information will continue to require prior NRC approval" is inaccurate, in that it needs to say something along the lines that any future Tier 2* departures for Tier 1-equivalent information will continue to require NRC review and approval. The staff must say that change controls for Tier 1-equivalent information will be consistently, reliably, and predictably preserved.
o The reliance on GDC 1 in the conclusion is new to me. It was not part of the proposed SE guidance provided to the staff on June 27. Examples from completed amendments need to be evaluated.
o The discussion of examples cited by the applicant is very limited, merely reiterating the applicant's claims without any evaluation. The staff should describe its views on how the proposed amendment would have applied to any previous Tier 2* amendment within the scope of the present request. The staff should determine if its assessment aligns with the licensee's views, and document that outcome.
o The safety evaluation should examine all existing Tier 2* LARs affecting topics within the scope of this amendment to determine if the proposed process would reliably yield an acceptable
outcome. Successful demonstration would increase confidence in the adequacy of the proposal. One or more unsuccessful tests would reveal deficiencies that must be addressed.
226 o Information needed to conduct such an evaluation was the intent of an ARPB RAI which was never sent to the licensee. The SE appears to accept the false premise that an amendment is unnecessary if it is determined to have minimal effect on or improve safety. See, for example, text in the last full paragraph on page 3.
o NRC routinely approves such licensing changes because it is necessary for the regulator to confirm that a change to a safety significant aspect of a facility is appropriate.
o If done correctly, such changes can certainly be safety neutral or improve safety.
o However, if they are not done properly, the effects can be negative. The staff should review implementing procedures before the amendment is issued, consistent with what I believe was the staff approach for NEI 96-07 when 10 CFR 50.59 was modified.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 227 Williams, Joseph From: McGovern, Denise Sent: Tuesday, July 31, 2018 9:21 AM To: Cc:
Subject:
Tier 2 * - Open door discussionGood morning, I am glad that I ran into all 3 of you this morning. Thank you for listening.
Just to clarify; I am not saying this is not safe (I can't answer that). This amendment would change the Tier 2* change process for Vogtle, any other AP1000 wanting to follow, and sets precedence for other design centers.
I am saying this is policy and rule and shouldn't be done without the Commission being aware. Below are 2 examples of what the staff has recently told the Commission.
Tier 2* Paper - https://www.nrc.gov/docs/ML1619/ML16196A321.pdf Existing Design Certifications As stated above, changes in the approach for Tier 2* in future design certifications would not be applied to existing certifications. The existing certified designs are adequate in their current state and satisfy relevant regulatory requirements that assure safety if that design is referenced in a future plant license application. Modification of the certified designs would require rulemaking and would require revising the existing NRC staff safety evaluation. It should be noted that COL applicants and lice nsees might also propose license amendments to change the designation of certain Tier 2* information in their plant-specific final safety analysis reports, which would be reviewed on a case-by-case basis. (Note that this addresses Tier 2* information not change process.)
Transformation Paper - Encl. 5 section b.
https://www.nrc.gov/docs/ML1811/ML18110A186.html "One of the driving factors behind the decision to implement distinct change processes in Parts 50 and 52 was the Commission's goal of maintaining standardization. Revising the Part 52 change process would be a policy shift away from standardization."
Please give me a call any time to discuss.
- Thanks, Denise Denise L. McGovern U.S. Nuclear Regulatory Commission Office of the Secretary 301.415.0681 228 Williams, Joseph From: Habib, Donald Sent: Tuesday, July 31, 2018 12:00 PM To: Williams, Joseph Cc:Segala, John; Dixon-Herrity, Jennifer
Subject:
RE: Follow-Up Question: Tier 2* Vogtle LAR 17-037 Status Importance:High Categories:
Red CategoryJoe -
I'd like to re-ask this question to the review team. Below is a re-statement of the question, that is more limiting and more precise in what we need to conclude, from a safety perspective. The initial question would have resulted in a broader finding statement, but one we might not be able to support and don't have to make in the first place.
Can you please give me feedback on this?
Does the proposed screening process criteria provide reasonable assurance ensure that safety significant changes to Tier 1 equivalent information will come to the NRC for review and approval?
Thanks Don From:Williams,JosephSent:Tuesday,July31,20187:51AMTo:Habib,Donald;Hoellman,Jordan;Green,Brian;Zhao,Jack;Ashley,Clinton;Hansing,Nicholas;Scarbrough,Thomas;VanWert,Christopher;Nolan,Ryan;Honcharik,John;Prescott,Paul;Patel,Pravin;Thomas,VaughnCc:RiveraVarona,Aida;Betancourt,Luis;Jackson,Dian e;Lupold,Timothy;Karas,Rebecca;Mitchell,Matthew;Kavanagh,Kerri;Samaddar,Sujit;Dixon Herrity,Jennifer;Patel,Chandu;Segala,John;Dixon Herrity,Jennifer;Patel,Chandu;Bradford,Anna;Taylor,Robert;Coyne,Kevin;Krohn,Paul;Caldwell,Robert;Monning er,John;McGovern,Denise
Subject:
RE:Follow UpQuestion:Tier2*VogtleLAR17 037StatusI believe a clarification is necessary. In my opinion, staff should not rely upon the 50.59-like criteria for answering the question in Don's message below. Review of the regulatory history for design certifications demonstrates that it was expected that Tier 2* changes would trip a 50.59-like threshold; such changes were sometimes described as "pre-identified unreviewed safety questions." However, when the form of certification rules was established, it was a conscious decision by the Commission to impose additional change controls on Tier 1 and Tier 2* information beyond the 50.59-like process. Therefore, the response to Don's question should rely only on the additional criteria proposed by SNC, i.e., the first page of the Enclosure 4 flowchart from the original submittal, not the second page that relies upon 10 CFR 52 Appendix D paragraph VIII.B.5.a.
Otherwise, the approach is inconsistent with Commission policy.
As outlined in my July 27 email, separate from the discussion above, I think this LAR involves other Commission policy issues that need to be addressed, as well.
Joe Williams
Senior Project Manager 229Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
From:Habib,DonaldSent:Monday,July30,20184:13PMTo:Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Krohn,Paul<Paul.Krohn@nrc.gov
>;Caldwell,Robert<Robert.Caldwell@nrc.gov
>
Subject:
Follow UpQuestion:Tier2*VogtleLAR17 037StatusTier 2* reviewers -
Thanks to all for your timely responses and comments.
By COB tomorrow, can you please reply to the specific question below? I need to make sure each branch is on
board with this conclusion:
For your branch's specific review area, do the screening criteria ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval?
Thanks Don From:Habib,DonaldSent:Thursday,July26,20187:37AMTo:Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert 230<Robert.Taylor@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
Action:ForReview:Tier2*VogtleLAR17 037StatusImportance:HighLAR 17-037 Technical Reviewers -
I need your assistance to finish the SE for this LAR, attached, which contains all of the inputs you have provided, plus much of the DLSE-generated content, which we are still working on.
ACTION: By COB Friday, please take a look at it and confirm that the DLSE-generated discussions are accurate and applicable for your specific review area. This should include the discussion at the beginning of Section 3.1 and for the exemption evaluation in Section 3.2.
Additionally, please affirm that the screening criteria will ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval. The license condition language has had minor changes since the previous (July 12) version. You may also wish to compare your branch input to those from other branches. Some minor editorial changes were made to the inputs (ML#s, licensee vs SNC, etc.)
After we have heard back from the tech branches, made any necessary changes, and received SNC's final submittal, then we will send the SE back to you for formal concurrence. Please let me know if you have questions.
Thanks to all for your efforts on this LAR. Please advise me if you need additional time.
Don Don Habib Project Manager NRO/DLSE, Licensing Branch 4
O-8D13 301-415-1035
From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037StatusDearall-231 ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,includingtheinformationthatDLSEdevelopedregardinghowthereviewwascondu cted.PleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforreviewbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthete chbranches,mad eanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.Haveagreatweekend!
From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037StatusDearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevi e wbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagai n.
Haveagreatweekend!
232
233 Williams, Joseph From: Williams, Joseph Sent: Tuesday, July 31, 2018 12:28 PM To: Habib, Donald Cc:Segala, John; Dixon-Herrity, Jennifer
Subject:
RE: Follow-Up Question: Tier 2* Vogtle LAR 17-037 Status Don, I can provide some feedback. However, my first thought is that we would be better served by a timeout. It's apparent there is not good alignment or understanding across the organization. We need to take a little time to figure out the appropriate standard. The SE doesn't come close to supporting this target.
Joe From:Habib,DonaldSent:Tuesday,July31,201812:00PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>
Subject:
RE:Follow UpQuestion:Tier2*VogtleLAR17 037StatusImportance:HighJoe -
I'd like to re-ask this question to the review team. Below is a re-statement of the question, that is more limiting and more precise in what we need to conclude, from a safety perspective. The initial question would have resulted in a broader finding statement, but one we might not be able to support and don't have to make in the first place.
Can you please give me feedback on this?
Does the proposed screening process criteria provide reasonable assurance ensure that safety significant changes to Tier 1 equivalent information will come to the NRC for review and approval?
Thanks Don From:Williams,JosephSent:Tuesday,July31,20187:51AMTo:Habib,Donald<Donald.Habib@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Segala,John 234<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Krohn,Paul<Paul.Krohn@nrc.gov
>;Caldwell,Robert<Robert.Caldwell@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;McGovern,Denise<Denise.McGovern@nrc.gov
>
Subject:
RE:Follow UpQuestion:Tier2*VogtleLAR17 037StatusI believe a clarification is necessary. In my opinion, staff should not rely upon the 50.59-like criteria for answering the question in Don's message below. Review of the regulatory history for design certifications demonstrates that it was expected that Tier 2* changes would trip a 50.59-like threshold; such changes were sometimes described as "pre-identified unreviewed safety questions." However, when the form of certification rules was established, it was a conscious decision by the Commission to impose additional change controls on Tier 1 and Tier 2* information beyond the 50.59-like process. Therefore, the response to Don's question should rely only on the additional criteria proposed by SNC, i.e., the first page of the Enclosure 4 flowchart from the original submittal, not the second page that relies upon 10 CFR 52 Appendix D paragraph VIII.B.5.a. Otherwise, the approach is inconsistent with Commission policy.
As outlined in my July 27 email, separate from the discussion above, I think this LAR involves other Commission policy issues that need to be addressed, as well.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
From:Habib,DonaldSent:Monday,July30,20184:13PMTo:Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Krohn,Paul<Paul.Krohn@nrc.gov
>;Caldwell,Robert<Robert.Caldwell@nrc.gov
>
Subject:
Follow UpQuestion:Tier2*VogtleLAR17 037StatusTier 2* reviewers -
Thanks to all for your timely responses and comments.
By COB tomorrow, can you please reply to the specific question below? I need to make sure each branch is on board with this conclusion:
235For your branch's specific review area, do the screening criteria ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval?
Thanks Don
From:Habib,DonaldSent:Thursday,July26,20187:37AMTo:Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
Action:ForReview:Tier2*VogtleLAR17 037StatusImportance:HighLAR 17-037 Technical Reviewers -
I need your assistance to finish the SE for this LAR, attached, which contains all of the inputs you have provided, plus much of the DLSE-generated content, which we are still working on.
ACTION: By COB Friday, please take a look at it and confirm that the DLSE-generated discussions are accurate and applicable for your specific review area. This should include the discussion at the beginning of Section 3.1 and for the exemption evaluation in Section 3.2. Additionally, please affirm that the screening criteria will ensure that changes to Tier 1 equivalent information will come to the NRC for review and approval. The license condition language has had minor changes since the previous (July 12) version. You may also wish to compare your branch input to those from other branches. Some minor editorial changes were made to the inputs (ML#s, licensee vs SNC, etc.)
After we have heard back from the tech branches, made any necessary changes, and received SNC's final submittal, then we will send the SE back to you for formal concurrence. Please let me know if you have questions.
Thanks to all for your efforts on this LAR. Please advise me if you need additional time.
Don Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13 301-415-1035
236 From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037Status
Dearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,
DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevi e wbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.
Haveagreatweekend!
From:Hoellman,JordanSent:Friday,July20,20189:14AMTo:Green,Brian<Brian.Green@nrc.gov
>;Zhao,Jack<Jack.Zhao@nrc.gov
>;Ashley,Clinton<Clinton.Ashley@nrc.gov
>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov
>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov
>;VanWert,Christopher<Christopher.VanWert@nrc.gov
>;Nolan,Ryan<Ryan.Nolan@nrc.gov
>;Honcharik,John<John.Honcharik@nrc.gov
>;Prescott,Paul<Paul.Prescott@nrc.gov
>;Patel,Pravin<Pravin.Patel@nrc.gov
>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov
>Cc:RiveraVarona,Aida<Aida.RiveraVarona@nrc.gov
>;Betancourt,Luis<Luis.Betancourt@nrc.gov
>;Jackson,Diane<Diane.Jackson@nrc.gov
>;Lupold,Timothy<Timothy.Lupold@nrc.gov
>;Karas,Rebecca<Rebecca.Karas@nrc.gov
>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov
>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov
>;Samaddar,Sujit 237<Sujit.Samaddar@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov
>;Williams,Joseph<Joseph.Williams@nrc.gov
>;Segala,John<John.Segala@nrc.gov
>;DixonHerrity,Jennifer<Jennifer.Dixon Herrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Patel,Chandu<Chandu.Patel@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>
Subject:
Tier2*VogtleLAR17 037StatusDearall-ThankstoallofyouforyourhardworkontheTier2*LAR.Wewouldliketoletyouknowwhatthenextstepsare.Earlynextweek,DLSEwillbesendingyouanearlydraftofthewholeSEsothatyoucanseetheentiredocument,in cludi ngtheinformationthatDLSEdevelopedregardinghowthereviewwasconducted.Pleasetakealookatitandconfirmthatourdescriptionisaccurateandthatyouarecomfortablethattheproposedlicenseconditionswilladequatelyensurethatitemsthatneedtocomebacktotheagencyforrevi e wbeforetheyarechangedbySNCareappropriatelycovered.Afterwehaveheardbackfromthetechbranches,madeanynecessarychanges,andreceivedSNC'sfinalsubmittal,thenwewillsendtheSEbacktoyouforformalconcurrence.Pleaseletusknowifyouhavequestions.Thanksagain.Haveagreatweekend!
238 Williams, Joseph From: Williams, Joseph Sent: Tuesday, July 31, 2018 12:36 PM To:Monninger, John; Coyne, Kevin Cc: Segala, John
Subject:
Tier 2* SE Attachments:
RE: Follow-Up Question: Tier 2* Vogtle LAR 17-037 StatusFYI, the attached message shows a brief exchange between Don Habib and I regarding DLSE's follow up question to the Tier 2* LAR reviewers. My opinion: we need to stop the bleeding. Call a timeout and get aligned. If that means starting over, so be it.
Joe 239 Williams, Joseph From: Habib, Donald Sent: Saturday, August 04, 2018 6:28 PM To:Prescott, Paul; Patel, Pravin; Thomas, Vaughn; Van Wert, Christopher; Williams, Joseph; Zhao, Jack; Hansing, Nicholas; Scarbrough , Thomas; Nolan, Ryan; Ashley, Clinton Cc:Patel, Chandu; Dixon-Herrity, Jennifer; Sa maddar, Sujit; Kavanagh, Kerri; Segala, John; Betancourt, Luis; Lupold, Timothy; Mitchell, Matthew; Jackson, Diane; Karas, Rebecca; Bradford, Anna
Subject:
For Review and Response: Updated Response for Vogtle Tier 2* LAR Attachments:
ND-18-1006_LAR-17-037S4_Roll-up and RAI-2 response_final-2 with enclosur....pdf Review Team -
Attached for your review is SNC's most recent supplement for LAR 17-037. The ADAMS link appears below.
Please verify that the supplement contains the expected informati on supporting your SE input, and reply about whether the submittal is OK or is missing something.
This submittal should contain an updated version of the original submittal, the previous 3 supplements, and additional information previously sent to us as draft. This submittal should include the necessary information to resolve all RAIs and other issues we have identified to SNC. The letter outlines the numerous enclosures, as follows:
Enclosures 1 through 8 were provided with the original LAR-17-037, in SNC letter ND-17-1726. Enclosure 9 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 provided a revised response to RAI LAR-17-037-1, and the initial responses to RAIs LAR-17-037-3 and RAI LAR-17-037-4, respectively, in SNC letter ND-18-0608. Enclosures 13, 14, 15, 16, and 17 provided the responses to RAIs LAR-17-037-5, -6, -7, -8, and -9, respectively, in SNC letter ND-18-0646. Enclosure 18, included in this letter, provides the response to RAI LAR-17-037-2. Enclosure 19, provides the response to the question from the NRC staff regarding Tier 2* text addressing firstof-a-kind testing.
After you respond, I will update your SE inputs with a confirmation statement.
Thanks Don
View ADAMS Properties ML18215A461 Open ADAMS Document (E180803t044805)
240 Williams, Joseph From: Williams, Joseph Sent: Monday, August 06, 2018 9:25 AM To:Ashley, Clinton; Betancourt, Luis; Hansing, Nicholas; Honcharik, John; Nolan, Ryan; Patel, Pravin; Scarbrough, Thomas; Thomas, Vaughn; Van Wert, Christopher Cc:Monninger, John; Coyne, Kevin; Cubbage, Amy; Taylor, Robert; Bradford, Anna; Dixon-Herrity, Jennifer; Habib, Donald; McGovern, Denise; Segala, John
Subject:
Vogtle Tier 2* LAR Briefing for Fred Brown - Friday, August 10 Attachments:RE: Clarification of Purpose of Fr ed Brown Briefing on Tier 2* LAR Importance:HighWhen Fred Brown talked at the NRO All Hands meeting about the Vogtle Tier 2* LAR, he indicated that a meeting is scheduled for this Friday, August 10 to ensure decision makers understand all the issues. His discussion was the direct outcome of feedback he has received from me and others regarding various issues that have arisen in the course of reviewing this LAR.
To prepare for that meeting, I asked Fred for clarification of the purpose and expected outcome of the August 10 meeting. His response is attached for your information. You'll see that he says that "Anyone else with concerns is also welcome (and requested) to take advantage of the meeting to make sure that their concerns are understood." I plan to take Fred at his word to convey my thoughts to him and others as best I can. I have had conversations with several of you over the course of this review which suggest that you might share at least some of the concerns I've outlined. If you also have concerns with this review, I encourage you to take advantage of this opportunity, as well. We can't hold management responsible for something we don't tell them. If you don't feel comfortable bringing issues forward yourself, I can try to do so myself if you are willing to describe your thoughts to me.
The issues I am raising fall into three categories. First, this LAR involves policy issues that need to be presented for decisions by the Commission, as the LAR represents a significant deviation from the Commission-approved fundamental structure and change controls for certified design information. The generic implications of the proposal also need to be addressed. Second, the process followed for this review has "put the cart before the horse," where RAIs were solicited and issued before acceptance criterial or review expectations were established and communicated. There has also not been a clear and consistent relationship between the questions and the findings that needed to be made, with incomplete preliminary guidance setting expectations for SE input has only been provided very recently, several months after receipt of the LAR, well after RAI milestones. I believe the process to date has created a chilling effect which has adversely affected the free and open discussion of possible issues and challenges associated with this unique first-of-a-kind LAR. It has been characterized to me as a "strange process that has been shoved down our throats," which I think is a pretty good description of how things have played out. The third issue is linked to the process concerns, as I think the draft SE was significantly flawed, as it did not adequately describe the findings that need to be made. As described in my July 27, 2018 email, I believe the framework provided by DLSE is unclear, and the findings regarding specific topics are not internally consistent. I know DLSE is revising the draft SE, so perhaps some of my concerns will be mitigated.
I also want to address some rumors that have made it back to me about my intent to use differing views processes. I think there is a strong possibility I will non-concur in the SE, but that decision is contingent on how effectively the issues I have communicated are addressed in the final product. It is my intent to communicate as clearly as I can beforehand to help people understand my point of view so that the issues can be resolved without using the non-concurrence process, but I am prepared to use that tool if we can't reach alignment. In a similar vein, I've heard a claim that I intend to file a DPO. That process is invoked only for completed products, so there would be little point in using that process, as an attempt to reverse a decision on a completed license amendment would have to meet a backfit test that I don't think could be met in this case.
241 I appreciate the feedback I've received from some of you over the last several weeks. This has not been an easy task, so that support is quite helpful.
Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
243From:Williams,JosephSent:Monday,August06,20188:24AMTo:
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LAR(statusofSER) I'd like t o se e it. When can you send it to me?
Joe From:Sent:Thursday,August02,20184:34PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LAR(statusofSER)Joe -
Regarding your preparation for this meeting, the SER will still be in-process at the time we have it. I can share an updated in-process version of the document with you, for information only, prior to the meeting, so that you can see what the document is saying.
Let me know whether you are interested in this, keeping in mind that it would still be a work in progress (further along that the last version shared, but likely still rough, not yet having any concurrences or really any review).
From:Brown,FrederickSent:Thursday,August02,20184:01PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;McGovern,Denise<Denise.McGovern@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LARHi Joe, What I requested was a meeting so that you could go through your concerns with the path we are on for the SE so that all the involved parties could hear them and ensure that they are understood. Anyone else with concerns is also welcome (and requested) to take advantage of the meeting to make sure that their concerns are understood.
We would have done this earlier (including at the very beginning of the review), as you originally requested, however I was under the misunderstanding that your only concern was the policy concern that you discussed with me in May. Now that I know there are other concerns (as discussed at the all hands meeting yesterday), I want to circle back and make sure that the person that ultimately approves the LAR understands and has considered any open concerns prior to finalizing the SE.
In addition, as a result of my long-standing and ongoing discussion of this topic in my periodics with the Commissioners and their staffs', I plan on sending up a CA Note with the near-final SE for Commission awareness of our final dispositioning of the LAR request. My intent is that the note provide at least a high-level acknowledgement of any open items of disagreement with our final position. That will be a lot easier if we are 244 sure what the areas of disagreement are . I understand that the SE is not yet final, so things that are open next Friday may end up being addressed and fall off the list. That would certainly be one measure of success , and I think would be more likely to happen with a complete mutual understanding than without one.
Hope this helps you prepare. Please let me know if you have any additional questions.
Fred From:Williams,JosephSent:Thursday,August02,20183:22PMTo:Brown,Frederick<Frederick.Brown@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;McGovern,Denise<Denise.McGovern@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LARImportance:HighFred, See the exchange below. I'm still not clear on the expected purpose, outcome, or process for the meeting. I'd appreciate clarification by Monday so I can prepare to provide the information you are seeking.
Thanks.
Joe From:Bradford,AnnaSent:Wednesday,August01,20189:37AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>
Subject:
Re:ClarificationofPurposeofFredBrownBriefingonTier2*LARHiJoe.IhadsharedwithFredtheemailthatyousentyesterday,takingabouthowreviewersshouldn'trelyonthe50.59process(I'mparaphrasing).Andyouremailpromptedhimtosaythathewantedtomeettodiscussyourconcern.That'sallIknow.iscurrentlygoingthroughthecommentsreceivedfromthetechbranchesandrevisingtheSEbutI'mnotsureifthosechangeswouldaddressyo urconcerns.I'montravelandhaven'tseenarecentversion.
AnnaH.BradfordDeputyDirectorDivisionofLicensing,Siting,andEnvironmentalAnalysis(DLSE)U.S.NuclearRegulatoryCommission301 415 156 0 245On:01August201809:24,"Williams,Joseph"<Joseph.Williams@nrc.gov
>wrote:I can envision a pretty broad range for the intended purpose and outcome of the briefing for Fred on August 10, so it's not easy to figure out how to prepare. Can you help me out? I would also like to know what is planned to be done in the meantime. For instance, do you plan revisions to the SE? Thanks. Joe 246 Williams, Joseph From: Brown, Frederick Sent: Monday, August 06, 2018 4:24 PM To: Williams, Joseph Cc:Segala, John; Dixon-Herrity, Jennifer; Habib, Donald; Monninger, John; Coyne, Kevin; Bradford, Anna; Ordaz, Vonna; Taylor, Robert; McGovern, Denise; Cubbage, Amy
Subject:
RE: Clarification of Purpose of Fr ed Brown Briefing on Tier 2* LAR Hi Joe, My short hand for what I heard from you and Denise is much less important than you providing your issues in your own words and then us making sure we have a common understanding.
Fred From:Williams,JosephSent:Monday,August06,20189:43AMTo:Brown,Frederick<Frederick.Brown@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov>;Taylor,Robert<Robert.Taylor@nrc.gov>;McGovern,Denise<Denise.McGovern@nrc.gov>;Cubbage,Amy<Amy.Cubbage@nrc.gov>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LARFred, Your note is helpful. I've forwarded it to the other revi ewers to be sure th ey are aware of your interest in hearing the f ull story.
Some reviewers have told me they were unable to attend the All Hands meeting last week. It would be very helpful if you could take a few minutes to give us bullets on the 5 issues you discussed in the meeting. I know you're very busy, so I appreciate any time you can spare to describe the issues in your own words.
Thanks.
Joe From:Brown,FrederickSent:Thursday,August02,20184:01PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;McGovern,Denise<Denise.McGovern@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LARHi Joe, What I requested was a meeting so that you could go through your concerns with the path we are on for the SE so that all the involved parties could hear them and ensure that they are understood. Anyone else with 247concerns is also welcome (and requested) to take advantage of the meeting to make sure that their concerns are understood.
We would have done this earlier (including at the very beginning of the review), as you originally requested, however I was under the misunderstanding that your only concern was the policy concern that you discussed with me in May. Now that I know there are other concerns (as discussed at the all hands meeting yesterday), I want to circle back and make sure that the person that ultimately approves the LAR understands and has considered any open concerns prior to finalizing the SE.
In addition, as a result of my long-standing and ongoing discussion of this topic in my periodics with the Commissioners and their staffs', I plan on sending up a CA Note with the near-final SE for Commission awareness of our final dispositioning of the LAR request. My intent is that the note provide at least a high-level acknowledgement of any open items of disagreement with our final position. That will be a lot easier if we are
sure what the areas of disagreement are . I understand that the SE is not yet final, so things that are open next Friday may end up being addressed and fall off the list. That would certainly be one measure of success , and I think would be more likely to happen with a complete mutual understanding than without one.
Hope this helps you prepare. Please let me know if you have any additional questions.
Fred From:Williams,JosephSent:Thursday,August02,20183:22PMTo:Brown,Frederick<Frederick.Brown@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;McGovern,Denise<Denise.McGovern@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LARImportance:HighFred, See the exchange below. I'm still not clear on the expected purpose, outcome, or process for the meeting. I'd appreciate clarification by Monday so I can prepare to provide the information you are seeking.
Thanks.
Joe From:Bradford,AnnaSent:Wednesday,August01,20189:37AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>
Subject:
Re:ClarificationofPurposeofFredBrownBriefingonTier2*LARHiJoe.IhadsharedwithFredtheemailthatyousentyesterday,takingabouthowreviewersshouldn'trelyonthe50.59process(I'mparaphrasing).Andyouremailpromptedhimtosaythathewantedtomeettodiscussyourconcern.That'sallIknow.
248iscurrentlygoingthroughthecommentsreceivedfromthetechbranchesandrevisingtheSEbutI'mnotsureifthosechangeswouldaddressyo urconcerns.I'montravelandhaven'tseenarecentversion.
AnnaH.BradfordDeputyDirectorDivisionofLicensing,Siting,andEnvironmentalAnalysis(DLSE)U.S.Nuclea rRegulatoryCommission301 4151560
On:01August201809:24,"Williams,Joseph"<Joseph.Williams@nrc.gov
>wrote:I can envision a pretty broad range for the intended purpose and outcome of the briefing for Fred on August 10, so it's not easy to figure out how to prepare. Can you help me out? I would also like to know what is planned to be done in the meantime. For instance, do you plan revisions to the SE? Thanks. Joe 249 Williams, Joseph From: Habib, Donald Sent: Tuesday, August 07, 2018 2:16 PM To:Prescott, Paul; Patel, Pravin; Thomas, Vaughn; Van Wert, Christopher; Williams, Joseph; Zhao, Jack; Hansing, Nicholas; Scarbrough , Thomas; Nolan, Ryan; Ashley, Clinton; Green, Brian; Honcharik, John Cc:Patel, Chandu; Dixon-Herrity, Jennifer; Sa maddar, Sujit; Kavanagh, Kerri; Segala, John; Betancourt, Luis; Lupold, Timothy; Mitchell, Matthew; Jackson, Diane; Karas, Rebecca; Bradford, Anna; Rivera-Varona, Aida
Subject:
Reminder: Updated Response for Vogtle Tier 2* LAR Attachments:
ND-18-1006_LAR-17-037S4_Roll-up and RAI-2 response_final-2 with enclosur....pdfTier 2* LAR Review Team -
This is just a reminder to look at this final submittal carefully to ensure that it has been appropriately updated to contain the correct information from previous formal and informal submittals.
Please reply by COB Friday either way, if you find an issue or when you have confirmed that the submittal contains the appropriate information.
Thanks Don From:Habib,DonaldSent:Saturday,August04,20186:28PMTo:Prescott,Paul<Paul.Prescott@nrc.gov>;Patel,Pravin<Pravin.Patel@nrc.gov>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov>;VanWert,Christopher<Christopher.VanWert@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Zhao,Jack<Jack.Zhao@nrc.gov>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov>;Nolan,Ryan<Ryan.Nolan@nrc.gov>;Ashley,Clinton<Clinton.Ashley@nrc.gov>Cc:Patel,Chandu<Chandu.Patel@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Samaddar,Sujit<Sujit.Samaddar@nrc.gov>;Kavanagh,Kerri<Kerri.Kavanagh@nrc.gov>;Segala,John<John.Segala@nrc.
g ov>;Betancourt,Luis<Luis.Betancourt@nrc.gov>;Lupold,Timothy<Timothy.Lupold@nrc.gov>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>;Karas,Rebecca<Rebecca.Karas@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>
Subject:
ForReviewandResponse:UpdatedResponseforVogtleTier2*LAR Review Team -
Attached for your review is SNC's most recent supplement for LAR 17-037. The ADAMS link appears below.
Please verify that the supplement contains the expected informati on supporting your SE input, and reply about whether the submittal is OK or is missing something.
This submittal should contain an updated version of the original submittal, the previous 3 supplements, and additional information previously sent to us as draft. This submittal should include the necessary information to resolve all RAIs and other issues we have identified to SNC. The letter outlines the numerous enclosures, as follows:
250Enclosures 1 through 8 were provided with the original LAR-17-037, in SNC letter ND-17-1726. Enclosure 9 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 provided a revised response to RAI LAR-17-037-1, and the initial responses to RAIs LAR-17-037-3 and RAI LAR-17-037-4, respectively, in SNC letter ND-18-0608. Enclosures 13, 14, 15, 16, and 17 provided the responses to RAIs LAR-17-037-5, -6, -7, -8, and -9, respectively, in SNC letter ND-18-0646. Enclosure 18, included in this letter, provides the response to RAI LAR-17-037-2. Enclosure 19, provides the response to the question from the NRC staff regarding Tier 2* text addressing firstof-a-kind testing.
After you respond, I will update your SE inputs with a confirmation statement.
Thanks Don
View ADAMS Properties ML18215A461 Open ADAMS Document (E180803t044805)
251 Williams, Joseph From: Sent: Wednesday, August 08, 2018 7:39 AM To: Williams, Joseph
Subject:
RE: Clarification of Purpose of Fred Brown Briefing on Tier 2* LAR (status of SER)
Attachments:
2018-08-07 Safety Evaluation - LAR 17-037.docx Categories:
Red CategoryJoe - Here you go . . .
Major things are: I still need to add the public comment discussion, plus some of the discipline-specific write-ups need some information added or changed.
My management is currently reviewing this version. Please don't share it until I have a chance to address their comments.
Thanks From:Williams,JosephSent:Wednesday,August08,20187:29AMTo:
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LAR(statusofSER) Can you send me the current version of the SE to help me prepare for talking to Fred on Friday? It would also be helpful if you can give me an idea of what additional changes you envision.
Thanks.
Joe From:Williams,JosephSent:Monday,August06,20184:22PMTo:
Subject:
Re:ClarificationofPurposeofFredBrownBriefingonTier2*LAR(statusofSER) On:06August201815:10," wrote:
254From:Sent:Thursday,August02,20184:34PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LAR(statusofSER)Joe - Regarding your preparation for this meeting, the SER will still be in-process at the time we have it. I can share an updated in-process version of the document with you, for information only, prior to the meeting, so that you can see what the document is saying. Let me know whether you are interested in this, keeping in mind that it would still be a work in progress (further along that the last version shared, but likely still rough, not yet having any concurrences or really any review). From:Brown,FrederickSent:Thursday,August02,20184:01PMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;McGovern,Denise<Denise.McGovern@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LARHi Joe, What I requested was a meeting so that you could go through your concerns with the path we are on for the SE so that all the involved parties could hear them and ensure that they are understood. Anyone else with concerns is also welcome (and requested) to take advantage of the meeting to make sure that their concerns are understood. We would have done this earlier (including at the very beginning of the review), as you originally requested, however I was under the misunderstanding that your only concern was the policy concern that you discussed with me in May. Now that I know there are other concerns (as discussed at the all hands meeting yesterday), I want to circle back and make sure that the person that ultimately approves the LAR understands and has considered any open concerns prior to finalizing the SE. In addition, as a result of my long-standing and ongoing discussion of this topic in my periodics with the Commissioners and their staffs', I plan on sending up a CA Note with the near-final SE for Commission awareness of our final dispositioning of the LAR request. My intent is that the note provide at least a high-level acknowledgement of any open items of disagreement with our final position. That will be a lot easier if we are sure what the areas of disagreement are . I understand that the SE is not yet final, so things that are open next Friday may end up being addressed and fall off the list. That would certainly be one measure of success , and I think would be more likely to happen with a complete mutual understanding than without one. Hope this helps you prepare. Please let me know if you have any additional questions. Fred From:Williams,JosephSent:Thursday,August02,20183:22PMTo:Brown,Frederick<Frederick.Brown@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald 255<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>;Bradford,Anna<Anna.Bradford@nrc.gov
>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>;McGovern,Denise<Denise.McGovern@nrc.gov
>
Subject:
RE:ClarificationofPurposeofFredBrownBriefingonTier2*LARImportance:HighFred, See the exchange below. I'm still not clear on the expected purpose, outcome, or process for the meeting. I'd appreciate clarification by Monday so I can prepare to provide the information you are seeking. Thanks. Joe From:Bradford,AnnaSent:Wednesday,August01,20189:37AMTo:Williams,Joseph<Joseph.Williams@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>Cc:Segala,John<John.Segala@nrc.gov
>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov
>;Habib,Donald<Donald.Habib@nrc.gov
>;Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>
Subject:
Re:ClarificationofPurposeofFredBrownBriefingonTier2*LARHiJoe.IhadsharedwithFredtheemailthatyousentyesterday,takingabouthowreviewersshouldn'trelyonthe50.59process(I'mparaphrasing).Andyouremailpromptedhimtosaythathewantedtomeettodiscussyourconcern.That'sallIknow.iscurrentlygoingthroughthecommentsreceivedfromthetechbranchesandrevisingtheSEbutI'mnotsureifthosechangeswouldaddressyourconcerns.I'montravelandhaven'tseenarecentversion.
AnnaH.BradfordDeputyDirectorDivisionofLicensing,Siting,andEnvironmentalAnalys is(DLSE)U.S.NuclearRegulatoryCommission301 4151560On:01August201809:24,"Williams,Joseph"<Joseph.Williams@nrc.gov
>wrote:I can envision a pretty broad range for the intended purpose and outcome of the briefing for Fred on August 10, so it's not easy to figure out how to prepare. Can you help me out? I would also like to know what is planned to be done in the meantime. For instance, do you plan revisions to the SE? Thanks. Joe 256 Williams, Joseph From: Habib, Donald Sent: Friday, August 10, 2018 7:29 AM To: Williams, Joseph
Subject:
2018-08-08pm Safety Evaluation - LAR 17-037 (with responses to public comment)
Attachments:
2018-08-08pm Safety Evaluation - LAR 17-037.docx Importance:High Categories:
Red CategoryJoe - This version includes responses to Ravi's comments, in Section 5.
Thanks Don 257 Williams, Joseph From: Williams, Joseph Sent: Friday, August 10, 2018 12:48 PM To: Brown, Frederick; Ordaz, Vonna; Krohn, Paul
- Bradford, Anna; Dixon-Herrity, Jennifer; Habib, Donald; Coyne, Kevin; Monninger, John; Helton, Shana Cc
- Ashley, Clinton; Betancourt, Luis; Hansing, Nicholas; Honcharik, John; Nolan, Ryan; Patel, Pravin; Scarbrough, Thomas; Thomas, Vaughn; Van Wert, Christopher
Subject:
Comments on Draft Vogtle Ti er 2* Safety Evaluation Attachments:
2018-08-07 Safety Evaluation - LAR 17-037 JFW comments.docx For your information, the attached file summarizes my comments on a version of the draft SE for the Vogtle Tier 2* amendment and exemption. This document is the basis of many of the comments I provided in today's management meeting.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470
258 Williams, Joseph From: Williams, Joseph Sent: Friday, August 10, 2018 2:44 PM To: Habib, Donald Cc:Segala, John; Dixon-Herrity, Jennifer; McGovern, Denise
Subject:
RE: Tier 2* Finding Statement for SER Don, Here's a quick cut for your consideration:
- 1. There should be reasonable assurance that the proposed screening criteria can clearly and reliably discriminate between Tier 2* information that is Tier 1-equivalent, and other information. 2. Changes to Tier 1-equivalent information must be reviewed and approved by NRC before implementation. 3. Other information will be subject to 50.59-like change controls. It is not acceptable for Tier 1-equivalent information to be screened in this step, as such an approach would be inconsistent with Commission-approved processes for certified design change controls. At the very least, it creates the possibility that Tier 1-equivalent information would not come to NRC for prior review and approval, which is an obviously unacceptable outcome. The Commission put additional controls in place, knowing full well that the 50.59-like process existed, but nonetheless chose to impose additional controls.
In this model, the emphasis is on the ability of the screening criteria proposed by SNC to reliably identify Tier 1-equivalent content. It's my understanding that this is in line with what was discussed at the June 27 meeting.
I think we also need to be careful about how the term "safety significant" is used. I think "potentially safety significant" is closer to the mark. NRC reviews a lot of changes affecting safety significant SSCs where the change itself isn't safety significant (might even be an improvement), but could have negative consequences if it's done badly.
I think it would be useful to would be helpful.
Joe _____________________________________________From:Habib,DonaldSent:Friday,August10,20182:04PMTo:Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Segala,John<John.Segala@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>
Subject:
RE:Tier2*FindingStatementforSERImportance:HighJoe -
The finding/conclusion statement we asked the staff to make is as follows (from the guidance in late June):
The proposed screening process continues to assure that any safety-significant change to Tier 2* information would require NRC approval or will otherwise receive appropriate control:
259o Because such a change would also affect Tier 1 o Because such a change would trip at least one of the (50.59-like) criteria in 10 CFR Part 52, Appendix D, Section VIII.B.5.b o Because such a change would trip at least one of the newly proposed criteria in the LAR o Because of another reason Can you please either make an appropriate edit to it where you think it is not sufficient OR give me a succinct description of a change that would be appropriate?
Thanks Don
OriginalAppointmentFrom:Brown,FrederickSent:Tuesday,July31,20182:32PMTo:Brown,Frederick;Monninger,John;Coyne,Kevin;Taylor,Robert;Bradford,Anna;Segala,John;Dixon Herrity,Jennifer;Habib,Donald;Williams,Joseph;Cubbage,Amy;McGovern,Denise;Cc:NRO_Deputy_Division_Directors;NRO_Division_Directors;Helton,Shana;Krohn,Paul;Ordaz,Vonna;OGC_CAL_RPResource;Caldwell,Robert;Miller,Fred;NRO_DEI_CALResource;Ashley,Clinton;Betancourt,Luis;Hansing,Nicholas;Honcharik,John;Nolan,Ryan;Patel,Pravin;Scarbrough,Thomas;Thomas,Vaughn;VanWert,Christopher
Subject:
DiscussstaffconcernsabouttheVogtleTier2*LARWhen:Friday,August10,201810:30AM 11:30AM(UTC 05:00)EasternTime(US&Canada).Where:HQOWFN 04B06 30pPlease let me know if you wish to join by phone and I will cre ate a bridgel ine. - Deanna Royer
261 Williams, Joseph From: Habib, Donald Sent: Tuesday, August 21, 2018 12:10 PM To: Karas, Rebecca; Van Wert, Christopher; Nolan, Ryan; Jackson, Diane; Ashley, Clinton; Segala, John; Williams, Joseph; Rivera-Varona, Aida; Green, Brian; Betancourt, Luis; Zhao, Jack; Mitchell, Matthew; Honcharik, John; Samaddar, Sujit; Patel, Pravin; Thomas, Vaughn; Lupold, Timothy; Scarbrou gh, Thomas; Hansing, Nicholas Cc:Dixon-Herrity, Jennifer; Hoe llman, Jordan; Bradford, Anna
Subject:
Action: Request for Review and Concurrence (LAR 17-037)
Attachments:
2018-08-21am Safety Evaluation - LAR 17-037 ML18207A262.docx Importance:High Follow Up Flag:Follow up Due By: Tuesday, August 21, 2018 2:30 PM Flag Status:
Flagged LAR 17-037 Review Team:
Attached for your review and concurrence is the safety evaluation for Vogtle LAR 17-037 (Tier 2* Departure Evaluation Process).
Please provide your comments and concurrence by COB Tuesday August 28. Some of the SE inputs from the technical branches have been edited for consistency and to assure that they support the overall conclusion of the SE. Therefore, you may wish to compare this concurrence version with your original input.
At a minimum, review the front portion of the SER, up to the beginning of Section 3.1.1, plus the updated version of your branch input. Your branch input should be consistent with the front material.
For any question/comment on an individual branch input, please provide an appropriate edit or response (SRSB, SEB, HOIB) with the technical staff review and concurrence. Therefore, I will follow up with you if there are
Thanks Don Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13 301-415-1035 262 Williams, Joseph From: Williams, Joseph Sent: Tuesday, August 21, 2018 12:15 PM To:Segala, John; Monninger, John; Coyne, Kevin
Subject:
FW: Action: Request for Review and Concurrence (LAR 17-037)
Attachments:
2018-08-21am Safety Evaluation - LAR 17-037 ML18207A262.docx Importance:HighFYI. I haven't looked at it, so I don't yet have any reaction to share. I will note that I think it is out of process to demonstrating what I consider to be a continuing undue emphasis on schedule.
From:Habib,DonaldSent:Tuesday,August21,201812:10PMTo:Karas,Rebecca<Rebecca.Karas@nrc.gov>;VanWert,Christopher<Christopher.VanWert@nrc.gov>;Nolan,Ryan<Ryan.Nolan@nrc.gov>;Jackson,Diane<Diane.Jackson@nrc.gov>;Ashley,Clinton<Clinton.Ashley@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Williams,Joseph<Joseph.Williams@nrc.gov>;Rivera Varona,Aida<Aida.Rivera Varona@nrc.gov>;Green,Brian<Brian.Green@nrc.gov>;Betancourt,Luis<Luis.Betancourt@nrc.gov>;Zhao,Jack<Jack.Zhao@nrc.gov>;Mitchell,Matthew<Matthew.Mitchell@nrc.gov>;Honcharik,John<John.Honcharik@nrc.gov>;Samaddar,Su jit<Sujit.Samaddar@nrc.gov>;Patel,Pravin<Pravin.Patel@nrc.gov>;Thomas,Vaughn<Vaughn.Thomas@nrc.gov>;Lupold,Timothy<Timothy.Lupold@nrc.gov>;Scarbrough,Thomas<Thomas.Scarbrough@nrc.gov>;Hansing,Nicholas<Nicholas.Hansing@nrc.gov>Cc:Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Hoellman,Jordan<Jordan.Hoellman2@nrc.gov>;Bradford,Anna<Anna.Bradford@nrc.gov>
Subject:
Action:RequestforReviewandConcurrence(LAR17037)Importance:High LAR 17-037 Review Team:
Attached for your review and concurrence is the safety evaluation for Vogtle LAR 17-037 (Tier 2* Departure Evaluation Process).
Please provide your comments and concurrence by COB Tuesday August 28. Some of the SE inputs from the technical branches have been edited for consistency and to assure that they support the overall conclusion of the SE. Therefore, you may wish to compare this concurrence version with your original input.
At a minimum, review the front portion of the SER, up to the beginning of Section 3.1.1, plus the updated version of your branch input. Your branch input should be consistent with the front material.
For any question/comment on an individual branch input, please provide an appropriate edit or response (SRSB, SEB, HOIB) with the technical staff review and concurrence. Therefore, I will follow up with you if there are Thanks Don 263 Don Habib
Project Manager NRO/DLSE, Licensing Branch 4 O-8D13 301-415-1035 264 Williams, Joseph From: Williams, Joseph Sent: Wednesday, August 22, 2018 12:49 PM To: Brown, Frederick; Ordaz, Vonna; Monninger, Jo hn; Coyne, Kevin; Bradford, Anna; Taylor, Robert; Segala, John; Dixon-Herrity, Jennifer Cc: McGovern, Denise; Figueroa Toledo, Gladys; Harrison, John; Hoellman, Jordan; Habib, Donald
Subject:
Decision to Non-Concur in Vogtle Tier 2* LAR Safety Evaluation Categories:
Red CategoryIn accordance with the requirements of MD 10.158, "NRC Non-concurrence Process,"
I am notifying you of my decision to apply that process to non-concur in review of a safety evaluation associated with Vogtle LAR 17-037, ADAMS accession number ML18207A262.
MD and DH 10.158 set requirements for managers responsible for processing a non-concurrence, along with expectations for staff engaging in that process. I request a meeting to review these requirements to ensure the awareness of all parties involved.
DH 10.158 Section F describes means for exercising discretion to engage in the non-concurrence process (NCP), stating that An NRC employee who is not eligible to use the NCP may approach his or her immediate supervisor, document signer, another manager in their organization, or the NCP Program Manager (PM) and request to engage in the NCP if he or she believes they have specific information that would enhance the decisionmaking process and that use of the NCP would be in the interest of the agency as a knowledge management tool.
and A document signer should allow an employee to engage in the NCP if he or she believes the employee has specific information that would enhance the decisionmaking process and use of the NCP would be in the interest of the agency as a knowledge management tool.
I request that Denise McGovern be authorized to engage in this non-concurrence consistent with these provisions. Denise served as the lead project manager for the Summer AP1000 COL, and is deeply knowledgeable about that license, the AP1000 certified design, and the Part 52 licensing process. She worked closely with the Vogtle COL lead project manager, including discussions involving a previous LAR of similar scope that was withdrawn by the licensee. She has already engaged with NRO staff and management on this issue, and her experience and perspectives are directly relevant to the topic.
I will place this message in ADAMS, profiled as non-publicly available.
Joe Williams Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors
Office of New Reactors 301.415.1470 265 Williams, Joseph From: Segala, John Sent: Thursday, August 23, 2018 7:57 AM To: Williams, Joseph
Subject:
FW: SNC Tier 2* meeting tomorrow - 9 a.m.
Attachments:
SNC Tier 2 star Presentation Slides.pdf
- Nonacceptance Letter - rev LJB.docx; IBMgetContent.pdf From
- Akstulewicz,FrankSent:Thursday,October23,201411:08AMTo:NRO_DNRL_Branch_Chiefs<NRODNRLBranchChiefs@nrc.gov>;NRO_Division_Directors<NRODivisionDirectors@nrc.gov>;NRO_Deputy_Division_Directors<NRODeputyDivisionDir@nrc.gov>Cc:Holahan,Gary<Gary.Holahan@nrc.gov>;Tracy,Glenn<Glenn.Tracy@nrc.gov>
Subject:
FW:SNCTier2*meetingtomorrow9a.m.Presentation 1 is the SNC arguments for moving forward - please review so that we can make a final decision on accepting or rejecting the proposal From: Burkhart, Lawrence Sent: Wednesday, October 22, 2014 9:12 AM To: Akstulewicz, Frank; Delligatti, Mark; McGovern, Denise; Reyes, Ruth; Jaffe, David; Bavol, Bruce; Libby, Earl; Tonacci, Mark; Joshi, Ravindra; Wilson, Anthony; Junge, Michael
Subject:
SNC Tier 2* meeting tomorrow - 9 a.m. Just for your prep and info, attached are:
-SNC's exemption request
-SNC's intended presentation for tomorrow
-NRC's draft letter (not concurred on yet)
Please note that there are several examples of Tier 2* LARs (structural and HFE) that SNC is claiming weren't safety significant - we should review and be prepared to discuss.
Larry 266 Williams, Joseph From: Coyne, Kevin Sent: Thursday, August 23, 2018 8:40 AM To: Williams, Joseph
Subject:
FW: Action: Request for Review and Concurrence (LAR 17-037)
From:Bradford,AnnaSent:Tuesday,August21,20183:07PMTo:Coyne,Kevin<Kevin.Coyne@nrc.gov>;Taylor,Robert<Robert.Taylor@nrc.gov>Cc:Monninger,John<John.Monninger@nrc.gov>
Subject:
Re:Action:RequestforReviewandConcurrence(LAR17 037)WegotfeedbackfromintoeachsectionoftheSEtomakeitconsistentthroughout,andarenowaskingthetechstafftotakeanotherlook.No"template"persewasputoutsinceallth estaffwere99%donewiththeirsectionsalready.
AnnaH.BradfordDeputyDirectorDivisionofLicensing,Siting,andEnvironmentalAnalysis(DLSE)U.S.NuclearRegulatoryCommission301 4151560 On:21August201815:00,"Coyne,Kevin"<Kevin.Coyne@nrc.gov
>wrote:Hi Anna - We previously discussed refining the fuels sections, , and then sending it out to the other reviewers to use as a template. Did this all happen or has the plan changed? Kevin From:Bradford,AnnaSent:Tuesday,August21,20182:57PMTo:Brown,Frederick<Frederick.Brown@nrc.gov
>;Ordaz,Vonna<Vonna.Ordaz@nrc.gov
>;Taylor,Robert<Robert.Taylor@nrc.gov
>Cc:Monninger,John<John.Monninger@nrc.gov
>;Coyne,Kevin<Kevin.Coyne@nrc.gov
>
Subject:
Fwd:Action:RequestforReviewandConcurrence(LAR17 037)FYI, the Tier 2* LAR is out to the tech staff for final co ncurrence. I read it before Don sent it out, and I think it's in good shape but I doubt it will satisfy all of Joe Williams' concerns. Anna H. BradfordDeputy Director 267Division of Licensing, Siting, and Environmental Analysis (DLSE)U.S. Nuclear Regulatory Commission301-415-1560 From: "Habib, Donald" <
Donald.Habib@nrc.gov
>
Subject:
Action: Request for Review and Concurrence (LAR 17-037)
Date: 21 August 2018 12:10 To: "Karas, Rebecca" <
Rebecca.Karas@nrc.gov>, "Van Wert, Christopher" <Christopher.VanWert@nrc.gov
>, "Nolan, Ryan" <
Ryan.Nolan@nrc.gov
>, "Jackson, Diane" <Diane.Jackson@nrc.gov
>, "Ashley, Clinton" <
Clinton.Ashley@nrc.gov
>, "Segala, John" <John.Segala@nrc.gov>, "Williams, Joseph" <Joseph.Williams@nrc.gov
>, "Rivera-Varona, Aida" <Aida.Rivera-Varona@nrc.gov
>, "Green, Brian" <Brian.Green@nrc.gov>, "Betancourt, Luis" <Luis.Betancourt@nrc.gov
>, "Zhao, Jack" <
Jack.Zhao@nrc.gov>, "Mitchell, Matthew" <Matthew.Mitchell@nrc.gov>, "Honcharik, John" <
John.Honcharik@nrc.gov>, "Samaddar, Sujit" <Sujit.Samaddar@nrc.gov
>, "Patel, Pravin" <Pravin.Patel@nrc.gov>, "Thomas, Vaughn" <Vaughn.Thomas@nrc.gov>, "Lupold, Timothy" <Timothy.Lupold@nrc.gov>, "Scarbrough, Thomas" <Thomas.Scarbrough@nrc.gov>, "Hansing, Nicholas" <
Nicholas.Hansing@nrc.gov
> Cc: "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>, "Hoellman, Jordan" <Jordan.Hoellman2@nrc.gov
>, "Bradford, Anna" <
Anna.Bradford@nrc.gov
> LAR 17-037 Review Team: Attached for your review and concurrence is the safety evaluation for Vogtle LAR 17-037 (Tier 2* Departure Evaluation Process).Please provide your comments and concurrence by COB Tuesday August 28
. Some of the SE inputs from the technical branches have been edited for consistency and to assure that they support the overall conclusion of the SE. Therefore, you may wish to compare this concurrence version with your original input. At a minimum, review the front portion of the SER, up to the beginning of Section 3.1.1, plus the updated version of your branch input. Your branch input should be consistent with the front material. For any question/comment on an individual branch input, please provide an appropriate edit or response (SRSB, SEB, HOIB) with the technical staff review and concurrence. Therefore, I will follow up with you if there are ThanksDon Don HabibProject Manager NRO/DLSE, Licensing Branch 4O-8D13 301-415-1035 268 Williams, Joseph From: Williams, Joseph Sent: Thursday, August 23, 2018 10:41 AM To:Ashley, Clinton; Betancourt, Luis; Hansing, Nicholas; Honcharik, John; Nolan, Ryan; Patel, Pravin; Scarbrough, Thomas; Thomas, Vaughn; Van Wert, Christopher Cc: McGovern, Denise
Subject:
Tier 2* SE Non-concurrenceFYI, I have informed management that I will not concur in the SE distributed earlier this week. I haven't yet completed reading through the updated SE, but it is apparent from what I've seen so far that the concerns I've been communicating have not yet been addressed. I have also requested that Denise McGovern, who has served as the Summer COL lead PM, be authorized to join the non-concurrence.
I may ask for assistance from some of you as I prepare my non-concurrence documentation. One of the issues I've raised is that I believe the proposed process should be tested by applying them to the current set of Tier 2* LARs. If everything comes through cleanly, then we have greater confidence that the process is adequate. However, if a problem is identified, some adjustment will be necessary. SNC also makes claims about a set of previous amendments that the current SE text does not question or evaluate; I think NRC should determine if we agree or not. I'm considering how to address these issues in my non-concurrence, and I may reach out with questions about the previous LARs. I'll appreciate any assistance or perspective you can offer.
Thanks. Joe Williams
Senior Project Manager Advanced Reactors and Policy Branch Division of Safety Systems, Risk Assessment, and Advanced Reactors Office of New Reactors 301.415.1470 269 Williams, Joseph From:Monninger, John Sent: Friday, August 24, 2018 12:37 PM To:Williams, Joseph; Van Wert, Christopher; Coyne, Kevin Cc: McGovern, Denise; Segala, John
Subject:
RE: Tier 2* LAR concurrence Chris, Generally speaking, when reviewing documents for potential concurrence, an individual's review is expected to be reflective of those areas that the individual is responsible for. For some documents, this is straightforward. For other documents, this may be more subtle (i.e., determining direct or indirect responsibility).
As Joe noted below, you are free to use the NCP for the specific technical aspects of the review you were directly responsible for, or for broader aspects of the review that you were exposed to.
In the old days (I tried to run down the reference from MD 3.57 but couldn't find it), an individual had the option to limit their concurrence to certain sections of a document in which they had primary/direct responsibility for. I've used this in the past for large complex documents (e.g., DCD FSER or COL FSER). For example, my concurrence would be limited to Chapters 4, 5, 6, 9, 15, and 19 (as this is what DSRA is responsible for). In these cases, my concurrence (either the concurrence block or my email concurrence) would explicitly say my concurrence is limited to these Chapters. Other times, I haven't necessarily agreed with the tone of a document; however, the technical substance was correct. In these cases, I've limited my concurrence to the technical aspects of the document and my concurrence reflected that. In other cases, I didn't necessarily support the position or approach being taken by another office or division. In these cases, I've limited my concurrence to DSRA's roles and responsibilities.
In the end, I believe you have options (e.g., concur, concur with comments for resolution, non-concur, concur on limited portions).
Feel free to stop by and chat with Kevin or me if you want to discuss.
John From:Williams,JosephSent:Friday,August24,201811:20AMTo:VanWert,Christopher<Christopher.VanWert@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>Cc:McGovern,Denise<Denise.McGovern@nrc.gov>;Segala,John<John.Segala@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>
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RE:Tier2*LARconcurrenceChris, It is my understanding that you are within process if you indicate that you do not agree with any aspect of the SE, not just the portions reflecting your input. For instance, if you agree with me that the proposal represents policy issues that need Commission decisions, you can say so. Denise McGovern is signing on to the non-concurrence on that basis, given her prior experience with the AP1000 COLs, including a similar amendment that was withdrawn in 2014. You and Denise both participated in the Tier 2* working group that gives you perspective in that regard, as well.
MD 10.158 on the non-concurrence process (NCP) states that
270An NRC employee who is not eligible to use the NCP may approach his or her immediate supervisor, document signer, another manager in their organization, or the NCP Program Manager (PM) and request to engage in the NCP if he or she believes they have specific information that would enhance the decisionmaking process and that use of the NCP would be in the interest of the agency as a knowledge management tool.
And A document signer should allow an employee to engage in the NCP if he or she believes the employee has specific information that would enhance the decisionmaking process and use of the NCP would be in the interest of the agency as a knowledge management tool.
You're already eligible to use the NCP, so I don't think it's stretching anything to allow you to express differing views about the overall approach or any particular detail where you have relevant knowledge or experience.
Joe From:VanWert,ChristopherSent:Friday,August24,201811:10AMTo:Coyne,Kevin<Kevin.Coyne@nrc.gov
>Cc:Williams,Joseph<Joseph.Williams@nrc.gov
>
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Tier2*LARconcurrenceKevin, I have a question for you- what should I be concurring on in response to Don and Jordan's concurrence request for the Tier 2* LAR SER? I can review my section and concur. However, I agree with Joe's concerns that he raised multiple times and as he has noted, they have not been addressed in this latest version. I don't want to give the impression that I'm good with the entire document or disagree with the points that Joe is highlighting, but if someone needs to know if I'm fine with what I had already written, then I have no problem doing that. Any thoughts?
Thanks!
Chris 271 Williams, Joseph From: Williams, Joseph Sent: Monday, August 27, 2018 10:09 AM To: Bradford, Anna Cc: Taylor, Robert; Dixon-Herrity, Jennifer; Habib, Donald; Monninger, John; Coyne, Kevin; Figueroa Toledo, Gladys; Segala, John; McGovern, Denise
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RE: CA Note Importance:High Anna, Thanks for sharing this with me. I don't believe MD 10.158 permits forwarding the non-concurrence without having completed the evaluation required by that procedure. I'll note that given the stated intent to issue the amendment within 3 days, one could conclude that a decision has already been made to issue the amendment, regardless of the issues raised in the non-concurrence.
I'll let you know if I have any other comments.
Joe
I'll let you know if I have any comments.
From:Bradford,AnnaSent:Monday,August27,20189:56AMTo:Williams,Joseph<Joseph.Williams@nrc.gov>Cc:Taylor,Robert<Robert.Taylor@nrc.gov>;Dixon Herrity,Jennifer<Jennifer.DixonHerrity@nrc.gov>;Habib,Donald<Donald.Habib@nrc.gov>;Monninger,John<John.Monninger@nrc.gov>;Coyne,Kevin<Kevin.Coyne@nrc.gov>;FigueroaToledo,Gladys<Gladys.FigueroaToledo@nrc.gov>;Segala,John<John.Segala@nrc.gov>
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CANoteJoe, Attached please find the draft of the CA Note that will forward the Tier 2* SE to the Commissioner Assistants. Our current schedule is to send this to the TAs on September 4. I'd be happy to receive any comments that you may have on the CA Note.
Thanks.
Anna H. Bradford Deputy Director Division of Licensing, Siting, and Environmental Analysis U.S. Nuclear Regulatory Commission
301-415-1560