ML19190A077
| ML19190A077 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 07/09/2019 |
| From: | NRC |
| To: | NRC/NRO/DLSE/LB4 |
| References | |
| Download: ML19190A077 (4) | |
Text
Vogtle PEmails From: Gleaves, Bill Sent: Tuesday, July 9, 2019 7:49 AM To: Leighty, Steven; Roberts, Kelli Anne Cc: Hughes, Brian; Patel, Chandu; Dixon-Herrity, Jennifer; Vogtle PEmails; Dudek, Michael; Stutzcage, Edward
Subject:
Vogtle LAR-19-005 Draft RAI 9696 7-9-19 Attachments: Vogtle LAR-19-005 Draft RAI_9696 7-9-19.pdf Importance: High Steve and Kelli, Attached is our management-approved draft RAI on the LAR-19-005, with the plan to discuss during the regular Thursday meeting on 7.11.19 at 9am.
This draft RAI will be final upon SNCs acceptance or within 7 days of the meeting (7.22.19), whichever is later. If SNC has comments or suggested changes, they will be considered for inclusion before finalization.
This email is also being sent to public ADAMS capture. If there is sensitive information, please inform me ASAP so that it will prevented from public viewing.
Respectfully, Billy William (Billy) Gleaves Senior Project Manager NRO/DLSE/Licensing Branch 2 (was Licensing Branch 4)
US Nuclear Regulatory Commission The contents of this message may be sensitive. If this message has been received in error, please delete it without reading it. Your receipt of this message is not intended to waive any applicable privilege. Do not disseminate this message without the permission of the author. Communications by this author do not represent NRC policy and are not binding on the Commission.
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Hearing Identifier: Vogtle_COL_Docs_Public Email Number: 460 Mail Envelope Properties (BN7PR09MB2916DCB1CB0D07653DD958599FF10)
Subject:
Vogtle LAR-19-005 Draft RAI 9696 7-9-19 Sent Date: 7/9/2019 7:49:18 AM Received Date: 7/9/2019 7:49:21 AM From: Gleaves, Bill Created By: Bill.Gleaves@nrc.gov Recipients:
"Hughes, Brian" <Brian.Hughes@nrc.gov>
Tracking Status: None "Patel, Chandu" <Chandu.Patel@nrc.gov>
Tracking Status: None "Dixon-Herrity, Jennifer" <Jennifer.Dixon-Herrity@nrc.gov>
Tracking Status: None "Vogtle PEmails" <Vogtle.PEmails@nrc.gov>
Tracking Status: None "Dudek, Michael" <Michael.Dudek@nrc.gov>
Tracking Status: None "Stutzcage, Edward" <Edward.Stutzcage@nrc.gov>
Tracking Status: None "Leighty, Steven" <sleighty@southernco.COM>
Tracking Status: None "Roberts, Kelli Anne" <KROBERTS@southernco.com>
Tracking Status: None Post Office: BN7PR09MB2916.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 1154 7/9/2019 7:49:21 AM Vogtle LAR-19-005 Draft RAI_9696 7-9-19.pdf 17501 Options Priority: High Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:
Recipients Received:
DRAFT Request for Additional Information Vogtle Nuclear Site, Units 3 and 4, Dockets 52-0025 and 52-0026 Southern Nuclear Operating Co.
Docket Nos. 52-0025 and 52-0026 Section: 14.03.08 - Radiation Protection Inspections, Tests, Analyses, and Acceptance Criteria Application Section: Tier 1
Background
In LAR-19-005, the licensee requests changes to COL Appendix C and Tier 1, Table 3.3-1, "Definition of Wall Thicknesses for Nuclear Island Buildings, Turbine Building, and Annex Building," and Table 3.3-6, "Inspections, Tests, Analyses, and Acceptance Criteria." The proposed changes include the allowance of construction deviations from the thicknesses of radiation shielding barriers in the nuclear island structures and annex building if the changes can be made without a "loss of shielding function."
Issue The proposed wording in Table 3.3-1, Footnotes 15 and 16 and the Table 3.3-6 ITAAC acceptance criteria for ITAAC 3.3.00.02a.i.a, 3.3.00.02a.i.b, 3.3.00.02a.i.c, 3.3.00.02a.i.d, 3.3.00.02a.ii.e, and 3.3.00.04b, are not clear. The proposed language does not specify if the radiation attenuation factor is reduced (or otherwise clarify whether an acceptable level of radiation attenuation is retained). Specifically, it is unclear to the staff what amount of radiation shielding reduction (and resulting radiation attenuation loss) can be made without being considered a loss in radiation shielding function. In addition, the radiological dose impacts and consequences of changes in radiation barrier thickness vary based on the radiation source and the dose reduction needs on the other side of the barrier. The staff is concerned that the current language will allow reductions in radiation attenuation that may not be acceptable without adding concrete density or by adding an additional shielding material to the wall.
Clarification Please clarify or revise, as appropriate, the Table 3.3-1, Footnotes 15 and 16 and the acceptance criteria for ITAAC 3.3.00.02a.i.a, 3.3.00.02a.i.b, 3.3.00.02a.i.c, 3.3.00.02a.i.d, 3.3.00.02a.ii.e, and 3.3.00.04b, in Table 3.3-6 to provide a criteria which ensures that radiation attenuation remains appropriate and the facility has been constructed and will be operated in accordance with the design and the relevant requirements.
Regulatory Basis 10 CFR 50, Appendix A, General Design Criteria (GDC) 61, requires that the fuel storage and handling, radioactive waste, and other systems which may contain radioactivity shall be designed to assure adequate safety under normal and postulated accident conditions. These systems shall be designed (1) with a capability to permit appropriate periodic inspection and testing of components important to safety (2) with suitable shielding for radiation protection, and (3) with appropriate containment, confinement, and filtering systems.
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10 CFR 52.80(a) requires that the application must contain the proposed inspections, tests, and analyses, that the licensee shall perform, and the acceptance criteria that are necessary and sufficient to provide reasonable assurance that, if the inspections, tests, and analyses are performed and the acceptance criteria met, the facility has been constructed and will be operated in conformity with the combined license, the provisions of the Act, and the Commission's rules and regulations.
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