ML18142B923

COL Docs - Draft RAI Responses for LAR-17-037, Changes to Tier 2* Departure Evaluation Process

ML18142B923
Person / Time
Site:	Vogtle
Issue date:	05/22/2018
From:	NRC
To:	NRC/NRO/DNRL/LB4
References
Download: ML18142B923 (26)

Text

1 Vogtle PEmails From:

Hoellman, Jordan Sent:

Tuesday, May 22, 2018 4:03 PM To:

Vogtle PEmails

Subject:

Draft RAI Responses for LAR-17-037, Changes 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-17-037-8_eRAI 9541_ICE (Draft to NRC-05-21-18).pdf; RAI LAR 17-037-9_eRAI 9524_SRSB (Draft to NRC-051718).pdf Attached are draft responses to RAIs issued by the staff to support their review of LAR-17-037, Changes to Tier 2*

Departure Evaluation Process.

The responses are provided to allow staff review in advance of a future public meeting.

Hearing Identifier:

Vogtle_COL_Docs_Public Email Number:

279 Mail Envelope Properties (SN6PR09MB26081EB4992CED2DE86AA718D5940)

Subject:

Draft RAI Responses for LAR-17-037, Changes to Tier 2* Departure Evaluation Process Sent Date:

5/22/2018 4:02:36 PM Received Date:

5/22/2018 4:02:48 PM From:

Hoellman, Jordan Created By:

Jordan.Hoellman2@nrc.gov Recipients:

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

Tracking Status: None Post Office:

SN6PR09MB2608.namprd09.prod.outlook.com Files Size Date & Time MESSAGE 261 5/22/2018 4:02:48 PM RAI LAR 17-037-5_eRAI 9514_HOIB (Draft to NRC-051718).pdf 835165 RAI LAR 17-037-6_eRAI 9542_LB4 (Draft to NRC-051718).pdf 791858 RAI LAR 17-037-7_eRAI 9544_ARPB (Draft to NRC-051718).pdf 868647 RAI LAR-17-037-8_eRAI 9541_ICE (Draft to NRC-05-21-18).pdf 726734 RAI LAR 17-037-9_eRAI 9524_SRSB (Draft to NRC-051718).pdf 824197 Options Priority:

Standard Return Notification:

No Reply Requested:

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Recipients Received:

Southern Nuclear Operating Company ND-18-XXXX Enclosure XX Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) LAR 17-037-5 Regarding the LAR-17-037 Review (LAR-17-037S3)

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

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

Draft Response VEGP)

P) Units 3 Units Additional Inf ditional I ding the LAR ding the LA (LAR (L

1 (05-17-2018) ormation (RAI) rmation (RA 7-037 Review 037 Revi 7-037S3) 037S3)

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

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

Regulatory Basis:

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

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

Amongst other things, 10 CFR Part 52 Appendix D:

x provides definitions of Tier 1, Tier 2, and Tier 2* as they pertain to the AP1000 design x

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

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

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

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

Description of the Issue:

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

Question:

Section 3, "Technical Evaluation" (Enclosure 1, Page 10 of 19) of LAR 17-037 provides specific examples of "material changes" that may affect design processes. The examples of material changes and non-material changes are helpful.

However, it's not clear that the examples provided will be sufficient for either the licensee or the NRC staff to determine whether a change is material or not, especially when the proposed change is unlike any of the examples given.

Clarifying this process is important because changes to the approved human factors implementation plans (IPs) may have significant effects on the iterative process, including generation of information from testing and interpretation of test results that employs various human factors processes to develop a final HFE design. Altering details that the NRC staff used in approving these implementation plans could, in some cases, invalidate the staff findings on the IPs, and may consequently challenge the staffs ability to rely on the results of HFE testing to Draft es ptance c tance e:

staff has rev staff has rev tly ly HFE HFE infor info ocess ocess idi

Response

ier 2 evaluation of aluation res from the S s from the e SRP accepta RP acce e guidance N uidance s NUREG UREG-071 0

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ed the process he proce ion identified as on identified owever, it is un wever, it tify tify human facto human fa cation is neces ation is ne

confirm that the main control room HSIs will support safe operation. Moreover, lack of a clear definition of a "material change" or criteria for evaluating changes may be problematic in regard to both licensee and NRC inspections related to human factors inspections, tests, analyses, and acceptance criteria (ITAAC).

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

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

Changes to Original LAR-17-037:

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

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

x The following are examples of material changes:

o The addition, deletion, or alteration of a design process step o Reconfiguration of design process steps o

Departures from regulatory guidance related to the design process o

Alteration of a detail that serves as the basis for acceptance in a Final Safety Evaluation Report (FSER) related to the affected design process Draft 7-037:

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Response

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

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

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

Draft Response VEGP)

P) Units 3 Units Additional Inf ditional I ding the LAR ding the LA (LAR (L

1 (05-17-2018) ormation (RAI) rmation (RA 7-037 Review 037 Revi 7-037S3) 037S3)

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

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

Question:

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

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

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

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

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

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

The staff requests the licensee to propose revisions to the UFSAR or the proposed license condition, or to provide a commitment, as appropriate, (1) to commit to a procedure that would be used to implement the Tier 2* departure evaluation process and (2) to identify the minimum information from Enclosure 1 that it is committing to in the LAR, or explain why a commitment to such information is not necessary.

SNC Response to RAI Question LAR 17-037-6 SNC plans to provide detailed guidance related to the use of the proposed Criteria to evaluate proposed Tier 2* departures in procedures used to determine if a proposed departure requires prior NRC approval. The guidance material will include, as a minimum, a restatement of the Draft viation fr iation material cha aterial cha ocesses wou esses wo tutes an adve tutes an adv ns and de ns and d

Response

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Criteria contained in the associated license condition and detailed guidance and associated bases provided in Enclosure 1 of ND-17-1726. In response to the RAI provided above, SNC is proposing to add a commitment which would commit SNC to adding to existing procedures detailed guidance related to the application of the qualification criteria contained in the proposed license condition. Changes to the commitment or material affecting the commitment would be addressed through SNCs Commitments Management program.

Changes to Original LAR-17-037:

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

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

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

The proposed regulatory commitment that would require SNC to provide detailed procedural guidance related to how the qualifying criteria would be applied to proposed Tier 2* departures ensures that departures from Tier 2* information with a safety significance commensurate with Tier 1 will require prior NRC approval.

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

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

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

REGULATORY COMMITMENT DUE DATE / EVENT Develop procedural guidance that contains a description of the qualifying criteria contained in License Condition 2.D(13) and the supporting detailed guidance and bases contained in the Technical Evaluation section of the approved LAR-17-037, Implemented prior to the implementation of the license amendment approving this LAR Draaft ry t

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Response

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including additional guidance provided by SNC in the supplements to the LAR.

Draft Response (05-17-2018)

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

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

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

Draft Response VEGP)

P) Units 3 Units Additional Inf ditional I ding the LAR ding the LA (LAR (L

1 (05-17-2018) ormation (RAI) rmation (RA 7-037 Review 037 Revi 7-037S3) 037S3)

ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

Page 2 of 5 The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

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

Question:

As noted in SNCs license amendment request (LAR) (ML17355A416), SECY-17-0075, Planned Improvements in Design Certification Tiered Information Designations, (ML16196A321) describes how the purpose of the Tier 2* designation is to control certain information which the staff has determined to have safety significance commensurate with that of Tier 1 information.

NRCs letter dated January 25, 2018, which accepted the LAR for review (ML18019A362), stated that the process criteria and guidance described in the application do not clearly differentiate between Tier 2* information with safety significance commensurate with Tier 1, and any Tier 2*

information which does not warrant the same level of control. For example, Criteria 2 and 3 address a material change, but do not clearly describe how controls on those changes ensure information with safety significance commensurate with Tier 1 is not modified without prior NRC review and approval.

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

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

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

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

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

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

SNC Response to RAI Question LAR 17-037-7 The purpose of the evaluation process used to develop the new criteria was to provide assurance that safety-significant changes to existing Tier 2* information would screen in for prior NRC review and approval. While a determination of safety significance was part of the process used to develop the criteria, SNC determined that a detailed analysis of all Tier 2* information in order to differentiate it into safety significance commensurate with Tier 1 information and Tier 2*

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Response

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ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

Page 3 of 5 information which does not warrant Tier 1 level control was not appropriate or even straightforward given the variability and inherent lack of specificity with which Tier 1 level information is defined.

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

information listed in 10 CFR Part 52, Appendix D, Paragraphs VIII.B.6.b and VIII.B.6.c. SNC reviewed available Commission Policy papers such as SECY-96-077, Certification of Two Evolutionary Designs, April 15, 1996 [ADAMS Accession No. ML003708129] and SECY 0075, Planned Improvements in Design Certification Tiered Information Designations, [ADAMS Accession Number ML16196A321] to better understand the bases behind the selection of Tier 1 information. SNC also reviewed existing certified Tier 1 DCDs to better understand the content and level of detail that should be contained in a Tier 1 DCD.

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

x Is the Tier 2* information adequately addressed in the VEGP 3 and 4 Plant-specific Tier 1 DCD or VEGP 3 and 4 Combined License (COL)? This step included a review to determine the degree to which codes, standards, and design and qualification processes, are relied upon for ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1 DCD.

x Would changes in the Tier 2* information be adequately addressed by other applicable regulations, e.g., 10 CFR 50.46?

x Would a change to the Tier 2* information have safety-significance commensurate with a change to Tier 1 information?

x Would a change to the Tier 2* information consistently and reliably require prior NRC approval using the evaluation process defined in 10 CFR Part 52, Appendix D, paragraph VIII.B.5?

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

x First, a set of Tier 2* information is already adequately addressed in Tier 1 and thus a change to this Tier 2* information, which would involve a change to the associated Tier 1 information, would require prior NRC approval. Therefore, neither an evaluation of safety-significance nor new evaluation criteria were considered necessary to provide assurance that changes would receive prior NRC approval.

x Second, for another set of Tier 2* information it was concluded that a change to this information would not have safety-significance commensurate with a change to Tier 1 information. Thus, new evaluation criteria were not considered necessary for this set of Tier 2* information.

x Third, it was determined that a change to a third set of Tier 2* information would require a prior NRC approval under 10 CFR Part 52, Appendix D, paragraph VIII.B.5 or another regulation in a consistent and reliable manner. Thus, it was concluded that the evaluation criteria currently provided in 10 CFR Part 52, Appendix D, VIII.B.5.b or VIII.B.5.c are Draft e Tier 2*

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Response

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ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

Page 4 of 5 adequate to reliably and consistently address changes to this information and new evaluation criteria to address changes to this information were not necessary.

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

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

Regarding Enclosure 5, it was not intended that this enclosure identify what portions of Tier 2*

information were considered to contain information that has safety significance commensurate with Tier 1. As stated earlier, while a determination of safety significance was part of the process used to develop the criteria, SNC determined that a detailed analysis of all Tier 2* information in order to identify what portions had safety significance commensurate with Tier 1 information was not necessary or appropriate. Enclosure 5 only provides a summary of the results of the evaluation process described above. of the original LAR-17-037 will be revised as shown below to incorporate the above clarification of the process used to develop the new evaluation criteria.

Changes to Original LAR-17-037:

Changes to Enclosure 1:

Revise the first two paragraphs on Page 8 of 19 of the original LAR-17-037 to read as follows:

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:

x Is the Tier 2* information adequately addressed in the VEGP 3 and 4 Plant-specific Tier 1 DCD or VEGP 3 and 4 Combined License (COL)? This step included a review to determine the degree to which codes, standards, and design and qualification processes, are relied upon for ITAAC acceptance criteria, but not specified in the VEGP 3 and 4 Plant-specific Tier 1 DCD.

x Would changes in the Tier 2* information be adequately addressed by other applicable regulations, e.g., 10 CFR 50.46?

x Would a change to the Tier 2* information have safety-significance commensurate with a change to Tier 1 information?

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Response

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ND-18-0xxx Enclosure xx Response to NRC Request for Additional Information (RAI) LAR 17-037-7 Regarding the LAR-17-037 Review (LAR-17-037S3)

Page 5 of 5 x

Would a change to the Tier 2* information consistently and reliably require prior NRC approval using the evaluation process defined in 10 CFR Part 52, Appendix D, paragraph VIII.B.5?

x 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 x

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 x

Safety-significance x

Degree to which 10 CFR Part 52, Appendix D, Section VIII.B.5 would effectively evaluate a Tier 2* departure Following the evaluation process described above, SNC made the following conclusions regarding 11 of the 24 Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c:

x First, a set of Tier 2* information is already adequately addressed in Tier 1 and thus a change to this Tier 2* information, which would involve a change to the associated Tier 1 information, would require prior NRC approval. Therefore, neither an evaluation of safety-significance nor new evaluation criteria were considered necessary to provide assurance that changes would receive prior NRC approval.

x Second, for another set of Tier 2* information it was concluded that a change to this information would not have safety-significance commensurate with a change to Tier 1 information. Thus, new evaluation criteria were not considered necessary for this set of Tier 2* information.

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

Based on the results of the analysis, 13 of the 24 Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c were determined to be adequately covered by existing Tier 1 information, covered by another regulation or the combined license, or did not rise to the level of Tier 1 safety significance. The remaining 131 of the 24 Tier 2* matters listed in 10 CFR Part 52, Appendix D, Section VIII paragraphs B.6.b and B.6.c were selected for development of additional screening criteria that would determine whether an associated Tier 2* departure qualifies for the departure evaluation process outlined in 10 CFR Part 52, Appendix D, Section VIII.B.5. A summary of the analysis is provided in Enclosure 5. The selected matters are:

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Southern Nuclear Operating Company ND-18-0xxx Enclosure X Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) 17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

Supplement 3 changes to the original LAR text are shown as blue-underlined text; deletions of original LAR text are shown as red strikethrough text.

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

Draft Req e

Regardin Regardin response ant (VEGP) U nt (VEG est for Ad est for A (05-21-2018) nits 3 and nits 3 and itional Informa al Infor e LAR e LAR-17 17-037 R (LAR

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-177-037 03

ND-18-0xxx Enclosure X Response to NRC RAI LAR-17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

Page 2 of 4 The following is the question provided by the NRC Staff [Request for Additional Information (RAI)

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

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

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

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

x WCAP-17201-P, AC160 High Speed Link Communication Compliance to DI&C-ISG-04 Staff Position 9, 12, 13, and 15, Rev. 0 x

WCAP-15927, Design Process for AP1000 Common Q Safety Systems, Rev. 2 x

WCAP-17179, AP1000 Component Interface Module Technical Report, Rev. 2 x

WCAP-16097-P-A, Common Qualified Platform, Rev. 0 x

WCAP-16096-NP-A, Software Program Manual for Common Q Systems, Rev. 01A Question 1 Although the Component Interface Module (CIM) design process is briefly discussed in Tier 1 under the PMS description, WCAP-17179 states that the CIM interfaces with the PMS and other systems, indicating that it is separate from the PMS. In addition, the CIM design process is different from that for the PMS. The licensee is requested to identify the CIM design processes as among those considered under Criterion 2 by explicitly listing them as examples under that criterion, or explain why this is unnecessary.

SNC Response to RAI Question 1 Because the CIM provides the priority logic between the PMS and other systems, CIM is often addressed in association with PMS, and in fact, the CIM is addressed in Tier 1 Section 2.5.2, Protection and Safety Monitoring System. So, for simplicity, the guidance and bases provided in Enclosure 1 to SNC letter ND-17-1726 (LAR-17-037) did not specifically call-out the CIM separate from the discussion provided for the PMS. However, SNC concurs that the CIM could be addressed in a separate bases discussion, similar to that provided for other elements of Tier 2* information covered by Criterion 2 of the proposed License Condition. It is worth noting that there is only a minimal, high-level discussion of the CIM development information Draft 00 Compo 0 Com A, Common Q Common NP-A, Softw A, Soft response ng two ng tw the following he follow ed Link Com d Link Co Rev. 0 Rev. 0 ss for AP100 ss for AP ent I en (05-21-2018) echnical or echnical o munication Com unication C 0 Common Q Sa ommon Q terface Module rface Modu ified Platform, fied Platform Program Manu Program Ma nterface Modu terface M WCAP WCAP-17 is se se

ND-18-0xxx Enclosure X Response to NRC RAI LAR-17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

Page 3 of 4 in Tier 2* document WCAP-17179, and there is a very low likelihood that this information will be changing at this point in the plants design/construction. Because the evaluation of changes to the design process applicable to PMS and the CIM would follow a similar approach, the basis for an evaluation of changes to the CIM design process would be consistent with that already provided for changes to the PMS design process in ND-17-1726,.

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

Changes to Enclosure 1:

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

Criterion 2 (Design Processes) Bases:

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

x Diverse Actuation System (Plant-specific Tier 1 DCD, Section 2.5.1; Plant-specific Tier 2 DCD, Chapter 7);

x Protection and Safety Monitoring System (Plant-specific Tier 1 DCD, Section 2.5.2; Plant-specific Tier 2 DCD, Chapter 7);

x Component Interface Module (Plant-specific Tier 1 DCD, Section 2.5.2; Plant-specific Tier 2 DCD, Chapter 7);

x Human Factors Engineering (Plant-specific Tier 1 DCD, Section 3.2; Plant-specific Tier 2 DCD, Chapter 18);

Diverse Actuation System (DAS)

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

Protection and Safety Monitoring System (PMS)

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

Component Interface Module (CIM)

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

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ND-18-0xxx Enclosure X Response to NRC RAI LAR-17-037-8 Regarding the LAR-17-037 Review (LAR-17-037S3)

Page 4 of 4 Question 2 The design process for the DAS is covered in Tier 1 Section 2.5.1. The staff is not aware of any Tier 2* information governing the DAS design process. However, the staff notices that there is a discussion in the LAR on changes to the DAS design process. The licensee is requested to clarify how changes to the DAS design process will receive prior NRC approval.

In particular, identify the DAS design process information that is designated as Tier 2*

information.

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

Specifically, Section 2.9 discusses the application of the various aspects of diversity (i.e.,

diversity in design, equipment, function, humans, signals, and software) in the design of the CIM and DAS.

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

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

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

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

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

None.

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Southern Nuclear Operating Company ND-18-0xxx Enclosure X Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Response to NRC Request for Additional Information (RAI) 17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3)

Supplement 3 changes to the original LAR text are shown as blue-underlined text; deletions of original LAR text are shown as red strikethrough text.

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

Draft Response onal Informati al Inform LARR-17 17-037 Re 037 p

LAR-17 17-037 037S )

(05-17-2018) view ew origi orig

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) 2 of 8 The following were questions provided by the NRC Staff [Request for Additional Information (RAI) [LAR 17-037-9] regarding the review of Southern Nuclear Operating Company (SNC)

License Amendment Request (LAR)17-037, which was submitted by SNC letter ND-17-1726 on December 21, 2017.

RAI Introduction The scope of Tier 2* information of the AP1000 certified design is defined in 10 CFR Part 52 Appendix D Sections VIII.B.6.b and VIII.B.6.c, which state that changes to Tier 2* will be treated as a request for a license amendment and require staff review and approval prior to implementation. SECY-17-0075, Planned Improvements in Design Certification Tiered Information Designations, (ADAMS Accession No. ML16196A321) states that Tier 2*

information has safety significance commensurate with that of Tier 1 information and would have received the Tier 1 designation, except that NRC decided to provide more flexibility for this type of information. Per the SECY and the statements of consideration associated with the final rule for Part 52 (72 FR 49352, Licenses, Certifications and Approvals for Nuclear Power Plants, p.49365, August 28, 2007), the purpose of the Tier 2* designation is to control certain information which the staff has determined to have safety significance commensurate with that of Tier 1 information. Consistent with this significance, the Tier 2* change process ensures that the information is controlled in a similar manner (e.g. changes to such information require prior staff review and approval).

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

... Result in a material change to the fuel criteria evaluation process...

Section 5.6.3 of Vogtle Electric Generating Plant (VEGP) Units 3 and 4 Technical Specifications provides the reporting requirement for the Core Operating Limits Report (COLR).

Section 5.6.3(b) provides the analytical methods used to determine the core operating limits and states that these methods shall be those previously reviewed and approved by the NRC.

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

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

SNC Response to RAI Question 1 Draft ontains t ntains This new co is new co and states t nd states endix D, Par endix D, Pa he provisions he provision ess wou ess wo al c al c

Response

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• designation is esignation e safety signific afety sig ficance, the Tie ance, the ner (e.g. chang e.g. c e pro e p (05-17-2018) 2* c 2 c s to such s to such osed revision to osed revisio ion governs the on governs SNC would be SNC wo aphs II.F and V s II.F and the new conditi the new con pply except for ply exce ge to the fuel c ge to the fu ctric Generat ric Gene ment fo ment aly

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) 3 of 8 The proposed changes to the Tier 2* evaluation process described in LAR 17-037 do not affect the Technical Specifications change control process requirements specified in 10 CFR Part 52, Appendix D, VIII.B.5.a or the specific Technical Specifications requirements in Section 5.6.3 for changes to analytical methods used to determine the core operating limits in the Core Operating Limits Report (COLR). Any changes to the documents listed in Technical Specifications Section 5.6.3.b require prior NRC approval. If WCAP-12488-P-A were referenced in any of these documents, changes to WCAP-12488-P-A would also require a change in the document that references it and thus require prior NRC approval. Nevertheless, a review of the references listed in Technical Specifications 5.6.3(b) was performed and confirmed that WCAP-12488-P-A is not referenced in any of the Technical Specifications COLR reference documents.

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

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 1 None Question 2 Item (1) of 10 CFR Part 52 Appendix D, Section VIII.B.6.b covers the maximum rod average fuel burnup. Additionally, the validity of the methods contained in referenced topical report WCAP-12488-P-A and the staffs approval for this topical report are based upon the burnup-dependent empirical fuel performance models. of LAR-17-037 contains the proposed revision to COL license condition 2.D which includes a new condition. This new condition governs the desired departures from plant-specific DCD Tier 2* information and states that SNC would be exempt from the requirements of 10 CFR Part 52, Appendix D, Paragraphs II.F and VIII.B.6 that invoke the Tier 2* change process. The exemption from the current Tier 2* change process would apply except for departures from Tier 2* information that, Result in a material change to the... maximum fuel rod average burn-up limits... However, the staff notes that Enclosure 1 of LAR-17-037 provides guidance (Criterion 3) which states that [a] material change is any change that would have an effect on maximum fuel rod average burn-up limits. The staff is concerned that the wording in Enclosure 3 does not reflect the guidance provided in Enclosure 1 and could lead a screener to interpret that some changes to rod average burn-up limits could be made without requiring prior staff review and approval.

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

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

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ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) 4 of 8 Changes to Enclosure 1:

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

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

Changes to Enclosure 3:

Revise Criterion 3 as follows:

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

Similar conforming changes are also applicable to Enclosures 1, 4, and 5 of the original LAR-17-037.

Question 3 of LAR-17-037 provides detailed guidance for Criterion 3 and contains examples of what are not considered material changes and would therefore not require prior NRC review and approval. The list includes minor corrections to drawings and figures (e.g., correcting mislabeled components)." It is unclear to the staff what drawings and figures this refers to since the Tier 2* information provided in FSAR Sections 4.2, 4.3, and 4.4 does not include any drawings or figures.

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

SNC Response to RAI Question 3 The reference in the Criterion 3 detailed guidance to minor corrections to drawings and figures was inappropriate, since there are no applicable figures or drawings in the UFSAR that are Tier 2*. Enclosure 1 of the original LAR-17-037 will be revised to remove this reference.

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

Revise the detailed guidance for Criterion 3 on Pages 10 and 11 of 19 as follows:

The following examples are not material changes:

o Editorial Changes Draft min mi is unc s unclea lea ovided in FSA ded in FS the licensee the license ctct the the C er

Response

io reactiv activ burn-up limi up lim erion 3 in respo on 3 in re Enclosures 1, 4 closures s detailed guida s detailed gu anges anges and w an r correct r co o t (05-17-2018) nce for ce for Criterion ite ould therefore n ould theref ons to drawings s to drawin e staff what dra e staff what d Sections 4.2, 4 ections 4.2 clarify which Ti larify which rion 3 n 3 guidance gui by Criterion 3 by Criterion stion 3 stion 3

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ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) 5 of 8 o

Clarifications to improve reader understanding o

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

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

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

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

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

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

Revise the detailed guidance for Criterion 3 on Pages 10 and 11 of 19 as follows (includes changes made in response to Question 3 of this RAI):

The following examples are not material changes:

o Editorial Changes Draft his N his N nformation ormatio emoving oving exce exce uidance state ance state dures dures they they do d

CFR Part 52 CFR Part 5 on on (i.e.

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do no ving detail) detai aning or sub ng or substa e in Enclosure Enclosu was to exclude to exclud se described in se describe Final Safety Final Saf guidanc gu cont (05-17-2018) rom the definitio m the defin NRC NRC-endorsed endo Analysis Report Analysis R e describes escribes cert c

ained in the UFS ined in the U ve detail, e detail, obsole bs hat because the at becau ot require evalua quire eva e no n t permitted permitt FSAR) without p AR) wit 000 plants) 000 plants), Se pplication of th plication s

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) 6 of 8 o

Clarifications to improve reader understanding o

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

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

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

SNC Response to RAI Question 5 The application of the terms adverse and design function as used in the guidance discussions in Enclosure 1 of the original LAR-17-037 is derived from the use of the same terms in NRC-endorsed guidance NEI 96-07, Revision 1, Guidelines For 10 CFR 50.59 Implementation (refer to footnote 6 on Page 12 of 19 in Enclosure 1 of the original LAR 17-037).

This NEI guidance provides an extensive discussion regarding how to evaluate whether a change adversely affects a design function. The term design function is defined in NEI 96-07 as follows (from Section 3.3 of NEI 96-07):

Design functions are UFSAR-described design bases functions and other SSC functions described in the UFSAR that support or impact design bases functions.

Implicitly included within the meaning of design function are the conditions under which intended functions are required to be performed, such as equipment response times, process conditions, equipment qualification and single failure.

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

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(05-17-2018) efin efin adverse verse and and nclosure 1 an ould be conside ould be con and design fun nd desig ginal LAR l LAR-177-03 6-07, Revision 07, Revisio e 6 on Page 12 6 on Pa an extensive dis n extensive design functio design fu of NEI 9 of NEI 96

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) 7 of 8 While it is not the intent of the LAR guidance to include the volume of the information contained in NEI 96-07 regarding the application of these terms, Enclosure 1 of the original LAR-17-037 will be revised to expand the reference to NEI 96-07 to clarify the use of the terms adverse and design function.

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

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

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

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

Under the 50.59 process NEI 96-07 allows changes to methodology input parameters; however, the staff considers Tier 2* information associated with NOTRUMP homogeneous sensitivity model and critical heat flux assessment during accumulator injection to be safety significant and an integral aspect of the methodology as approved for the AP1000. Therefore, the staff maintains that any changes to that information would involve a departure from a method of evaluation described in the FSAR and require prior NRC review and approval. Had Tier 2* not existed at the time of approval of the AP1000 design, the information related to the NOTRUMP methodology would have either been designated Tier 1 or a change to the approved topical report would have been necessary.

The staff requests that additional screening criteria be included in the Tier 2* departure evaluation process that captures the critical safety aspect of the Tier 2* information for small-break LOCA analysis methodology, and identify that any changes (material or otherwise) to those Tier 2* items must undergo NRC review and approval as a change to the methodology.

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ation process o ation proce sure 5.

e 5 The sta he ormation associ rmation ass Due to the uniq Due to th code to be de to be acc wo paragraphs ragra 07 allows 07 allows chan mation mation associa as assessment du assessment ethodology as thodolog o that inf o tha ARR a

ND-18-0xxx Enclosure X Response to NRC Request for Additional Information (RAI) LAR-17-037-9 Regarding the LAR-17-037 Review (LAR-17-037S3) 8 of 8 Proposed Criterion 3 will be revised as follows to capture the critical safety aspect of the Tier 2*

information for small break LOCA analysis methodology.

Changes to Original LAR-17-037 in response to RAI LAR-17-037-9, Question 6 Changes to Enclosure 1:

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

Due to the uniqueness of the AP1000 design, the use of the NOTRUMP code is considered acceptable, in part, because of the identified Tier 2* information in Chapter 15 (two paragraphs in Subsections 15.6.5.4B.2.2 and 15.6.5.4B.2.3). The Tier 2*

information associated with NOTRUMP homogeneous sensitivity model and critical heat flux assessment during accumulator injection is considered to be safety-significant and an integral aspect of the methodology as approved for the AP1000. Therefore, any changes to that information would involve a departure from a method of evaluation described in the FSAR and require prior NRC review and approval.

Changes to Enclosure 3:

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

3. Result in a material change to the fuel criteria evaluation process, the fuel principal design requirements, or nuclear design of fuel and reactivity control system,; or result in any change to the maximum fuel rod average burn-up limits; or result in any change to small break LOCA analysis methodology described in UFSAR Subsections 15.6.5.4B.2.2 or 15.6.5.4B.2.3; or Similar conforming changes are also applicable to Enclosures 1 and 4 of the original LAR 037.

Changes to Enclosure 5:

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

6 Small-break loss-of-coolant accident (LOCA) analysis methodology.

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

Draft chan cha

ents, ts, or or nu nu ft to the the maxim maxim af mall break L all break Dra ons 15.6.5.4 ons 15.6.5.4 Dr hanges hange

Response

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e us sensitivit ensitiv se onsidered to be idered to se ved f d for the AP or the ns departure from arture fr on RC review and review o

changes made changes ma e to the e to ar (05-17-2018) in response to esponse uel criteria evalu criteria ev design of fuel a design of fue fuel fuel rod avera rod A analysis meth analysis 17 2 or 15.6.5.4B.

15.6.

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