NL-04-2035, Revised Schedule for Generic Letter 2003-01 Control Room Habitability

Revised Schedule for Generic Letter 2003-01 Control Room Habitability

ML043030315
Person / Time
Site:	Hatch
Issue date:	10/27/2004
From:	Sumner H Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-03-001, NL-04-2035
Download: ML043030315 (2)

Text

H.L Sumner, Jr. Southern Nuclear Vice President Operating Company. Inc.

Hatch Project Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.7279 SOUTHERN hum October 27, 2004 COMPANY Energy to Serve Your WorldW DocketNos.: 50-321 NL-04-2035 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Revised Schedule for Generic Letter 2003-01 Control Room Habitability Ladies and Gentlemen:

By letters dated August 4, 2003 and March 29, 2004, Southern Nuclear Operating Company (SNC) submitted a course of action, including a schedule and associated justification, for developing responses to Generic Letter (GL) 2003-0 1, "Control Room Habitability" information requests. This letter provides a revision to the schedule for ASTM E741 tracer gas testing and responding to the GL 2003-01 information requests for the Edwin I. Hatch Nuclear Plant (HNP).

Based on an October 7, 2004 telephone conference between NRC staff and SNC personnel, SNC concluded that significant regulatory uncertainty existed regarding: 1) interpretation of the operability status of the control room with respect to potential tracer gas test results, and 2) the application of certain compensatory measures including potassium iodide. The regulatory uncertainty resulted from NRC staff discussion on the October 7 telecon that appeared to be inconsistent with the guidance contained in the NRC letter to NEI, dated January 30, 2004, titled "NEI Draft White Paper, Use of the Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability", as well as NRC/industry guidance contained in GL 91-18 revision 1, control room habitability related Regulatory Guides 1.196 and 1.197, and NEI control room habitability guidance in NEI 99-03 revisions 0 and 1. Since these issues could not be resolved prior to planned HNP tracer gas testing starting October 11, 2004, SNC has elected to revise the schedule.

Consistent with plans to conduct the HNP tracer gas testing the week beginning October 11, 2004, SNC had completed planned control room boundary maintenance. In addition, the necessary test procedures were already in place and the test vendor was completing final arrangements in preparation for starting testing October 11, 2004.

Finally, those procedure changes necessary to support planned compensatory measures were ready for implementation should they have been required.

As a result of the regulatory uncertainty introduced by the October 7 telecon, SNC now plans to complete tracer gas testing within 120 days of receipt of NRC approval for

U. S. Nuclear Regulatory Commission NL-04-2035 Page 2 implementation of an alternative source term (AST) in accordance with 10 CFR 50.67.

Within 90 days after completion of the HNP tracer gas testing, SNC wvill submit the information requested by GL 2003-01. The license amendment request supporting full scope implementation of an AST in accordance with Regulatory Guide 1.183 is planned for submittal by December 31, 2004.

The revised schedule allows for HNP tracer gas testing to be performed following implementation of AST which will result in a design basis control room unfiltered inleakage value with considerably more design margin than the current HNP licensing/design basis. Discussions between NRC staff and SNC personnel during the NEI Licensing Forum on October 20-21, 2004 appeared to deal with some of the issues raised during the October 7 telecon. However, continued significant regulatory uncertainty regarding the application of potassium iodide as a compensatory measure remains a fundamental impediment to conducting tracer gas testing prior to implementation of AST.

This letter contains no NRC commitments. If you have any questions, please advise.

Sincerely, H. L. Sumner, Jr.

HLS/CLT/daj cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. G. R. Frederick, General Manager - Plant Hatch RTYPE: CHAO2.004 U. S. Nuclear Regulatorv Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Hatch Mr. D. S. Simpkins, Senior Resident Inspector - Hatch

Text

H.L Sumner, Jr. Southern Nuclear Vice President Operating Company. Inc.

Hatch Project Post Office Box 1295 Birmingham. Alabama 35201 Tel 205.992.7279 SOUTHERN hum October 27, 2004 COMPANY Energy to Serve Your WorldW DocketNos.: 50-321 NL-04-2035 50-366 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Revised Schedule for Generic Letter 2003-01 Control Room Habitability Ladies and Gentlemen:

By letters dated August 4, 2003 and March 29, 2004, Southern Nuclear Operating Company (SNC) submitted a course of action, including a schedule and associated justification, for developing responses to Generic Letter (GL) 2003-0 1, "Control Room Habitability" information requests. This letter provides a revision to the schedule for ASTM E741 tracer gas testing and responding to the GL 2003-01 information requests for the Edwin I. Hatch Nuclear Plant (HNP).

Based on an October 7, 2004 telephone conference between NRC staff and SNC personnel, SNC concluded that significant regulatory uncertainty existed regarding: 1) interpretation of the operability status of the control room with respect to potential tracer gas test results, and 2) the application of certain compensatory measures including potassium iodide. The regulatory uncertainty resulted from NRC staff discussion on the October 7 telecon that appeared to be inconsistent with the guidance contained in the NRC letter to NEI, dated January 30, 2004, titled "NEI Draft White Paper, Use of the Generic Letter 91-18 Process and Alternative Source Terms in the Context of Control Room Habitability", as well as NRC/industry guidance contained in GL 91-18 revision 1, control room habitability related Regulatory Guides 1.196 and 1.197, and NEI control room habitability guidance in NEI 99-03 revisions 0 and 1. Since these issues could not be resolved prior to planned HNP tracer gas testing starting October 11, 2004, SNC has elected to revise the schedule.

Consistent with plans to conduct the HNP tracer gas testing the week beginning October 11, 2004, SNC had completed planned control room boundary maintenance. In addition, the necessary test procedures were already in place and the test vendor was completing final arrangements in preparation for starting testing October 11, 2004.

Finally, those procedure changes necessary to support planned compensatory measures were ready for implementation should they have been required.

As a result of the regulatory uncertainty introduced by the October 7 telecon, SNC now plans to complete tracer gas testing within 120 days of receipt of NRC approval for

U. S. Nuclear Regulatory Commission NL-04-2035 Page 2 implementation of an alternative source term (AST) in accordance with 10 CFR 50.67.

Within 90 days after completion of the HNP tracer gas testing, SNC wvill submit the information requested by GL 2003-01. The license amendment request supporting full scope implementation of an AST in accordance with Regulatory Guide 1.183 is planned for submittal by December 31, 2004.

The revised schedule allows for HNP tracer gas testing to be performed following implementation of AST which will result in a design basis control room unfiltered inleakage value with considerably more design margin than the current HNP licensing/design basis. Discussions between NRC staff and SNC personnel during the NEI Licensing Forum on October 20-21, 2004 appeared to deal with some of the issues raised during the October 7 telecon. However, continued significant regulatory uncertainty regarding the application of potassium iodide as a compensatory measure remains a fundamental impediment to conducting tracer gas testing prior to implementation of AST.

This letter contains no NRC commitments. If you have any questions, please advise.

Sincerely, H. L. Sumner, Jr.

HLS/CLT/daj cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. G. R. Frederick, General Manager - Plant Hatch RTYPE: CHAO2.004 U. S. Nuclear Regulatorv Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Hatch Mr. D. S. Simpkins, Senior Resident Inspector - Hatch