NL-06-1458, Response to Request for Additional Information Regarding Technical Specification Review Request, Containment Tendon Surveillance Program

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Response to Request for Additional Information Regarding Technical Specification Review Request, Containment Tendon Surveillance Program
ML061880282
Person / Time
Site: Vogtle  
Issue date: 07/06/2006
From: Sumner H
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-06-1458
Download: ML061880282 (5)


Text

H. L Sumner, Jr.

Vice President July 6, 2006 Docket Nos.:

50-424 50-425 Southern Nuclear Operating Company, Inc.

40 lnverness Center Parkway Post Office Box 1295 Birmingham. Alabama 352111 Tel 205.992.7279 Fax 205.992.0341 SOUTHERN A COMPANY Energy to Serve Your World" U. S. Nuclear Regulatory Commission ATIN: Document Control Desk Washington, D. C. 20555-000 1 Vogtle Electric Generating Plant Response to Request for Additional Information Regarding Technical Specification Revision Request Containment Tendon Surveillance Prouam Ladies and Gentlemen:

On March 29,2006, Southern Nuclear Operating Company (SNC) submitted a proposed change to the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS). The proposed amendment will revise VEGP TS section 5.5, "Programs and Manuals," section 5.6, "Reporting Requirements," and TS Bases for LC0 3.6.1, "Containment," relative to references of the VEGP Containment Tendon Surveillance Program in order to reflect the latest requirements for tendon surveillance.

On June 6,2006, SNC received a Request for Additional Information (RAI) containing 2 questions from the staff concerning the VEGP Containment Tendon Surveillance Program Submittal. SNC responses to these questions are enclosed.

(Signature and affirmation are on the following page.)

U. S. Nuclear Regulatory Commission NL 145 8 Page 2 Mr. H. L. Sumner, Jr. states he is a Vice President of Southern Nuclear Operating Company, is authorized to execute this oath on behalf of Southern Nuclear Operating Company and to the best of his knowledge and belief, the facts set forth in this letter are true.

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

Respectfully submitted, NUCLEAR OPERATING COMPANY H. L. Sumner, Jr.

Enclosure:

Vogtle Electric Generating Plant Response to Request for Additional Information Regarding the Containment Tendon Surveillance Program cc:

Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. E. Grissette, Vice-President - Plant Vogtle Mr. T. E. Tynan, General Manager - Plant Vogtle RType: CVC7000 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle State of Georgia Mr. L. C. Barrett, Commissioner - Department of Natural Resources

Enclosure Vogtle Electric Generating Plant Response to Request for Additional Information Regarding the Containment Tendon Surveillance Program

Vogtle Electric Generating Plant Response to Request for Additional Information Regarding the Containment Tendon Surveillance Program NRC Ouestion 1 In the first page of the enclosure to SNC's letter, SNC stated that "The requirements of Regulatory Guide 135, Revision 2 with the exceptions referenced in TS 5.5.6 are included in ASME Code Section XI, Subsection IWL as modified by [Title 10 of the Code of Federal Regulations (10 CFR), Part 50, Section 50.55a(b)(2)(viii)] 10 CFR 5055a(b)(2)(viii)." Please clarify how the requirements of 10 CFR 50.55a(b)(2)(viii)(A-E) are addressed in SNC's inspection program.

SNC Response to NRC Ouestion 1 Southern Nuclear Operating Company's (SNC) Vogtle Electric Generating Plant (VEGP) utilizes the equivalent requirements of the 1997 10 CFR 50.55a(b)(2)(ix),

which are required to be met per the VEGP Containment Inspection Program Plan.

In accordance with the VEGP Containment Inspection Program Plan, VEGP addresses the 10 CFR 50.55a(b)(2)(ix)(A) examination requirement by performing grease cap inspections at the same frequency as the VT3C required by IWL Item L1.ll.

The VEGP Containment Inspection Program Plan captures the reporting requirements of IWA-6000 as supplemented by 10 CFR 50.55a(b)(2)(ix)(B-E). In addition, the non-reporting requirements of 10 CFR 50.55a(b)(2)(ix)(B-C) are listed in VEGP procedure "Containment Tendon Surveillance Requirements" as acceptance criteria.

As noted in the VEGP Containment Inspection Program Plan, Request for Engineering Reviews are used to evaluate potential degradation in inaccessible areas as described in requirement 10 CFR 50.55a(b)(2)(ix)(E).

NRC Ouestion 2 In the second page of the enclosure to SNC's letter under TS Section 5.5.17 "Containment Leakage Rate Testing Program, SNC stated that "The visual examination of containment concrete surfaces intended to fulfill the requirements of 10 CFR [Part] 50, Appendix J, option B testing, will be performed in accordance with the requirements of and frequency specified by ASME section XI Code, Subsection IWL." Please clarify how SNC's inspection program meets these requirements.

Enclosure Page 1 of 2

Vogtle Electric Generating Plant Response to Request for Additional Information Regarding the Containment Tendon Surveillance Program SNC Resvonse to NRC Ouestion 2 10 CFR 50 Appendix J, Option B requires that:

"A general visual inspection of the accessible interior and exterior surfaces of the containment system for structural deterioration which may affect the containment leak-tight integrity must be conducted prior to each test, and at a periodic interval between tests based on the performance of the containment system."

The IWE general visual exam (JWE-35 10.1) in conjunction with the IWL Concrete surface VT-3C exams (IWL-25 10) of the interior surfaces and exterior surfaces of the containment at an interval described in Section XI meets the intent of 10 CFR Appendix J, Option B for VEGP. In addition, both the IWE and IWL containment surface visual exams are performed when performing a Type A test in accordance with 10 CFR 50 Appendix J, Option B.

Enclosure Page 2 of 2