ML081970569
| ML081970569 | |
| Person / Time | |
|---|---|
| Site: | Hatch, Vogtle, Farley  |
| Issue date: | 09/03/2008 |
| From: | Melanie Wong NRC/NRR/ADRO/DORL/LPLII-1 |
| To: | David Jones Southern Nuclear Operating Co |
| Martin R, NRR/DORL, 415-1493 | |
| References | |
| GL-08-001, TAC MD7825, TAC MD7826, TAC MD7833, TAC MD7834, TAC MD7892, TAC MD7893 | |
| Download: ML081970569 (10) | |
Text
September 3, 2008 Mr. David H. Jones Vice President Engineering Southern Nuclear Operating Company 40 Inverness Center Parkway Birmingham, Alabama 35242
SUBJECT:
HATCH NUCLEAR PLANT UNITS 1 AND 2, FARLEY NUCLEAR PLANT UNITS 1 AND 2, AND VOGTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 -
RE: GENERIC LETTER 2008-01, MANAGING GAS ACCUMULATION IN EMERGENCY CORE COOLING, DECAY HEAT REMOVAL, AND CONTAINMENT SPRAY SYSTEMS, PROPOSED ALTERNATIVE COURSE OF ACTION (TAC NOS. MD7833, MD7834, MD7825, MD7826, MD7892, AND MD7893)
Dear Mr. Jones:
On January 11, 2008, the U.S. Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
By letter dated May 30, 2008, Southern Nuclear Operating Company, Inc. (SNC, the licensee),
the licensee, submitted a 3-month response to GL 2008-01 for Hatch Nuclear Plant Units 1 and 2 (Hatch-1 and Hatch-2), Farley Nuclear Plant Units 1 and 2 (Farley-1 and Farley-2), and Vogtle Electric Generating Plant Units 1 and 2 (Vogtle-1 and Vogtle-2). The NRC staffs assessment of the responses for Hatch-1, Hatch-2, Farley-1, Farley-2, Vogtle-1 and Vogtle-2 is contained in the enclosure.
The NRC staff reviewed the licensees proposed alternative course of action and the associated basis for acceptance and concluded that for Hatch, Farley and Vogtle, the licensees reasons and basis for acceptability for why walkdowns of some piping segments of the GL subject systems would not be completed by October 11, 2008, is acceptable. However, the NRC staff requests that the licensee submit a 3-month supplemental response for Hatch, Farley and
D.
Vogtle to revise its proposed alternative course of action related to its 9-month initial response and its 9-month supplemental (post-outage) response as described in the enclosure.
If you have any questions regarding this letter, please feel free to contact Bob Martin at (301) 415-1493.
Sincerely,
/RA/
Melanie C. Wong, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321, 50-366, 50-348, 50-364, 50-424 and 50-425
Enclosure:
As stated cc w/encl: See next page
D.
Vogtle to revise its proposed alternative course of action related to its 9-month initial response and its 9-month supplemental (post-outage) response as described in the enclosure.
If you have any questions regarding this letter, please feel free to contact Bob Martin at (301) 415-1493.
Sincerely,
/RA/
Melanie C. Wong, Chief Plant Licensing Branch II-1 Division of Operating Reactor Licensing Office of Nuclear Reactor Regulation Docket Nos. 50-321, 50-366, 50-348, 50-364, 50-424 and 50-425
Enclosure:
As stated cc w/encl: See next page DISTRIBUTION:
PUBLIC RidsRgn2MailCenterResource LPL2-1 R/F DBeaulieu, DPR/PGCB RidsNrrDorlLpl2-1Resource SSun, DSS/SRXB RidsNrrLAGLappertResource WLyon, DSS/SRXB RidsNrrPMRMartinResource RidsNrrDorlDprResource RidsOgcRpResource RidsAcrsAcnw_MailCTRResource ADAMS Accession Number: ML081970569
- by e-mail OFFICE NRR/LPL2-1/PM NRR/LPL2-1/LA NRR/DPR/PGCB/BC NRR/DSS/DD NRR/LPL2-1/BC NAME RMartin GLappert MMurphy JWermeil MWong DATE 08/13/08
- 08/13/08
- 09/02/08 08/13/08 09/03/08 OFFICIAL RECORD COPY
NRC STAFF ASSESSMENT OF 3-MONTH RESPONSE TO GENERIC LETTER 2008-01 HATCH NUCLEAR PLANT UNITS 1 AND 2, FARLEY NUCLEAR PLANT UNITS 1 AND 2, AND VOGTLE ELECTRIC GENERATING PLANT UNITS 1 AND 2 DOCKET NOS. 50-321, 50-366, 50-348, 50-364, 50-424 AND 50-425 1.0 Background On January 11, 2008, the Nuclear Regulatory Commission (NRC) issued Generic Letter (GL) 2008-01, Managing Gas Accumulation in Emergency Core Cooling, Decay Heat Removal, and Containment Spray Systems (Agencywide Documents Access and Management System (ADAMS) Accession No. ML072910759). The GL requested licensees to submit information to demonstrate that the emergency core cooling, decay heat removal, and containment spray systems (hereinafter referred to as the subject systems) are in compliance with the current licensing and design bases and applicable regulatory requirements, and that suitable design, operational, and testing control measures are in place for maintaining this compliance.
Specifically, the GL requested licensees to provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
In accordance with Section 50.54(f) of Title 10 of the Code of Federal Regulations (10 CFR),
GL 2008-01 required that each licensee submit the requested information within 9 months (hereinafter referred to as the 9-month submittal) of the date of the GL. The GL also stated that if a licensee cannot meet the requested 9-month response date, the licensee is required to provide a response within 3 months (hereinafter referred to as the 3-month submittal) of the date of the GL, describing the alternative course of action it proposes to take, including the basis for the acceptability of the proposed alternative course of action.
2.0 Licensees Proposed Alternative Course of Action By letter dated May 30, 2008, South Nuclear Operating Company, Inc. (SNC), the licensee, submitted a 3-month response to GL 2008-01 for Hatch Nuclear Plant Units 1 and 2 (Hatch-1 and Hatch-2), Farley Nuclear Plant Units 1 and 2 (Farley-1 and Farley-2), and Vogtle Electric Generating Plant Units 1 and 2 (Vogtle-1 and Vogtle-2). SNC indicated that for Hatch, Farley and Vogtle, the following GL 2008-01 reporting request would not be completed by the requested response time:
- 1.
Design Evaluation That Would Not Be Completed By October 11, 2008 Walkdowns of some piping segments of the GL subject systems would not be completed by October 11, 2008 because of one or more of the following reasons: (1) high radiation
areas during power operation need to be entered; (2) confined spaces need to be entered; (3) prolonged containment entries during power operation need to made; (4) piping is buried; (5) insulation needs to be removed from piping; and (6) scaffolding needs to be erected. SNC will complete promptly non-outage related walkdowns of piping segments that require high radiation area access, scaffolding and/or insulation removal, confined space entry, or are related to buried piping, with consideration given to nuclear and industry safety. SNC planned to complete walkdowns of piping segments that require a refueling outage for performance according to the following schedule:
Farley fall 2008 Vogle fall 2008 Hatch spring 2009 Farley spring 2009 Vogtle fall 2009, and Hatch spring 2010.
If the above refueling outage schedule is changed, SNC will provide an updated schedule with the 9-month response. The licensee stated that the current schedule for these walkdowns is acceptable due to low risk of gas intrusion issues. This acceptability is based on updated surveillance procedures, recent operating history, adequacy of the design basis was determined from previous system evaluation such as for INPO SOER 97-01, Potential Loss of High Pressure Injection and Charging Capability from Gas Intrusion, and SER 2-05, Gas Intrusion in Safety System, and Engineering and Operator training coverage of the gas intrusion subject.
- 2.
Testing Evaluation and Corrective Action Evaluation That Would Not Be Completed By October 11, 2008 SNC indicated that the requested GL action to review all applicable procedures and describe all corrective actions that result from the procedure reviews would not be entirely completed by October 11, 2008, due to the large number of procedures to be reviewed. The scope of procedures that may be affected by the evaluation requested in GL 2008-01 includes:
Maintenance, Testing (e.g., all pump tests including restoration to standby conditions), and Plant evolutions (e.g., suction source change such as tank to suppression pool or the refueling water storage tank to containment sump or evolutions involving idle train startup).
The license stated that the current plan for completing all procedure reviews is acceptable based on previous reviews associated with previously identified gas intrusion issues. As a compensatory measure, additional pre-job briefing will be conducted for activities that have been associated with gas accumulation issues, to stress measures to identify and eliminate gas voids and to take appropriate corrective actions for any conditions adverse to quality.
The licensee provided the following commitment for completion of the GL 2008-01 response:
Complete GL 2008-01 requested licensing basis evaluation prior to nine months from the date of GL 2008-01.
3.0 NRC staff Assessment The NRC staff finds that for Hatch, Farley and Vogtle, the licensees reasons and basis for acceptability for why walkdowns of some piping segments of the GL subject systems would not be completed by October 11, 2008, is acceptable based on the above-described operating experience, current designs and inspection results associated with managing gas accumulation.
However, the NRC staff requests that the licensee submit a 3-month supplemental response for Hatch, Farley and Vogtle to revise its proposed alternative course of action related to its 9-month initial and supplemental response as described below.
The NRC staff notes the following examples where the licensees 3-month submittal dated May 30, 2008, does not clearly describe the content and/or schedule for the 9-month submittals:
(1)
Although the submittal stated that the reviews of all applicable procedures and the description of all corrective actions resulting from the procedure reviews would not be entirely completed by October 11, 2008, the submittal is unclear regarding the schedule for completing and reporting the results of the procedure reviews.
(2)
Even though the licensees May 30, 2008, submittal stated, that walkdowns of piping segments that require a refueling outage for performance will be completed in accordance with the schedule listed for Hatch, Farley and Vogtle in item 1 of Section 2 of this assessment, it is not clear if: (1) that is the schedule the information will be submitted to the NRC; and (2) that schedule is within 90 days following startup from the first refueling outages that initiate after October 11, 2008 for the respective units.
The NRC staff requests that the licensee submit a 3-month supplemental response for Hatch, Farley and Vogtle to revise its proposed alternative course of action related to its 9-month initial and supplemental response. The NRC staff requests that the licensee submit the information requested in the GL as follows:
(1) 9-Month Initial Submittal - For the portions of the subject systems that are accessible prior to the refueling outages in accordance with the schedule listed in item 1 of Section 2 of this evaluation Hatch, Farley and Vogtle, provide all GL requested information to the NRC by October 11, 2008. This includes completing the review of as many applicable procedures as practical, and providing the results and the description of corrective actions resulting from the procedure reviews.
(2) 9-Month Supplemental (Post-Outage) Submittals - Except for the long-term items described below, provide all remaining GL requested information for the subject systems to the NRC within 90 days following startup from each of the refueling
outages for Hatch, Farley and Vogtle for first refueling outage at each unit that initiates after October 11, 2008.
For each of these two submittals (the 9-month initial and supplemental submittals), and consistent with the information requested in the GL, the licensees should provide: (1) a description of the results of evaluations that were performed in response to the GL; (2) a description of all corrective actions that the licensee determined were necessary; and (3) a statement regarding which corrective actions were completed, the schedule for completing the remaining corrective actions, and the basis for that schedule.
The NRC staff notes that the licensees submittal dated May 30, 2008, did not mention other potential long-term actions that are identified in the GL. For instance, the industry is assessing whether it is necessary to perform pump testing to determine the allowable limits on ingested gas volume in pump suctions, as well as the need to develop an analysis capability to adequately predict void movement (entrapped gas) from piping on the suction side of the pumps into the pumps. It is unlikely this industry effort will be complete for the 9-month initial or supplemental submittals. Further, technical specification changes may be necessary to reflect the improved understanding achieved during response to the GL, but these cannot be fully developed for the 9-month initial or supplemental submittals. A Technical Specifications Task Force traveler may provide a generic example that can be adopted by licensees. The NRC staff requests that the licensee address in its 9-month submittal how it plans to track such long-term actions (e.g., Corrective Action Program and/or commitment tracking). The NRC plans to perform follow up inspections of licensee responses to GL 2008-01 at all plants using a Temporary Instruction inspection procedure.
Edwin I. Hatch Nuclear Plant, Units 1 & 2 cc:
Mr. Dennis R. Madison Vice President - Hatch Edwin I. Hatch Nuclear 11028 Hatch Parkway North Baxley, GA 31513 Laurence Bergen Oglethorpe Power Corporation 2100 E. Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Mr. R. D. Baker Manager - Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Resident Inspector Plant Hatch 11030 Hatch Parkway N.
Baxley, GA 31531 Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE., Suite 1252 Atlanta, GA 30334 Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Arthur H. Domby, Esq.
Troutman Sanders Nations Bank Plaza 600 Peachtree St, NE, Suite 5200 Atlanta, GA 30308-2216 Chairman Appling County Commissioners County Courthouse Baxley, GA 31513 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. K. Rosanski Resident Manager Oglethorpe Power Corporation Edwin I. Hatch Nuclear Plant P.O. Box 2010 Baxley, GA 31515
Joseph M. Farley Nuclear Plant, Units 1 & 2 cc:
Mr. J. Randy Johnson Vice President - Farley Joseph M. Farley Nuclear Plant 7388 North State Highway 95 Columbia, AL 36319 Mr. B. D. McKinney, Licensing Manager Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. M. Stanford Blanton Balch and Bingham Law Firm P.O. Box 306 1710 Sixth Avenue North Birmingham, AL 35201 Mr. J. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201 State Health Officer Alabama Department of Public Health 434 Monroe St.
Montgomery, AL 36130-1701 Chairman Houston County Commission P.O. Box 6406 Dothan, AL 36302 Resident Inspector U.S. Nuclear Regulatory Commission 7388 N. State Highway 95 Columbia, AL 36319 William D. Oldfield SAER Supervisor Southern Nuclear Operating Company, Inc.
P.O. Box 470 Ashford, AL 36312
Vogtle Electric Generating Plant, Units 1 & 2 cc:
Mr. Tom E. Tynan Vice President - Vogtle Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830 Mr. N. J. Stringfellow Manager, Licensing Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Jeffrey T. Gasser Executive Vice President Southern Nuclear Operating Company, Inc.
P.O. Box 1295 Birmingham, AL 35201-1295 Mr. Steven M. Jackson Senior Engineer - Power Supply Municipal Electric Authority of Georgia 1470 Riveredge Parkway, NW Atlanta, GA 30328-4684 Mr. Reece McAlister Executive Secretary Georgia Public Service Commission 244 Washington St., SW Atlanta, GA 30334 Mr. Harold Reheis, Director Department of Natural Resources 205 Butler Street, SE, Suite 1252 Atlanta, GA 30334 Attorney General Law Department 132 Judicial Building Atlanta, GA 30334 Mr. Laurence Bergen Oglethorpe Power Corporation 2100 East Exchange Place P.O. Box 1349 Tucker, GA 30085-1349 Arthur H. Domby, Esquire Troutman Sanders Nations Bank Plaza 600 Peachtree Street, NE Suite 5200 Atlanta, GA 30308-2216 Resident Inspector Vogtle Plant 8805 River Road Waynesboro, GA 30830 Office of the County Commissioner Burke County Commission Waynesboro, GA 30830 Mr. Bob Masse Resident Manager Oglethorpe Power Corporation Vogtle Electric Generating Plant 7821 River Road Waynesboro, GA 30830