NL-08-1122, License Renewal - Revised RAI Responses 3.3-1 & 3.4-1

License Renewal - Revised RAI Responses 3.3-1 & 3.4-1

ML081990458
Person / Time
Site:	Vogtle
Issue date:	07/17/2008
From:	Tynan T Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-08-1122
Download: ML081990458 (5)

Text

Tom Tynan Southern Nuclear Vice President Vogtle Operating Company, Inc.

7821 River Road Waynesboro, Georgia 30830 Tel 706 8263151 Fax 706 8263321 July 17, 2008 SOUTHERN COMPANY A.

Energy to Serve }'Our World'*

Docket Nos.: 50-424 NL-08-1122 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant License Renewal - Revised RAI Responses Ladies and Gentlemen:

By letter dated June 27, 2007, Southern Nuclear Operating Company (SNC) submitted a License Renewal Application (LRA) for Vogtle Electric Generating Plant (VEGP) Units 1 and 2, seeking to extend the terms of the operating licenses an additional 20 years beyond the current expiration dates.

Since submittal of the LRA, SNC has responded to Nuclear Regulatory Commission (NRC) Requests for Additional Information (RAls) by various letters.

In response to questions raised during telephone conversations with the NRC staff, the response to RAI 3.3-1 & 3.4-1 has been revised. The revised response to this RAI is provided in the Enclosure to this letter. Changes from the previous response are indicated by revision bars adjacent to affected paragraphs.

(Affirmation and signature are provided on the following page.)

U. S. Nuclear Regulatory Commission NL-08-1122 Page 2 Mr. T. E. Tynan 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, SOUTHERN NUCLEAR OPERATING COMPANY 15:~~

T. E. Tynan Vice President - Vogtle

~orn to and subscribed before me this ~ fh day of 00\t jllJ1J -U---' 2008.

~{)l\J;Ylx ~ . ~(~

Nbtary Public Notary Public, BlJr~:e Co:~n:y, Georgia My commission expires: My Commission [)(!1 i""3 January 13, 201?

TETICMldaj

Enclosure:

Revised Response to RAI 3.3-1 & 3.4-1 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President wlo Enclosure Mr. D. H. Jones, Vice President - Engineering wlo Enclosure Mr. M. J. Ajluni, Manager, Nuclear Licensing wi Enclosure Mr. N. J. Stringfellow, Licensing Supervisor, Vogtle wi Enclosure RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator wi Enclosure Mr. R. A. Jervey, NRR Project Manager - Vogtle wi Enclosure Mr. G. J. McCoy, Senior Resident Inspector - Vogtle wi Enclosure State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources wlo Enclosure

Vogtle Electric Generating Plant License Renewal - Revised RAI Responses Enclosure Revised Response to RAI 3.3-1 & 3.4-1

VEGP License Renewal Audit Requests and Responses RAI- 3.3-1&3.4-1 Regarding the use of AMP's (e.g., the External Surfaces Monitoring Program) that credit visual examinations of external polymer (including elastoers, thermoplastics, thermoset, or rubber materials) surfaces, justify your basis for crediting the AMP for aging management of cracking and changes in material properties of the polymetric materials. Clarify how a visual examination alone is capable of detecting a crack or a change in a specific material property (such as a change in a hardness, strength, elasticity or fracture toughness property) in these type of materials.

VEGP Response:

Mechanical components in the scope of license renewal which are constructed from polymeric materials are managed by four aging management programs: External Surfaces Monitoring Program, Fire Protection Program, Periodic Surveillance and Preventive Maintenance Activities, and Piping and Duct Internal Inspection Program.

External Surfaces Monitoring Program The VEGP External Surfaces Monitoring Program does not credit visual examination alone for detecting changes in material properties (including cracking) of polymeric materials.

Visual examinations will be performed to detect discontinuities and imperfections on the surface of components, including such conditions as cracking, peeling, blistering, chalking, crazing, delamination, flaking, discoloration, or physical distortion.

In addition, the VEGP External Surfaces Monitoring Program refers to EPRI guidance documents (primarily EPRI 1007933) that provide for the use of tactile techniques in conjunction with visual examination as described above.

Tactile techniques include scratching the material surface to screen for waxy or chalky residues (which can be indicative of polymer breakdown), pressing the polymer to qualitatively evaluate resiliency, bending or folding the polymer to identify crazing (surface cracking) or whitening (which can be indicative of reduced bonding of the filler), and stretching to evaluate tear resistance.

VEGP credits both visual examination and tactile examination techniques as described in EPRI guidance documents for aging management of polymeric materials which are in the scope of the External Surfaces Monitoring Program.

Fire Protection Program Inspections of fire barrier seals and seismic gap fire seals are performed in accordance with the applicable fire codes and standards. EPRI guidance is not applicable to this program.

Periodic Surveillance and Preventive Maintenance Activities Periodic Surveillance and Preventive Maintenance Activities include inspection of tank diaphragms, and of flexible connectors and access panel seals on the Control Room Filter Units.

Tank diaphragms are visually inspected for water on top of the diaphragms, and for other abnormalities. Physical manipulation of tank diaphragms is not appropriate due to the limited access to the interior of the tanks. The function of the diaphragms is to prevent oxygen infiltration to the process fluids. Monitoring of the chemistry of the process fluids provides indirect indication of the condition of the tank diaphragms. The visual inspections, supported by monitoring of fluid chemistry, provide assurance of the integrity of these components.

The Control Room Filter Units' flexible connectors and access panel seals are visually inspected for damage or other abnormalities. As discussed in the operating experience section of this aging management program, these periodic visual inspections have identified instances of degradation of the filter unit door seals, indicating that the program to monitor these seals is effective.

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VEGP License Renewal Audit Requests and Responses Piping and Duct Internal Inspection Program The VEGP Piping and Duct Internal Inspection Program does not credit visual examination alone for detecting changes in material properties (including cracking) of polymeric materials.

Visual examinations will be performed to detect discontinuities and imperfections on the surface of components, including such conditions as cracking, surface bloom, wrinkling, chalking, crazing, delamination, flaking, discoloration, or distortion.

In addition, the VEGP Piping and Duct Internal Inspection Program implementing procedures require physical manipulation of elastomers. The inspection procedure refers to EPRI guidance document1007933 that provides for the use of tactile techniques in conjunction with visual examination as described above. Tactile techniques include scratching the material surface to screen for waxy or chalky residues (which can be indicative of polymer breakdown), pressing the polymer to qualitatively evaluate resiliency, bending or folding the polymer to identify crazing (surface cracking) or whitening (which can be indicative of reduced bonding of the filler), and stretching to evaluate tear resistance.

VEGP credits both visual examination and tactile examination techniques as described in EPRI guidance documents for aging management of polymeric materials which are in the scope of the Piping and Duct Internal Inspection Program.

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