NL-08-0811, Request for Implementation Extension for License Amendment Request to Revise Technical Specification (TS) 3.3.2, ESFAS Instrumentation, and TS 3.5.4, Refueling Water Storage Tank (Rwst).

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Request for Implementation Extension for License Amendment Request to Revise Technical Specification (TS) 3.3.2, ESFAS Instrumentation, and TS 3.5.4, Refueling Water Storage Tank (Rwst).
ML081430154
Person / Time
Site: Vogtle  Southern Nuclear icon.png
Issue date: 05/21/2008
From: David Jones
Southern Nuclear Operating Co
To:
Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-002, NL-08-0811
Download: ML081430154 (3)


Text

David H. Jones Southern Nuclear Vice President Operating Company, Inc.

Engineering 40 Invemess Center Parkway Birmingham. Alabama 35242 Tel 205.992.5984 Fax 205.992.0341 SOUTHE-A May 21,2008 COMPANY Energy to Serve lOur WorU""

Docket Nos.: 50-424 NL-08-0811 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Request for Implementation Extension for License Amendment Request to Revise Technical Speci'fication (TS) 3.3.2, "ESFAS Instrumentation,"

and TS 3.5.4. "Refueling Water Storage Tank (RWST)"

Ladies and Gentlemen:

On January 9, 2008 Southern Nuclear Operating Company (SNC) submitted a License Amendment Request (LAR) to the NRC to revise the Vogtle Electric Generating Plant (VEGP) Technical Specifications (TS) 3.3.2, "ESFAS Instrumentation," and TS 3.5.4, "Refueling Water Storage Tank (RWST)." The proposed TS changes are required to meet commitments related to the resolution of issues identified in NRC Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated September 13, 2004.

By SNC letter (NL-07-1969) to the NRC, dated December 7,2007, SNC requested an extension to the completion schedule to extend the completion of the corrective actions reqUired by Generic Letter 2004-02 for VEGP Units 1 and 2 from December 31,2007 to June 30,2008. This would allow SNC to complete downstream effects modifications for Unit 1, complete the downstream effects evaluation for both units, receive and process the screen vendors' test reports for chemical effects testing, and allow sufficient time for the NRC review and approval of this TS amendment request. As stated in the letter, the TS amendment is needed to ensure that the new RHR sump screens would be fUlly submerged in the worst case accident scenario at the initiation of cold-leg recirculation. This extension request to May 31,2008 was SUbsequently approved by the NRC in a letter dated December 19, 2007.

U. S. Nuclear Regulatory Commission NL-08-0811 Page 2 On January 28,2008, SNC received a Request for Additional Information (RAI) from the NRC regarding the January 9, 2008 submittal. SNC responded to the subject RAI by letter dated February 6, 2008 (NL-08-0143).

On February 25, 2008 a teleconference held between SNC, the NRC, and Westinghouse Electric Company LLC (Westinghouse), regarding the LAR, resulted in a request from the NRC for additional information. SNC responded to the request by letter dated March 5, 2008 (NL-08-0300).

On May 8, 2008, a teleconference held between SNC and the NRC, regarding the LAR, resulted in an additional request from the NRC for additional information. At this time, SNC is preparing a response to the NRC's request in a separate letter.

On May 20,2008, in a phone conversation between the NRR Project Manager for VEGP and the SNC VEGP Licensing Manager, the NRC requested that SNC add a new footnote to VEG P TS Table 3.3.2-1, Function 7.b regarding the implementation of the proposed new RWST Level-Low Low Nominal Trip Setpoint and Allowable Values. Addition of the new footnote to the VEGP TS will require additional time for review by the Plant Review Board and the Corporate Safety Review Board. As a result of this latest NRC request, SNC respectfully requests an extension for the implementation of the LAR from May 31,2008 to 30 days from receipt of the NRC's approval of the LAR.

The addition of the proposed footnote will not alter the conclusions of the Significant Hazards Consideration Evaluation provided with our original submittal (NL-07-1969) to the NRC, dated December 7,2007. The revised TS page will be provided to the NRC in a separate letter, along with SNC's response to the NRC's RAI from May 8, 2008.

VEGP has staged the necessary design change work involved in making the setpoint changes, contingent on receipt of NRC's approval. In addition to the design change work, draft operations, maintenance, and administrative procedures are prepared for implementation, as well as applicable personnel training. The 30-day implementation period from receipt of the NRC's approval of the LAR would provide the necessary time to ensure that the approved TS changes are implemented safely and properly.

U. S. Nuclear Regulatory Commission NL-08-0811 Page 3 Mr. D. H. Jones 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.

D. H. Jone Vice President - Engineering

~,~n~subscribed before me thitti?CS--deyof ~ I 2008.

. ~

My commission expires: $L ('1-/0 LMS/LPH/daj cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, Vice President - Vogtle Mr. L. M. Stinson, Vice President - Fleet Operations Support RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. A. Jervey, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources

Text

David H. Jones Southern Nuclear Vice President Operating Company, Inc.

Engineering 40 Invemess Center Parkway Birmingham. Alabama 35242 Tel 205.992.5984 Fax 205.992.0341 SOUTHE-A May 21,2008 COMPANY Energy to Serve lOur WorU""

Docket Nos.: 50-424 NL-08-0811 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Request for Implementation Extension for License Amendment Request to Revise Technical Speci'fication (TS) 3.3.2, "ESFAS Instrumentation,"

and TS 3.5.4. "Refueling Water Storage Tank (RWST)"

Ladies and Gentlemen:

On January 9, 2008 Southern Nuclear Operating Company (SNC) submitted a License Amendment Request (LAR) to the NRC to revise the Vogtle Electric Generating Plant (VEGP) Technical Specifications (TS) 3.3.2, "ESFAS Instrumentation," and TS 3.5.4, "Refueling Water Storage Tank (RWST)." The proposed TS changes are required to meet commitments related to the resolution of issues identified in NRC Generic Letter (GL) 2004-02, "Potential Impact of Debris Blockage on Emergency Recirculation During Design Basis Accidents at Pressurized Water Reactors," dated September 13, 2004.

By SNC letter (NL-07-1969) to the NRC, dated December 7,2007, SNC requested an extension to the completion schedule to extend the completion of the corrective actions reqUired by Generic Letter 2004-02 for VEGP Units 1 and 2 from December 31,2007 to June 30,2008. This would allow SNC to complete downstream effects modifications for Unit 1, complete the downstream effects evaluation for both units, receive and process the screen vendors' test reports for chemical effects testing, and allow sufficient time for the NRC review and approval of this TS amendment request. As stated in the letter, the TS amendment is needed to ensure that the new RHR sump screens would be fUlly submerged in the worst case accident scenario at the initiation of cold-leg recirculation. This extension request to May 31,2008 was SUbsequently approved by the NRC in a letter dated December 19, 2007.

U. S. Nuclear Regulatory Commission NL-08-0811 Page 2 On January 28,2008, SNC received a Request for Additional Information (RAI) from the NRC regarding the January 9, 2008 submittal. SNC responded to the subject RAI by letter dated February 6, 2008 (NL-08-0143).

On February 25, 2008 a teleconference held between SNC, the NRC, and Westinghouse Electric Company LLC (Westinghouse), regarding the LAR, resulted in a request from the NRC for additional information. SNC responded to the request by letter dated March 5, 2008 (NL-08-0300).

On May 8, 2008, a teleconference held between SNC and the NRC, regarding the LAR, resulted in an additional request from the NRC for additional information. At this time, SNC is preparing a response to the NRC's request in a separate letter.

On May 20,2008, in a phone conversation between the NRR Project Manager for VEGP and the SNC VEGP Licensing Manager, the NRC requested that SNC add a new footnote to VEG P TS Table 3.3.2-1, Function 7.b regarding the implementation of the proposed new RWST Level-Low Low Nominal Trip Setpoint and Allowable Values. Addition of the new footnote to the VEGP TS will require additional time for review by the Plant Review Board and the Corporate Safety Review Board. As a result of this latest NRC request, SNC respectfully requests an extension for the implementation of the LAR from May 31,2008 to 30 days from receipt of the NRC's approval of the LAR.

The addition of the proposed footnote will not alter the conclusions of the Significant Hazards Consideration Evaluation provided with our original submittal (NL-07-1969) to the NRC, dated December 7,2007. The revised TS page will be provided to the NRC in a separate letter, along with SNC's response to the NRC's RAI from May 8, 2008.

VEGP has staged the necessary design change work involved in making the setpoint changes, contingent on receipt of NRC's approval. In addition to the design change work, draft operations, maintenance, and administrative procedures are prepared for implementation, as well as applicable personnel training. The 30-day implementation period from receipt of the NRC's approval of the LAR would provide the necessary time to ensure that the approved TS changes are implemented safely and properly.

U. S. Nuclear Regulatory Commission NL-08-0811 Page 3 Mr. D. H. Jones 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.

D. H. Jone Vice President - Engineering

~,~n~subscribed before me thitti?CS--deyof ~ I 2008.

. ~

My commission expires: $L ('1-/0 LMS/LPH/daj cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, Vice President - Vogtle Mr. L. M. Stinson, Vice President - Fleet Operations Support RType: CVC7000 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. A. Jervey, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources