NL-08-1022, Request to Revise the Unit 1 and Unit 2 Operating Licenses to Extend the Interim Period for the Use of Potassium Iodide

Request to Revise the Unit 1 and Unit 2 Operating Licenses to Extend the Interim Period for the Use of Potassium Iodide

ML081850565
Person / Time
Site:	Hatch
Issue date:	07/02/2008
From:	Gasser J Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
NL-08-1022
Download: ML081850565 (20)

Text

Jeffrey T. Gasser Southern Nuclear Executive Vice President Operating Company, Inc.

and Chief Nuclear Officer 40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.7721 Fax 205.992.6165 SOUTHERN COMPANY A

JUly 2,2008 Energy to Serve }Our"World'"

Docket Nos.: 50-321 NL-08-1022 50-366 U. S. Nuclear Regulatory Commission AnN: Document Control Desk Washington, D. C. 20555-0001 Edwin I. Hatch Nuclear Plant Request to Revise the Unit 1 and Unit 2 Operating Licenses to Extend the Interim Period for the Use of Potassium Iodide Ladies and Gentlemen:

On March 17, 2006 in accordance with the requirements of 10 CFR 50.90, Southern Nuclear Operating Company (SNC) proposed a revision the Edwin I.

Hatch Nuclear Plant (HNP) Operating Licenses DPR-57 and NPF-5 to incorporate the use of potassium iodide (KI) into the HNP licensing basis for an interim period of approximately 4 years. The initial request was documented in our letter NL-06-0271 dated March 17, 2006, and supplemental information as requested by the NRC was submitted in letter NL-06-0756 dated April 14, 2006.

In a letter dated May 25,2006 the NRC issued revised operating licenses to support the use of potassium iodide to reduce the 30-day post-accident thyroid dose to the occupants of the main control room (MCR) for an interim period of 4 years or until May 31,2010. This interim period was proposed in order to facilitate the performance of activities related to Control Room Habitability, including 1) performance of tracer gas testing of the HNP Units 1 and 2 common MCR, 2) submittal of a full scope alternative source term analysis (AST) for NRC review, 3) NRC review of the SNC AST submittal in a projected time period of 2 years or less, and 4) if needed, additional time to complete the NRC review or for SNC to initiate additional design basis changes, including potential plant modifications that may be identified as necessary. The potential need for additional NRC AST review time had also previously been raised by the NRC in a November 29,2005 meeting.

By letter dated February 25, 2008 SNC proposed to modify certain valves that form a part of the alternative leakage treatment (ALT) pathway boundary for AST to provide the capability to remotely operate those valves. The proposed implementation schedule in that submittal was May 31, 2011 for Unit 2 and May 31,2012 for Unit 1. Based on the schedule to complete the above referenced modifications for each unit of Plant Hatch, SNC hereby requests that operating license condition C (8) of DPR-57 issued for Hatch-Unit 1 be extended to May 31,2012 and that operating license condition C (3) (f) of NPF-5 issued for Hatch-Unit 2 be extended until May 31, 2011.

U. S. Nuclear Regulatory Commission NL-08-1022 Page 2 Enclosure 1 to this letter provides the description and justification for the proposed change, Enclosure 2 provides the Significant Hazards Evaluation and Environmental Assessment, Enclosure 3 provides the Regulatory Safety Analysis, Enclosure 4 provides the marked up Operating License (OL) pages, Enclosure 5 provides clean typed OL pages, and Enclosure 6 provides a list of Regulatory Commitments. Based on the foregoing, the requirements of 10 CFR 50.90 will continue to be met by this request to extend the period of interim use of potassium iodide.

SNC requests approval of the proposed request by November 14, 2008. In accordance with the requirements of 10 CFR 50.91, a copy of this letter will be sent to the designated State official of the Environmental Protection Division of the Georgia Department of Natural Resources.

Mr. J. T. Gasser states he is Executive 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.

The NRC commitments contained in this letter are provided as a table in Enclosure 6. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY 1Tfj~

J. T. Gasser Executive Vice President

. Sworn to and subscribed before me this;2-M daYOf~t1p ,2008.

p

U. S. Nuclear Regulatory Commission NL-08-1022 Page 3

Enclosures:

1. Description and Justification for Proposed Change

2. 10 CFR 50.92 Significant Hazards Evaluation and Environmental Assessment

3. Regulatory Safety Analysis

4. Marked-up Operating License Pages

5. Clean Typed Operating License Pages

6. List of Regulatory Commitments cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. R. Madison, Vice President - Hatch Mr. D. H. Jones, Vice President - Engineering RType: CHA02.004 U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. R. E. Martin, NRR Project Manager - Hatch Mr. J. A. Hickey, Senior Resident Inspector - Hatch State of Georgia Mr. N. Holcomb, Commissioner - Department of Natural Resources

Edwin I. Hatch Nuclear Plant Request to Revise the Operating Licenses to Support Use of Potassium Iodide for an Interim Period Enclosure 1 Description and Justification for Proposed Change

Enclosure 1 Description and Justification for Proposed Change Proposed Change Southern Nuclear Operating Company (SNC) requests a revision of the Edwin I. Hatch Nuclear Plant (HNP) Operating Licenses to incorporate the use of potassium iodide (KI) into the HNP licensing basis for an extended period.

Specifically, the license condition previously authorized by the NRC in a letter dated May 25,2006 will be extended in sections 2.C of the HNP Units 1 and 2 Operating Licenses. This revised license condition will authorize SNC to credit administering KI to reduce the 30 day post-accident thyroid radiological dose to the operators in the main control room (MCR) for an extended period of time for Hatch Unit 1 until May 31,2012 and for Hatch Unit 2 until May 31,2011.

Background

Credit for KI in the DBA radiological consequences analyses was initially requested, and subsequently authorized as noted above, to address the potential impact of MCR unfiltered inleakage utilizing ASTM E741 tracer gas testing to determine actual MCR unfiltered inleakage as requested by NRC Generic Letter (GL) 2003-01, "Control Room Habitability." Consistent with 10 CFR 20.1702 and NRC IN 88-15, the interim crediting of KI allows time for the implementation of appropriate design basis changes to address the impact of MCR unfiltered inleakage. These design basis changes include the full scope implementation of an alternative source term (AST) following NRC approval, in accordance with the requirements of 10 CFR 50.90 and 10 CFR 50.67.

The HNP current licensing basis (CLB) MCR unfiltered inleakage is 110 cfm based on having a pressurized control room, with reliance on KI. The HNP Units 1 and 2 common MCR has a unique location. The MCR, as part of the control building, is located between the open end bays of the HNP Units 1 and 2 turbine buildings. The majority of the ductwork associated with the Main Control Room Environmental Control System, which encompasses two independent filter trains for pressurizing the control room post-accident, is located external to the control room boundary on top of the control building within the confines of the HNP Unit 1 and 2 turbine bUildings. Consequently, only minimal MCR unfiltered inleakage can be justified without the use of KI or self-contained breathing apparatus (SCBA).

The addition of a new license condition to sections 2.C of the HNP Units 1 and 2 Operating Licenses was proposed to assure that KI credit was limited to a defined interim period. SNC initially proposed that the interim period be defined as approximately 4 years, with the license condition including a specific end date for crediting KI of May 31, 2010. This period of time would allow for: 1) tracer gas testing of the HNP Units 1 and 2 common MCR, 2) submittal of AST for NRC review, 3) NRC review of the SNC AST submittal in a projected time period of 2 years or less, and 4) if needed, additional time to complete the NRC review or for SNC to initiate additional design basis changes, including potential plant modi'fications that may be identified as necessary. The potential need for additional NRC AST review time was raised by the NRC in a November 29, 2005 meeting.

Since that time, significant resources and effort has been expended by both NRC and SNC towards approval of AST. As a result of these reviews, new modifications have recently been identified and SNC has concluded that the recently identified modifications for AST can not be completed by May 31, 2010.

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Enclosure 1 Description and Justification for Proposed Change Justification of Extended Use of KI Based on this background, SNC is proposing to credit KI in the DBA radiological consequences analyses to address the impact of MCR unfiltered inleakage for an extended interim period prior to full scope implementation of AST and/or other design basis changes determined to be necessary.

As part of the ongoing review of the HNP AST submittal, it was identified by SNC letter dated February 25, 2008 that modifications would be required to certain alternative leakage treatment (ALT) path boundary valves in order to provide the capability to remotely position the valves to their required post-accident position. The letter identified that the proposed modifications could not be implemented until May 31,2012.

Specifically, the proposed implementation would occur by May 31, 2011 for Unit 2 and May 31, 2012 for Unit 1. The extension of time that SNC is authorized to credit administering KI to reduce the 30 day post-accident thyroid radiological dose to the operators in the MCR is tied to the boundary valve modification implementation dates, specifically for Hatch Unit 1 until May 31,2012 and for Hatch Unit 2 until May 31,2011.

A walk down of the Unit 1 valve locations was performed during the 2008 Unit 1 refueling outage in order to obtain information for the detailed engineering design packages required to implement the modifications. The subject valves are located in an area of the plant that is normally inaccessible during power operation. Since both Hatch units operate on 2-year operating cycles, the first opportunity to walk down the Unit 2 configuration will be during the spring 2009 refueling outage. This results in an implementation date of 2011 for Unit 2. Some of the valves being modified are critical to power operation, so both normal operating and post-accident operating modes are fully addressed in the detailed design packages to be issued for implementation. At this time, the Unit 1 design package has not been finalized and has not yet undergone the reviews that will be needed to assure safe and effective implementation of the modifications. The availability of components for the final design package has not been determined. Based on the current status, SNC is proposing that the Unit 1 implementation be scheduled for the spring 2012 refueling outage. If the opportunity develops to bring the modifications forward to the 2010 refueling outage, SNC will take advantage of that opportunity to complete the modifications at the earlier date. However, in order to avoid additional schedular issues related to cessation of reliance on KI, SNC is requesting a license condition date of May 31, 2012 for Unit 1.

The effectiveness of KI in blocking the uptake of radioiodine by the thyroid is well documented and use of KI on an interim basis is acceptable as stated in NRC and industry documents, including 10 CFR 20.1702, NRC IN 88-15, regulatory position 2.7.3 of Regulatory Guide (RG) 1.196, titled "Control Room Habitability at Light-Water Nuclear Power Reactors," and AppendiX F of NEI 99-03 revision 0, titled "Control Room Habitability Guidance."

The proposed extended implementation of KI will comply with RG 1.196 regulatory position 2.7.3 guidance. SNC personnel who might need to use KI are screened for possible allergic reactions to iodine and are on an approved list. Adequate supplies of KI are stored in the MCR and administration of KI is procedurally controlled. Specifically, in response to a DBA and consistent with the Emergency Plan and emergency implementing E1 - 2

Enclosure 1 Description and Justification for Proposed Change procedures, the Emergency Director determines if radiological conditions in the MCR warrant issuance of KI to MCR personnel to assure the 30 day thyroid dose remains in compliance with regulatory limits of 10 CFR 50 Appendix A General Design Criterion (GDC) 19. For clarity it is noted that, because of the common control room for HNP Units 1 and 2, should a loss-of-coolant accident (LOCA) occur on either unit crediting KI, KI would be issued to any MCR personnel associated with both HNP Units 1 and 2 operation.

In addition, SNC has worded the license condition to include a sunset clause that commits to removing the crediting of KI from the DBA radiological analyses prior to May 31,2012 should design basis changes be completed earlier that render the crediting of KI no longer necessary.

Review of Incorporation of KI into the DBA Radiological Consequences Analyses The radiological consequences analyses remain as described in the enclosure to SNC's March 17,2006 submittal to incorporate license conditions providing for crediting of KI for the original interim period through May 31, 2010.

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Edwin I. Hatch Nuclear Plant Request to Revise the Operating Licenses to Support Use of Potassium Iodide for an Interim Period Enclosure 2 10 CFR 50.92 Significant Hazards Evaluation and Environmental Assessment

Enclosure 2 10 CFR 50.92 Significant Hazards Evaluation and Environmental Assessment Proposed Change Southern Nuclear Operating Company (SNC) requests a revision of the Edwin I. Hatch Nuclear Plant (HNP) Operating Licenses to incorporate the use of potassium iodide (KI) into the HNP licensing basis for an extended period of time.

Specifically, an extension is proposed to the license condition previously added to sections 2.C of the HNP Units 1 and 2 Operating Licenses. This license condition will authorize SNC to credit administering KI to reduce the 30 day post-accident thyroid radiological dose to the operators in the main control room (MCR) for an extended period of an additional 2 years. The extended period is approximately 2 years longer than previously granted by the NRC in a letter of May 25,2006. Specifically, for Hatch- Unit 1 the period would expire on May 31,2012 and for Unit 2 the period would expire May 31, 2011.

10 CFR 50.92 Evaluation In 10 CFR 50.92(c) the Nuclear Regulatory Commission (NRC) provides the following standards to be used in determining the existence of a significant hazards consideration:

"...a proposed amendment to an operating license for a facility licensed under 50.21 (b) or 50.22, or for a testing facility involves no significant hazards consideration, if operation of the facility in accordance with the proposed amendment would not: (1) Involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of a new or different kind of accident from any accident previously evaluated; or (3)

Involve a significant reduction in the margin of safety."

SNC has reviewed the proposed amendment request and determined that its adoption does not involve a significant hazards consideration based upon the following discussion:

1. Does the proposed change involve a significant increase in the probability or consequences of an accident previously evaluated?

This proposed change will authorize SNC to credit KI for an extended period in the DBA radiological consequences analyses to address the impact of MCR unfiltered inleakage. This proposed change does not result in any functional or operational change to any systems, structures, or components and has no impact on any assumed initiator of any analyzed accident. Therefore, the proposed change does not result in an increase in the probability of an accident previously evaluated.

This proposed change does not introduce any additional method of mitigating the thyroid dose to MCR occupants in the event of a loss-of-coolant accident (LOCA) since the existing license condition has already introduced this method as part of the licensing basis for an interim period of time. The updated LOCA MCR radiological dose, considering 110 ctm unfiltered inleakage and crediting KI, continues to meet GOC 19 acceptance limits. In the context of the current licensing basis with MCR unfiltered inleakage considered, LOCA continues to be the limiting event for radiological exposures to the operators in the MCR. Radiological doses to MCR occupants are within the regulatory limits of GOC 19 with MCR unfiltered inleakage up E2 - 1

Enclosure 2 10 CFR 50.92 Significant Hazards Evaluation and Environmental Assessment to 1000 cfm without the crediting of KI for the main steam line break accident (MSLB),

control rod drop accident (CRDA), and fuel handling accident (FHA). Therefore, the proposed change does not result in a significant increase in the consequences of an accident previously evaluated.

2. Does the proposed change create the possibility of a new or different kind of accident from any previously evaluated?

This proposed change will authorize SNC to credit KI for an extended period in the DBA radiological consequences analyses to address the impact of MCR unfiltered inleakage. This proposed change does not result in any functional or operational change to any systems, structures, or components. Therefore, the proposed change does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed change involve a significant decrease in the margin of safety?

This proposed change will authorize SNC to credit KI for an extended period in the DBA radiological consequences analyses to address the impact of MCR unfiltered inleakage. This proposed change does not result in any functional or operational change to any systems, structures, or components. This proposed change extends the use of an additional method of mitigating the thyroid dose to MCR occupants in the event of a LOCA until May 31, 2012. The updated LOCA MCR radiological dose, considering 110 cfm unfiltered inleakage and crediting KI, continues to meet GDC 19 acceptance limits. In the context of the current licensing basis with MCR unfiltered inleakage considered, LOCA continues to be the limiting event for radiological exposures to the operators in the MCR. Radiological doses to MCR occupants are within the regulatory limits of GDC 19 with MCR unfiltered inleakage of up to 1000 cfm without the crediting of KI for the main steam line break accident (MSLB), control rod drop accident (CRDA), and fuel handling accident (FHA). Therefore, the proposed change does not involve a significant decrease in the margin of safety.

Environmental Assessment SNC has evaluated the proposed changes and determined the changes do not involve (1) a significant hazards consideration, (2) a significant change in the types or significant increase in the amounts of any effluents that may be released offsite, or (3) a significant increase in the individual or cumulative occupational exposure. Accordingly, the proposed changes meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9), and an environmental assessment of the proposed changes is not required.

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Edwin I. Hatch Nuclear Plant Request to Revise the Operating Licenses to Support Use of Potassium Iodide for an Interim Period Enclosure 3 Regulatory Safety Analysis

Enclosure 3 Regulatory Safety Analysis Southern Nuclear Operating Company (SNC) requests a revision of the Edwin I. Hatch Nuclear Plant (HNP) Operating Licenses to extend the allowed usage of potassium iodide (KI) into the HNP licensing basis for an additional time period.

Specifically, a license condition revision is proposed to that previously authorized to sections 2.C of the HNP Units 1 and 2 Operating Licenses. This revised license condition will authorize SNC to credit administering KI to reduce the 30 day post-accident thyroid radiological dose to the operators in the main control room (MCR) for an extended period of approximately 2 years. The extended period is approximately 2 years longer than previously granted by the NRC in a letter of May 25,2006. Specifically, for Hatch- Unit 1 the period would expire on May 31,2012 and for Unit 2 the period would expire May 31, 2011.

Therefore, the proposed change of incorporating the use of KI into the HNP licensing basis for an interim period complies with the applicable regulatory requirements and guidance. In addition, it should be noted that the proposed change does not result in any functional or operational change to any HNP systems, structures, or components.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

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Edwin I. Hatch Nuclear Plant Request to Revise the Operating Licenses to Support Use of Potassium Iodide for an Interim Period Enclosure 4 Marked-Up Operating License Pages

- 6 program attribute not covered by the plant-specific surveillance material testing program. The plant-specific program, if needed, will include the following actions:

(a) Capsules will periodically be removed to determine the rate of embrittlement.

(b) Capsules will be removed at neutron fluence levels that provide relevant data for assessing the integrity of the Plant Hatch, Unit 1 reactor pressure vessel (in particular, for the determination of reactor pressure vessel pressure-temperature limits through the period of extended operation).

(c) Capsules will contain material to monitor the impact of irradiation on the Plant Hatch Unit 1 reactor pressure vessel and will contain dosimetry to monitor neutron fluence.

Before the renewal term begins, the licensee will notify the NRC of its decision to implement the integrated surveillance program or a plant s ecific program, and provide the appropriate revisions to the Updated Final S t Analysis Report Supplement summary descriptions of the f--_ _.....vessel surve' nce material testing program.

2012 Southern lear is authorize 0 credit administering potassium iodide to reduce the 30 post-accident t oid radiological dose to the operators in the main control m until Ma 31, . Should desi n basis changes be com~leted .

Inecess rYl prior to May 31, , Southern Nuclear will remove the crediting of potassium iodide from the design basis accident radiological consequences analyses (reference Unit 2 FSA~Jda~~raPh 15.3.3.4.2.2) in the next Updated Final Safety Analysis Report as required by 10 CFR 50.71 (e).

D. Southern Nuclear shall not market or broker power or energy from Edwin I. Hatch Nuclear Plant, Unit 1.

3. This renewed license is effective as of the date of issuance and shall expire at midnight, August 6, 2034.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

Appendix A - Technical Specifications Appendix B - Environmental Protection Plan Date of Issuance: January 15, 2002 Renewed License No. DPR-57 Amendment No. ~

-6 Boiling Water Reactor Vessel Internals Project program or through a staff-approved plant-specific program. The plant-specific program, if needed, will be developed in a manner consistent with other aging management programs, will include consideration of the 10 program attributes utilized for other aging management programs, and will provide a technical justification for any program attribute not covered by the plant-specific surveillance material testing program. The plant specific program, if needed, will include the following actions:

I. Capsules will periodically be removed to determine the rate of embrittlement.

ii. Capsules will be removed at neutron fluence levels that provide relevant data for assessing the integrity of the Plant Hatch Unit 2 reactor pressure vessel (in particular, for the determination of reactor pressure vessel pressure temperature limits through the period of extended operation).

iii. Capsules will contain material to monitor the impact of irradiation on the Plant Hatch Unit 2 reactor pressure vessel and will contain dosimetry to monitor neutron fluence.

Before the renewal term begins, the licensee will notify the NRC of its decision to implement the integrated surveillance program or a plant-specific 2011 1---""""I"nr"!"V1ram, and provide the appropriate revisions to the Updated Final Safety L...- -' Analy* Report Supplement summary descriptions of the vessel surveillance material te* program.

(f) 2011 Southern Nuclear is authon to credit administering potassium iodide to reduce the 30 day post-acciden roid radiological dose to the operators in th in control room until Ma 31, . Should desi n basis chan es be complet~~~~~~~~~~~~~~~~~~~~~~~§§;~*

prior to May 3 , , Southern Nuclear will remove the crediting of potassium iodide from the design basis accident radiological consequences analyses (reference Unit 2 FSAR para~ 5.3.3.4.2.2) in the next Updated Final Safety Analysis Report ~ as required by 10 CFR 50.71 (e).

D. This renewed license is subject to the following antitrust conditions:

(1) As used herein:

a. "Entity" means any financially responsible person, private or public corporation, municipality, county, cooperative, association, joint stock association or business trust, owning, operating or proposing to own or operate equipment or facilities within the state of Georgia (other than Chatham, Effingham, Fannin, Towns and Union Counties) for Renewed License No. NPF-5 Amendment No. ~

Edwin I. Hatch Nuclear Plant Request to Revise the Operating Licenses to Support Use of Potassium Iodide for an Interim Period Enclosure 5 Clean Typed Operating License Pages

- 6 program attribute not covered by the plant-specific surveillance material testing program. The plant-specific program, if needed, will include the following actions:

(a) Capsules will periodically be removed to determine the rate of embrittlement.

(b) Capsules will be removed at neutron fluence levels that provide relevant data for assessing the integrity of the Plant Hatch, Unit 1 reactor pressure vessel (in particular, for the determination of reactor pressure vessel pressure-temperature limits through the period of extended operation).

(c) Capsules will contain material to monitor the impact of irradiation on the Plant Hatch Unit 1 reactor pressure vessel and will contain dosimetry to monitor neutron fluence.

Before the renewal term begins, the licensee will notify the NRC of its decision to implement the integrated surveillance program or a plant specific program, and provide the appropriate revisions to the Updated Final Safety Analysis Report Supplement summary descriptions of the vessel surveillance material testing program.

(8) Design Bases Accident Radiological Consequences Analyses Southern Nuclear is authorized to credit administering potassium iodide to reduce the 30 day post-accident thyroid radiological dose to the operators in the main control room until May 31,2012. Should design basis changes be completed prior to May 31, 2012, Southern Nuclear will remove the I

crediting of potassium iodide from the design basis accident radiological consequences analyses (reference Unit 2 FSAR paragraph 15.3.3.4.2.2) in the next Updated Final Safety Analysis Report as required by I 10 CFR 50.71 (e).

D. Southern Nuclear shall not market or broker power or energy from Edwin I. Hatch Nuclear Plant, Unit 1.

3. This renewed license is effective as of the date of issuance and shall expire at midnight, August 6, 2034.

FOR THE U.S. NUCLEAR REGULATORY COMMISSION Samuel J. Collins, Director Office of Nuclear Reactor Regulation Attachments:

Appendix A - Technical Specifications Appendix B - Environmental Protection Plan Date of Issuance: January 15, 2002 Renewed License No. OPR-57 Amendment No.

-6 Boiling Water Reactor Vessel Internals Project program or through a staff-approved plant-specific program. The plant-specific program, if needed, will be developed in a manner consistent with other aging management programs, will include consideration of the 10 program attributes utilized for other aging management programs, and will provide a technical justification for any program attribute not covered by the plant-specific surveillance material testing program. The plant specific program, if needed, will include the following actions:

i. Capsules will periodically be removed to determine the rate of embrittlement.

ii. Capsules will be removed at neutron fluence levels that provide relevant data for assessing the integrity of the Plant Hatch Unit 2 reactor pressure vessel (in particular, for the determination of reactor pressure vessel pressure temperature limits through the period of extended operation).

iii. Capsules will contain material to monitor the impact of irradiation on the Plant Hatch Unit 2 reactor pressure vessel and will contain dosimetry to monitor neutron fluence.

Before the renewal term begins, the licensee will notify the NRC of its decision to implement the integrated surveillance program or a plant-specific program, and provide the appropriate revisions to the Updated Final Safety Analysis Report Supplement summary descriptions of the vessel surveillance material testing program.

(f) Design Bases Accident Radiological Conseguences Analyses Southern Nuclear is authorized to credit administering potassium iodide to reduce the 30 day post-accident thyroid radiological dose to the operators in the main control room until May 31, 2011. Should design basis changes be completed prior to May 31, 2011, Southern Nuclear will remove the crediting I

of potassium iodide from the design basis accident radiological consequences analyses (reference Unit 2 FSAR paragraph 15.3.3.4.2.2) in the next Updated Final Safety Analysis Report as reqUired by 10 CFR 50.71 (e).

D. This renewed license is subject to the following antitrust conditions:

(1) As used herein:

a. "Entity" means any financially responsible person, private or public corporation, municipality, county, cooperative, association, joint stock association or business trust, owning, operating or proposing to own or operate equipment or facilities within the state of Georgia (other than Chatham, Effingham, Fannin, Towns and Union Counties) for Renewed License No. NPF-5 Amendment No.

Edwin I. Hatch Nuclear Plant Request to Revise the Operating Licenses to Support Use of Potassium Iodide for an Interim Period Enclosure 6 List of Regulatory Commitments

Enclosure 6 List of Regulatory Commitments The following table identifies those actions committed by Southern Nuclear Operating Company (SNC) in this document for the Edwin I. Hatch Nuclear Plant.

Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

SCHEDULED TYPE COMPLETION One-Time Continuing DATE COMMITMENT Action Compliance (If Required)

SNC will end the crediting of potassium iodide to reduce the 30 day post-accident thyroid X May 31,2012 radiological dose to the main control room operators.

Should design basis changes be completed rendering the crediting of potassium iodide no longer necessary prior to May 31,2012, SNC will remove the crediting of potassium iodide from the design basis accident X N/A radiological consequences analyses in the next Updated Final Safety Analysis Report update as required by 10 CFR 50.71 (e).

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