NL-08-1195, Generic Letter 2004-02 Response Extension Request

Generic Letter 2004-02 Response Extension Request

ML082170306
Person / Time
Site:	Vogtle
Issue date:	07/31/2008
From:	Ajluni M Southern Nuclear Operating Co
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
GL-04-002, GSI-191, NL-08-1195, WCAP-16793-NP
Download: ML082170306 (5)

Text

Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.5776 Fax 205.992.5363 July 31, 2008 SOUTHERNAM COMPANY Energy to Serve Your WorldSM Docket Nos.: 50-424 NL-08-1195 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Ladies and Gentlemen:

By letter dated May 22, 2008, (NL-08-0818) Southern Nuclear Operating Company (SNC) requested an extension for the final response to Generic Letter 2004-02 for the completion of:

• Downstream effects evaluations in accordance with WCAP-1 6406-P Rev.

1, "Evaluation of Downstream Sump Debris Effects in Support of GSI-191" and WCAP-16793-NP, "Evaluation of Long-Term Cooling Considering Particulate, Fibrous and Chemical Debris in the Recirculating Fluid."

" Completion of chemical effects testing and evaluation of test results.

An extension was granted by the NRC to July 31, 2008, in a letter dated May 29, 2008.

In May 2008 the sump screen vendor, General Electric Hitachi, expected to receive the final Chemical Effects Testing (CE) Summary Report from our 3rd party vendor (Alion) on June 24, 2008. GEH was to incorporate the results and provide the final Hydraulic Sizing Report to SNC by July 11, 2008. GEH did not receive the final CE Summary Report until July 25, 2008 causing a delay in issuance of the Vogtle S100 Report. The CE Summary report was delayed for the following reasons:

- The original test results for the 8D fiber case produced non-conclusive results.

Alion and GEH took additional time to work though an acceptable solution using the second test results.

-Alion worked with SNC and other utilities involved in VUEZ testing to address NRC questions regarding VUEZ Testing during preparation of the Vogtle CE Summary report. Additional effort was provided to consider these issues in the report.

U. S. Nuclear Regulatory Commission NL-08-1195 Page 2

- Alion received an NRC visit and a NUPIC audit during this time frame. In house visitors consumed more resources than anticipated.

- The test report from the VUEZ test facility, which is used as a basis for the CE Summary Report, was delayed due to several jobs at the test facility competing for resources. The CE Summary Report was provided to GEH on July 25, 2008.

GEH will expedite incorporation of the results and is expected to issue their final S100 report to SNC by Aug 2, 2008.

A review of the CE report and SNC calculations indicates margin exists. SNC has reasonable assurance that positive margin is maintained throughout the anticipated sump temperature range. Preliminary numbers indicate a minimum of approximately 7.5 feet of margin. This conclusion will be incorporated into our final design documentation as appropriate once the final S100 report is received.

The bases for the previous extension requests, letters dated December 7, 2007 (NL-07-1969) and May 22, 2008, (NL-08-0818) remain valid and SNC has reasonable assurance that the new VEGP sump screens will perform their design basis function under the original design bases considerations. This extension request will allow SNC to complete the documentation updates required to support the GL/GSI-1 91 considerations.

It is anticipated that with the above deliverable schedule, an extension request until August 2 9 th is needed to perform a review of the final S100 report and incorporate the results into our design documentation. Therefore, SNC is requesting an extension of the final submittal for GL 2004-02 to August 29, 2008 based on the above schedule of vendor and in-house deliverables. These matters were discussed with members of your staff on July 28, 2008.

Mr. M. J. Ajluni states he is Nuclear Licensing Manager for Southern Nuclear Operating Company and 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 the Enclosure. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Mark J. Ajluni Manager-Nuclear Licensing

U. S. Nuclear Regulatory Commission NL-08-1195 Page 3 Sworn to and subscribedbefore me this 3L day of 3u / 1,2008.

Notary Public My commission expires: / /

MJA/DWM/cag

Enclosures:

cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, Vice President - Vogtle Mr. D. H. Jones, Vice President - Engineering 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

Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Enclosure List of Regulatory Commitments

Enclosure List of Regulatory Commitments The following table identifies those actions committed by Southern Nuclear Operating Company in this document for Vogtle Electric Generating Plant. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Regulatory Commitments Due Date / Event VEGP Units 1 and 2 will be in compliance with the regulatory requirements listed in the Applicable August 29, 2008 Regulatory Requirements section of GL 2004-02.

Text

Southern Nuclear Operating Company, Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Tel 205.992.5776 Fax 205.992.5363 July 31, 2008 SOUTHERNAM COMPANY Energy to Serve Your WorldSM Docket Nos.: 50-424 NL-08-1195 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Ladies and Gentlemen:

By letter dated May 22, 2008, (NL-08-0818) Southern Nuclear Operating Company (SNC) requested an extension for the final response to Generic Letter 2004-02 for the completion of:

• Downstream effects evaluations in accordance with WCAP-1 6406-P Rev.

1, "Evaluation of Downstream Sump Debris Effects in Support of GSI-191" and WCAP-16793-NP, "Evaluation of Long-Term Cooling Considering Particulate, Fibrous and Chemical Debris in the Recirculating Fluid."

" Completion of chemical effects testing and evaluation of test results.

An extension was granted by the NRC to July 31, 2008, in a letter dated May 29, 2008.

In May 2008 the sump screen vendor, General Electric Hitachi, expected to receive the final Chemical Effects Testing (CE) Summary Report from our 3rd party vendor (Alion) on June 24, 2008. GEH was to incorporate the results and provide the final Hydraulic Sizing Report to SNC by July 11, 2008. GEH did not receive the final CE Summary Report until July 25, 2008 causing a delay in issuance of the Vogtle S100 Report. The CE Summary report was delayed for the following reasons:

- The original test results for the 8D fiber case produced non-conclusive results.

Alion and GEH took additional time to work though an acceptable solution using the second test results.

-Alion worked with SNC and other utilities involved in VUEZ testing to address NRC questions regarding VUEZ Testing during preparation of the Vogtle CE Summary report. Additional effort was provided to consider these issues in the report.

U. S. Nuclear Regulatory Commission NL-08-1195 Page 2

- Alion received an NRC visit and a NUPIC audit during this time frame. In house visitors consumed more resources than anticipated.

- The test report from the VUEZ test facility, which is used as a basis for the CE Summary Report, was delayed due to several jobs at the test facility competing for resources. The CE Summary Report was provided to GEH on July 25, 2008.

GEH will expedite incorporation of the results and is expected to issue their final S100 report to SNC by Aug 2, 2008.

A review of the CE report and SNC calculations indicates margin exists. SNC has reasonable assurance that positive margin is maintained throughout the anticipated sump temperature range. Preliminary numbers indicate a minimum of approximately 7.5 feet of margin. This conclusion will be incorporated into our final design documentation as appropriate once the final S100 report is received.

The bases for the previous extension requests, letters dated December 7, 2007 (NL-07-1969) and May 22, 2008, (NL-08-0818) remain valid and SNC has reasonable assurance that the new VEGP sump screens will perform their design basis function under the original design bases considerations. This extension request will allow SNC to complete the documentation updates required to support the GL/GSI-1 91 considerations.

It is anticipated that with the above deliverable schedule, an extension request until August 2 9 th is needed to perform a review of the final S100 report and incorporate the results into our design documentation. Therefore, SNC is requesting an extension of the final submittal for GL 2004-02 to August 29, 2008 based on the above schedule of vendor and in-house deliverables. These matters were discussed with members of your staff on July 28, 2008.

Mr. M. J. Ajluni states he is Nuclear Licensing Manager for Southern Nuclear Operating Company and 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 the Enclosure. If you have any questions, please advise.

Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY Mark J. Ajluni Manager-Nuclear Licensing

U. S. Nuclear Regulatory Commission NL-08-1195 Page 3 Sworn to and subscribedbefore me this 3L day of 3u / 1,2008.

Notary Public My commission expires: / /

MJA/DWM/cag

Enclosures:

cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, Vice President - Vogtle Mr. D. H. Jones, Vice President - Engineering 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

Vogtle Electric Generating Plant Generic Letter 2004-02 Response Extension Request Enclosure List of Regulatory Commitments

Enclosure List of Regulatory Commitments The following table identifies those actions committed by Southern Nuclear Operating Company in this document for Vogtle Electric Generating Plant. Any other statements in this submittal are provided for information purposes and are not considered to be regulatory commitments.

Regulatory Commitments Due Date / Event VEGP Units 1 and 2 will be in compliance with the regulatory requirements listed in the Applicable August 29, 2008 Regulatory Requirements section of GL 2004-02.