ML080950108
| ML080950108 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 04/03/2008 |
| From: | Tynan T E Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-08-0522 | |
| Download: ML080950108 (7) | |
Text
Tom Tynan Southern Nuclear Vice President Vogtle Operating Company, Inc. 7821 River Road Waynesboro, Georgia 30830 Tel 706 8263151 Fax 706 826 3321 April 3, 2008 SOUTHERN'\
COMPANY Energy to Serve Your World " Docket Nos.: 50-424 NL-08-0522 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Supplemental Information Related to License Amendment Request for Interim Alternate Repair Criterion to Technical Specification "Steam Generator (SG)
Ladies and Gentlemen:
On February 13, 2008, Southern Nuclear Operating Company (SNC) submitted an application to revise Vogtle Electric Generating Plant (VEGP) Technical Specification (TS) 5.5.9, "Steam Generator (SG) Program" and TS 5.6.10, "Steam Generator Tube Inspection Report," to propose a one cycle revision to incorporate an interim alternate repair criterion (ARC) in the provisions for SG tube repair criteria during Refueling Outages 1 R14 (Unit 1) and 2R13 (Unit 2) and the subsequent operating cycles for each unit. On February 8, 2008, Wolf Creek Nuclear Operating Company (WCNOC) submitted a similar application to revise TS 5.5.9 and TS 5.6.10 to incorporate an interim ARC, and on February 20, 2008, the Nuclear Regulatory Commission (NRC) provided, by electronic mail, issues and comments related to the WCNOC amendment application.
A teleconference was held with representatives from SNC, WCNOC, Exelon Generation Company, NRC and other industry representatives on February 21, 2008, to discuss the issues and comments related to the WCNDC submittal.
Subsequent to this teleconference, the NRC provided WCNDC a request for additional information (RAI) letter by electronic mail on February 28, 2008 that contained thirteen (13) questions.
On March 10 and 18,2008, subsequent to the WCNOC RAlletter, the NRC provided SNC RAI letters containing seventeen (17) questions by electronic mail regarding the SNC February 13, 2008 amendment application for VEGP. On March 21, 2008, SNC provided a response to the seventeen (17) questions contained in the NRC RAI letters. Regarding question 13, the SNC response, as well as the WCNDC response, indicated that an administrative limit would be established to not exceed the calculated steam line break leakage value. On March 26,2008, SNC was informed by a telephone call from the VEGP NRC Project Manager that, during a teleconference with WCNDC and the WCNOC NRC Project Manager, it was identified that a regulatory commitment was U. S. Nuclear Regulatory Commission NL-08-0522 Page 2 required for this administrative limit since the NRC safety evaluation for the requested amendment was relying on the use of a constant multiplier of 2.5 to calculate a steam line break administrative limit. Enclosure 1 provides additional details. In addition, as a result of the subsequent discussions with the NRC and Wolf Creek personnel, SNC will not require the interim ARC for 2R13 (Unit 2) and the subsequent operating cycle as previously submitted in the February 13, 2008 application.
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. The additional information provided in the Enclosures does not impact the conclusions of the No Significant Hazards Consideration provided in Reference 1 of Enclosure
- 1. The NRC commitment contained in this letter is provided as a table in Enclosure
- 2. If you have any questions, please advise. Respectfully submitted, SOUTHERN NUCLEAR OPERATING COMPANY T.
.: ,.'..* , t}'"TA : "..:.... -.' . '. Vice President
-Vogtle ':,.'(" ***...7..:. ***** .:
Sworn to and subscribed before me this day of ,2008.
c/Jjvr; JJ.
Notary Public, Burke county,
... C mmission expires January 13, My commission expires: IV_,Y_O _ TET/DRG/daj
Enclosures:
Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion
- 2. List of Regulatory Commitments U. S. Nuclear Regulatory Commission NL-08-0522
Page 3 cc: Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. D. H. Jones, Vice President - Engineering RType: CVC7000
U. S. Nuclear Regulatory Commission Mr. V. M. McCree, Acting Regional Administrator Mr. S. P. Lingam, 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 Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion to Technical Specification 5.5.9, "Steam Generator (SG) Program" Enclosure 1 Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion
Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion E1-1 On February 13, 2008 Southern Nuclear Operating Company (SNC) submitted an application to revise Vogtle Electric Generating Plant (VEGP) Technical Specification (TS) 5.5.9, "Steam Generator (SG) Program" and TS 5.6.10, "Steam Generator Tube Inspection Report," to propose a one cycle revision to incorporate an interim alternate repair criterion (ARC) in the provisions for SG tube repair criteria during Refueling Outages 1R14 (Unit 1) and 2R13 (Unit 2) and the subsequent operating cycles for each unit (Reference 1).
On March 10 and 18, 2008 the Nuclear Regulatory Commission (NRC) provided SNC request for additional information (RAI) letters containing seventeen (17) questions by electronic mail regarding the SNC February 13, 2008 amendment application for VEGP. On March 21, 2008 SNC provided a response to seventeen (17) questions contained in the NRC RAI letters (Reference 2).
In the response to question 13 in Reference 2, SNC indicated that an administrative limit would be established to not exceed the calculated steam line break leakage value. On March 26, 2008 SNC was informed by a telephone call from the VEGP NRC Project Manager that during a teleconference with Wolf Creek Nuclear Operating Corporation's (WCNOC) and the WCNOC NRC Project Manager, it was identified that a regulatory commitment was required for this administrative limit since the NRC safety evaluation for the requested amendment was relying on the use of a constant multiplier of 2.5 to calculate a steam line break administrative limit.
Specifically, the response to question 13 stated, in part:
For integrity assessments, the ratio of 2.5 will be used in the completion of both the condition monitoring (CM) and operational assessment (OA) upon implementation of the IARC. For example, for the CM assessment, the component of leakage from the lower 4 inches for the most limiting steam generator during the prior cycle of operation will be multiplied by a factor of 2.5 and added to the total leakage from any other source and compared to the allowable accident analysis leakage assumption. For the OA, the difference in leakage from the allowable limit during the limiting design basis accident minus the leakage from the other sources will be divided by 2.5 and compared to the observed leakage. An administrative limit will be established to not exceed the calculated value.
As such, SNC considers the above to be a regulatory commitment.
In addition, as a result of the subsequent discussions with the NRC and Wolf Creek personnel, SNC will not require the interim ARC for 2R13 (Unit 2) and the subsequent operating cycle as previously submitted in the February 13, 2008 application.
References:
- 1. SNC letter NL-08-0148, "License Amendment Request to Revise Technical Specification (TS) Sections 5.5.9, "Steam Generator (SG) Program" and TS 5.6.10, "Steam Generator Tube Inspection Report" for Interim Alternate Repair Criterion," February 13, 2008.
- 2. SNC letter NL-08-0343, "Response to Request for Additional Information Related to License Amendment Request for an Interim Alternate Repair Criterion to Technical Specification 5.5.9, "Steam Generator (SG) Program"," March 21, 2008.
Vogtle Electric Generating Plant Supplemental Information Related to License Amendment Request for an Interim Alternate Repair Criterion to Technical Specification 5.5.9, "Steam Generator (SG) Program" Enclosure 2 List of Regulatory Commitments List of Regulatory Commitments E2-1 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.
Commitment Due Date/Event For VEGP Unit 1 Only: For integrity assessments, the ratio of 2.5 will be used in the completion of both the condition monitoring (CM) and operational assessment (OA) upon implementation of the IARC. For example, for the CM assessment, the component of leakage from the lower 4 inches for the most limiting steam generator during the prior cycle of operation will be multiplied by a factor of 2.5 and added to the total leakage from any other source and compared to the allowable accident analysis leakage assumption. For the OA, the difference in leakage from the allowable limit during the limiting design basis accident minus the leakage from the other sources will be divided by 2.5 and compared to the observed leakage. An administrative limit will be established to not exceed the calculated value.
Completion of CM and OA