2009/07/17 Vogtle COL Review - FW: OI responses submitted ...ND-09-1092 BLN-SER-OI-Ch14 Response.pdf...

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PMVogtleCOLPEm Resource

From: Sebrosky, JosephSent: Friday, July 17, 2009 10:36 AMTo: Joshi, RavindraCc: VogtleCOL ResourceSubject: FW: OI responses submitted 7/16/09Attachments: ND-09-1090 BLN-SER-OI-Ch12 Response.pdf; ND-09-1092 BLN-SER-OI-Ch14

Response.pdf; ND-09-1089 BLN SER-OI-Ch10 Response.pdf; ND-09-1113 BLN-SER-OI-Ch19 Response.pdf

Ravi, For your information - joe -----Original Message----- From: Aughtman, Amy G. [mailto:[email protected]] Sent: Friday, July 17, 2009 9:25 AM To: Sebrosky, Joseph Cc: Sparkman, Wesley A. Subject: OI responses submitted 7/16/09 <<ND-09-1090 BLN-SER-OI-Ch12 Response.pdf>> Jo <<ND-09-1092 BLN-SER-OI-Ch14 Response.pdf>> e, <<ND-09-1089 BLN SER-OI-Ch10 Response.pdf>> <<ND-09-1113 BLN-SER-OI-Ch19 Response.pdf>> Since you are acting for Ravi, wanted to make sure someone was aware we submitted the following OI responses yesterday. Ravi was copied I believe, but we do not have you on our standard distribution. We hope to get 1 or 2 more (Ch 16 and 17) out today as well. ND-09-1090 BLN-SER-OI-Ch12 Response.pdf ND-09-1092 BLN-SER-OI-Ch14 Response.pdf ND-09-1089 BLN SER-OI-Ch10 Response.pdf ND-09-1113 BLN-SER-OI-Ch19 Response.pdf Amy A.

Hearing Identifier: Vogtle_COL_Public Email Number: 126 Mail Envelope Properties (B4ECC0E252653F48B3F57C3B833465E8101A9ABB2C) Subject: FW: OI responses submitted 7/16/09 Sent Date: 7/17/2009 10:36:02 AM Received Date: 7/17/2009 10:36:04 AM From: Sebrosky, Joseph Created By: [email protected] Recipients: "VogtleCOL Resource" <[email protected]> Tracking Status: None "Joshi, Ravindra" <[email protected]> Tracking Status: None Post Office: HQCLSTR02.nrc.gov Files Size Date & Time MESSAGE 894 7/17/2009 10:36:04 AM ND-09-1090 BLN-SER-OI-Ch12 Response.pdf 1011068 ND-09-1092 BLN-SER-OI-Ch14 Response.pdf 974964 ND-09-1089 BLN SER-OI-Ch10 Response.pdf 971733 ND-09-1113 BLN-SER-OI-Ch19 Response.pdf 1000714 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date: Recipients Received:

U.S. Nuclear Regulatory Commission ND-09-1090 Page 3 of 4

cc: Southern Nuclear Operating CompanyMr. J. H. Miller, III, President and CEO (w/o enclosure) Mr. J. T. Gasser, Executive Vice President, Nuclear Operations (w/o enclosure) Mr. D. H. Jones, Site Vice President – Vogtle 3 and 4 (w/o enclosure) Mr. T. E. Tynan, Vice President - Vogtle (w/o enclosure) Mr. M. K. Smith, Technical Support Director Mr. D. M. Lloyd, Vogtle 3 & 4 Project Support Director Mr. C. R. Pierce, Nuclear Development Licensing Manager Mr. M. J. Ajluni, Nuclear Licensing Manager Mr. W. A. Sparkman, COL Project Engineer Document Services RTYPE: AR01.1053 File AR.01.02.06

Nuclear Regulatory CommissionMr. L. A. Reyes, Region II Administrator (w/o enclosure) Mr. F.M. Akstulewicz, Deputy Director Div. of Safety Systems & Risk Assess. (w/o enclosure) Ms. S. M. Coffin, AP1000 Manager of New Reactors (w/o enclosure) Mr. R. G. Joshi, Lead Project Manager of New Reactors Mr. B. Hughes, Project Manager of New Reactors Ms. T. E. Simms, Project Manager of New Reactors Mr. B. C. Anderson, Project Manager of New Reactors Mr. M. M. Comar, Project Manager of New Reactors Mr. M. D. Notich, Environmental Project Manager Mr. J. H. Fringer, III, Environmental Project Manager Mr. L. M. Cain, Senior Resident Inspector of VEGP

Georgia Power CompanyMr. O. C. Harper, IV, Vice President, Resource Planning and Nuclear Development (w/o enclosure)

Oglethorpe Power CorporationMr. M. W. Price, Chief Operating Officer (w/o enclosure)

Municipal Electric Authority of GeorgiaMr. S. M. Jackson, Vice President, Power Supply (w/o enclosure)

Dalton UtilitiesMr. D. Cope, President and Chief Executive Officer (w/o enclosure)

Bechtel Power CorporationMr. J. S. Prebula, Project Engineer (w/o enclosure) Mr. R. W. Prunty, Licensing Engineer

Tetra Tech NUS, Inc.Ms. K. K. Patterson, Project Manager


Shaw Stone & Webster, Inc.Mr. K. B. Allison, Project Manager (w/o enclosure) Mr. J. M. Oddo, Licensing Manager Mr. D. C. Shutt, Licensing Engineer

Westinghouse Electric Company, LLCMr. W. E. Cummins, Vice President of Regulatory Affairs and Standardization Mr. N. C. Boyter, Consortium Project Director Vogtle Units 3 & 4 (w/o enclosure) Mr. S. A. Bradley, Vogtle Project Licensing Manager Mr. R. B. Sisk, Manager, AP1000 Licensing and Customer Interface Mr. J. L. Whiteman, Principal Engineer, Licensing & Customer Interface Mr. D. A. Lindgren, Principal Engineer AP1000 Licensing and Customer Interface

NuStart EnergyMr. R. J. Grumbir Mr. E. R. Grant Mr. B. Hirmanpour Mr. N. Haggerty Ms. K. N. Slays

Other NuStart Energy AssociatesMs. M. C. Kray, NuStart Mr. S. P. Frantz, Morgan Lewis Mr. P. S. Hastings, NuStart & Duke Energy Mr. J. A. Bailey, TVA Ms. A. L. Sterdis, TVA Mr. J. P. Berger, EDF Mr. M. W. Gettler, FP&L Mr. P. Hinnenkamp, Entergy Mr. G. D. Miller, PG&N Mr. M. C. Nolan, Duke Energy Mr. N. T. Simms, Duke Energy Mr. G. A. Zinke, NuStart & Entergy

(w/o Enclosure)Mr. R. H. Kitchen, PGN Ms. A. M. Monroe, SCE&G Mr. R. Reister, DOE/PM

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Southern Nuclear Operating Company

ND-09-1090

Enclosure

Response to R-COLA SER with Open Items

Chapter 12

Open Item Response12.01-01 Standard - See enclosed 12.03-01 Standard - See enclosed 12.04-01 Standard - See enclosed

ND-09-1090 Enclosure Response to SER OIs for Chapter 12

Page 2 of 4

eRAI Tracking No. 3276 NuStart Qb Tracking No. 3513 NRC SER OI Number 12.01-01: STD COL 12.1-1 includes a commitment to the use of a “Generic FSAR Template Guidance for Ensuring That Occupational Radiation Exposures Are as Low as Is Reasonably Achievable (ALARA),” as an operational program document, based on draft NEI Template 07-08, Revision 2. The NEI template presents the functional elements of an ALARA program, which, if met, would demonstrate compliance with 10 CFR 20.1101 and 10 CFR 19.12. Accordingly, BLN FSAR Section 12.1, STD COL 12.1-1 needs to be updated as to its commitment to the final NEI ALARA template if it is accepted by the NRC staff. Therefore, the staff cannot find the applicant’s reference to the NEI 07-08 template to be acceptable until the staff completes its review of this template as a method to meet the regulatory requirements of an ALARA program, and the BLN FSAR is updated to reference the final version of this template. This is identified as Open Item 12.1-1.

SNC Response:The revisions to the COL application associated with this open item cannot be completed until the NEI 07-08 template has been approved. Once this occurs, NEI must issue the approved (or –A) version of the template. Once the approved version of the template is issued, a supplemental response to this item will be provided that incorporates the appropriate changes into the COL application.

This response is expected to be STANDARD for the S-COLAs.

Associated VEGP COL Application Revisions: To be provided in a future supplemental response.


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eRAI Tracking No. 0613, 0863 NuStart Qb Tracking No. 3514 NRC SER OI Number 12.03-01: The applicant stated in a letter dated September 22, 2008, that it will adopt the NEI 08-08, “Generic FSAR Template Guidance for Life Cycle Minimization of Contamination,” Revision 0 template. If approved by the NRC, the applicant will provide additional description of site specific design features and procedures for operation that minimize contamination of the facility, site, and environment. NEI 08-08 is currently under staff review. This is identified as OpenItem 12.3-1.

SNC Response:The revisions to the COL application associated with this open item cannot be completed until the NEI 08-08 template has been approved. Once this occurs, NEI must issue the approved (or –A) version of the template. Once the approved version of the template is issued, a supplemental response to this item will be provided that incorporates the appropriate changes into the COL application.


Associated VEGP COL Application Revisions: To be provided in a future supplemental response.


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eRAI Tracking No. 2753 NuStart Qb Tracking No. 3515 NRC SER OI Number 12.04-01: Section 4.5 of Part 3, Environmental Report (ER), of the BLN COL application provides an analysis of the expected average annual dose that will be received by a construction worker at BLN Unit 4 during the construction period. Section 4.5.6 of the ER states that there will be a radiation protection and ALARA program for BLN Unit 4 construction workers that will meet the requirements of 10 CFR 20.1302. Section 4.6 of the ER Table 4.6-1 describes specific measures and controls. Contrary to the ER, BLN COL FSAR Section 12.4 does not contain any description of a construction worker program to address minimizing exposure during BLN Unit 4 construction. In RAI 12.3-12.4-6, the applicant was requested to describe the program that will ensure the construction workers will be monitored and that exposures will be minimized and maintained ALARA in accordance with 10 CFR 20.1101(b). This is identified as Open Item 12.4-1.

SNC Response:Construction workers are considered as members of the public. However, additional protective measures are taken in order to minimize exposure during construction from the operating plant. The operating plant Radiation Protection program will include monitoring of construction areas (e.g., placement of TLDs).

The FSAR will be revised as shown under the associated COLA revision section to include the construction worker dose monitoring described above.


Associated VEGP COL Application Revisions: COLA Part 2, FSAR Chapter 12, Subsection 12.4.1.9, will be revised to include the following new subsection (12.4.1.9.4.5 for VEGP) at the end of the section with a Left Margin Annotation (LMA) of STD SUP 12.4-1:

STD SUP 12.4-1 12.4.1.9.x Operating Unit Radiological Surveys

The operating unit conducts radiological surveys in the unrestricted and controlled area and radiological surveys for radioactive materials in effluents discharged to unrestricted and controlled areas in implementing 10 CFR 20.1302. These surveys demonstrate compliance with the dose limits of 10 CFR 20.1301 for construction workers.

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ND-09-1092

Enclosure


Chapter 14

Open Item Response14.02-01 Standard - See enclosed 14.02-02 Standard - See enclosed


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eRAI Tracking No. N/A NuStart Qb Tracking No. 3500 NRC SER OI Number 14.02-01: Since development of test specifications and test procedures will require detailed plant-specific design information and close coordination with design organizations, the staff determined that it is acceptable to develop detailed preoperational and startup test specifications and test procedures during the post-COL phase (See Section 14.2.3.5). Therefore, the staff finds acceptable proposed License Condition 2, Item 14.4-2. Concerns remain regarding the adequacy of administrative controls in License Condition 6, Item d., for the development of test specifications and test procedures. This is identified as Open Item 14.2-1.

SNC Response:

The NRC staff has indicated that the administrative controls on License Conditions is under review by the NRC. The Open Item 14.2-1 is related to generic Open Item No.1-2 (license conditions and commitments); as such, no action is required by the Applicant until Open Item 1-2 is generically resolved.


Associated VEGP COL Application Revisions: To be provided in a future supplemental response, if required based on resolution of Open Item 1-2.


Page 3 of 3

eRAI Tracking No. N/A NuStart Qb Tracking No. 3501 NRC SER OI Number 14.02-02: The staff determined that it is acceptable to develop a site-specific startup administrative manual, which will contain the administrative procedures and standards that govern the activities associated with the plant initial test program, during the post-COL phase (see Section 14.2.3.5). Therefore, the staff finds acceptable proposed License Condition 2, Item 14.4-3. Concerns remain regarding the adequacy of administrative controls for changing the test program as described in License Condition 8. This is identified as Open Item 14.2-2.

SNC Response:

The NRC staff has indicated that the administrative controls on License Conditions is under review by the NRC. The Open Item 14.2-2 is related to generic Open Item No.1-2 (license conditions and commitments); as such, no action is required by the Applicant until Open Item 1-2 is generically resolved.


Associated VEGP COL Application Revisions: To be provided in a future supplemental response, if required based on resolution of Open Item 1-2.

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ND-09-1089

Enclosure


Chapter 10

Open Item Response10.01-01 Standard - See enclosed


Page 2 of 3

eRAI Tracking No. 0169 – 10.3.6-1 NuStart Qb Tracking No. 3489 NRC SER OI Number 10.01-01: The response to RAI 10.3.6-1 described how susceptibility to FAC will be evaluated as the design and as-built information becomes available, and high-risk (of FAC) components will be evaluated for baseline testing prior to startup. The staff had the following concerns: …

c) The applicant did not add the FAC program implementation schedule and construction phase activities to the COL application.

The applicant submitted a supplemental RAI response dated May 26, 2009 (ML091480012). ...The revised response to RAIs 10.3.6-1, 10.3.6-2, and 10.3.6-3 therefore addressed all of the concerns identified above, with the exception of identifying the program implementation schedule in the application. This is Open Item 10.1-1.

SNC Response:The FAC program implementation schedule, including the construction phase activities, will be included in the application as shown in the Application Revisions section below. The changes shown below also include previous changes identified in the response to BLN-RAI-LTR-152 (reformatting and the addition of item e), and the response to question 13.03-25.Q included with BLN-RAI-LTR-122, Supplement 5 (revision of item b), and one minor editorial revision for consistency in the language (delete “the” in item b). The identified changes will be included in a future application revision.


Associated VEGP COL Application Revisions: COLA Part 10, proposed License Condition 6, will be revised from: 6. OPERATIONAL PROGRAM READINESS: The NRC inspection of operational programs will be the subject of the following license condition in accordance with SECY-05-0197.PROPOSED LICENSE CONDITION:The licensee shall submit to the appropriate Director of the NRC, a schedule, no later than 12 months after issuance of the COL, that supports planning for and conduct of NRC inspections of operational programs listed in the operational program FSAR Table 13.4-201. The schedule shall be updated every 6 months until 12 months before scheduled fuel loading, and every month thereafter until either the operational programs in the FSAR table have been fully implemented or the plant has been placed in commercial service, whichever comes first.

a. This schedule shall include a submittal schedule for the emergency planning implementation procedures to the NRC consistent with 10 CFR Part 50, Appendix E, Section V.

b. This schedule shall include a schedule for the development of the site specific Severe Accident Management Guidance.

c. This schedule shall include a submittal schedule for the reactor vessel pressurized thermal shock evaluation at least 18 months prior to initial fuel load.

d. This schedule shall include a submittal schedule for approved preoperational and startup test procedures in accordance with FSAR Section 14.2.3.


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To read:

6. OPERATIONAL PROGRAM READINESS: The NRC inspection of operational programs will be the subject of the following license condition in accordance with SECY-05-0197.PROPOSED LICENSE CONDITION:The licensee shall submit to the appropriate Director of the NRC, a schedule, no later than 12 months after issuance of the COL, that supports planning for and conduct of NRC inspections of operational programs listed in the operational program FSAR Table 13.4-201. The schedule shall be updated every 6 months until 12 months before scheduled fuel loading, and every month thereafter until either the operational programs in the FSAR table have been fully implemented or the plant has been placed in commercial service, whichever comes first. This schedule shall include a submittal schedule for:

a. the emergency planning implementation procedures to the NRC consistent with 10 CFR Part 50, Appendix E, Section V.

b. the implementation of site specific Severe Accident Management Guidance.c. a reactor vessel pressurized thermal shock evaluation at least 18 months prior to initial fuel load.d. approved preoperational and startup test procedures in accordance with FSAR Subsection 14.2.3. e. an emergency response data system (ERDS) implementation program plan consistent with

10 CFR Part 50, Appendix E, Section V.f. a flow accelerated corrosion (FAC) program implementation schedule, including the construction

phase activities.

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ND-09-1113

Enclosure


Chapter 19

Open Item Response19.58-01 Plant-Specific – Bellefonte (not included) NRC Staff Action (eRAI 1985 – 19-16)19.58-02 Plant-Specific – Bellefonte (not included) NRC Staff Action (eRAI 1985 – 19-17) 19.59-01 Standard - See enclosed


Page 2 of 2

eRAI Tracking No. 0815 NuStart Qb Tracking No. 3505 NRC SER OI Number 19.59-01: In response to the first part of RAI 19-4, the applicant proposed revisions to BLN COL FSAR Table 2.0-201 and a similar passage in BLN COL FSAR Section 3.7.1.1.1. These have been incorporated in Revision 1 of the BLN COL FSAR. The staff finds the need for additional testing to be inconsistent with the BLN COL FSAR, Revision 1 statements on this issue. This is Open Item 19.59-1.

SNC Response:This Open Item is related to seismic margins. In discussions with the NRC staff, it was determined that the staff is following up with Westinghouse to resolve this open item in the DCD (reference: DCD Open Item OI-SRP19.0-SPLA-12). As such, no action is needed by the COL Applicant at this time. However, the Open Item remains open for tracking purposes.


Associated VEGP COL Application Revisions: To be provided in a future supplemental response if DCD open item resolution results in the need for a COLA change.

2009/07/17 Vogtle COL Review - FW: OI responses submitted ...ND-09-1092 BLN-SER-OI-Ch14 Response.pdf...

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