Generic Letter 2004-02 Plant-Specific Correspondence From 2008 and Later
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The purpose of the Generic Letter (GL) supplemental response is to provide the U. S. Nuclear Regulatory Commission (NRC) with the remaining information to support NRC staff verification that corrective actions to address the GL are adequate. In keeping with the holistic resolution approach endorsed by the Commission in its Staff Requirements Memorandum dated November 16, 2006, each licensee may use any combination of measures that will provide reasonable assurance that long-term core cooling is maintained. The GL supplemental response should provide a summary-level description of the approach chosen. This summary should identify key aspects of design modifications, process changes, and supporting analyses that the licensee believes are relevant or important to the NRC staff’s verification that corrective actions to address the GL are adequate. The summary should address significant conservatisms and margins that are used to provide high confidence the issue has been addressed even with uncertainties remaining. Licensees should address commitments and/or descriptions of plant programs that support conclusions.
To clarify expectations for the supplemental responses, the NRC staff issued additional guidance, “Content Guide for Generic Letter 2004-02,” on August 15, 2007 and a revised guidance, November 21, 2007, that detailed the information the NRC staff believed would be sufficient to support closure of the GL. The guidance was developed with input from the Nuclear Energy Institute and other stakeholders at public meetings on April 18, 2007, and June 19, 2007.
The NRC staff received and approved many extension requests to the December 31, 2007 deadline on the basis provided in SECY-06-0078, which stated that licensees could extend the deadline if, among other things, the licensee had made physical improvements to the ECCS sump or materials inside containment to better ensure a high level of ECCS sump performance. As licensees’ supplemental responses to GL 2004-02 were received in 2008, the NRC reviewed the responses and issued additional RAIs, because in many cases, all of the requested information was not submitted or the staff had concerns with the information contained in the responses.
Verification of corrective actions to address the GL will also include review of inspection results associated with Temporary Instruction (TI) 2515/166, “Pressurized Water Reactor Containment Sump Blockage (NRC GL 2004-02).” This TI requires NRC inspectors to verify actions implemented in response to NRC Generic Letter 2004-02 are complete and, where applicable, are programmatically controlled. In general, the final supplemental responses in each area should, as appropriate, (1) state that the information provided in the previous GL 2004-02 responses continues to apply, (2) supplement the previous information, and (3) revise previous information.
The NRC assesses the design and operation of nuclear power plants on an ongoing basis to ensure that public health and safety are maintained and that the environment is protected. The NRC is committed to closing GSI-191 in 2010, the NRC believes it is prudent to incur no further delays in resolving the issue.