NL-06-0734, Response to Request for Additional Information on Proposed Technical Specification Change for Surveillance Test Interval Extensions for Components of the Reactor Protection System
| ML061280041 | |
| Person / Time | |
|---|---|
| Site: | Vogtle  |
| Issue date: | 05/05/2006 |
| From: | Grissette D Southern Nuclear Operating Co |
| To: | Document Control Desk, Office of Nuclear Reactor Regulation |
| References | |
| NL-06-0734 | |
| Download: ML061280041 (6) | |
Text
Don E. Grissette Vice President May 5, 2006 Southern Nuclear Operating Company. Inc.
40 lnverness Center Parkway Post Office Box 1295 Birmingham, Alabama 35201 Docket Nos.:
50-424 50-425 Tel 205.992.6474 Fax 205.992.0341 Energy to Serve Your World' U. S. Nuclear Regulatory Commission A m : Document Control Desk Washington, D. C. 20555-0001 Vogtle Electric Generating Plant Response to a Request for Additional Information on Proposed Technical Specifications Change for Surveillance Test Interval Extensions for Components of the Reactor Protection Svstem Ladies and Gentlemen:
By letter dated January 27,2005, Southern Nuclear Operating Company (SNC) proposed to revise Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications (TS) by extending the Surveillance Test Intervals (STI) for certain components of the Reactor Trip System (RTS) and Engineered Safety Feature Actuation System (ESFAS). The proposed changes would revise TS Limiting Conditions for Operation (LCOs) 3.3.1,3.3.2,3.3.6, and 3.3.8. Specifically, the Reactor Trip Breaker (RTB) bypass test time is relaxed from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />, the completion time from 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, and the surveillance frequency from 2 months to 4 months in TS LC0 3.3.l. The surveillance frequency for the Actuation Logic Test is relaxed from a staggered 2 month to 6 month basis; the Master Relay Test is relaxed from a staggered 2 month to 6 month basis; and the Channel Operational Test is relaxed from a 3 month to a 6 month basis.
During a telephone conference on February 2,2006, the NRC requested SNC to verify in writing that the structures, systems and components (SSCs) affected by the proposed changes are covered by the maintenance rule (or other applicable program) and that the performance goals for the SSCs are being met (i.e., consistent with the assumptions of the submittal) and continued performance monitoring (under the maintenance rule or other program) will ensure that the performance goals will continue to be met. Enclosure 1 provides the response to this request.
(Affirmation and signature are on the following page.)
U. S. Nuclear Regulatory Commission NL-06-0734 Page 2 Mr. D. E. Grissette 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 NRC commitment contained in this letter is provided as a table in Enclosure 2.
If you have any questions, please advise.
Respectfully submitted, SO)KflERN NUCLEAR OPERATING COMPANY Don E. Grissette
-'*-*..,,',**,?*~~-
Enclosures:
- 1. Response to a Request for Additional Information on Proposed Technical Specifications Change for Surveillance Test Interval ~xtensions for Components of the Reactor Protection System
- 2. Regulatory Commitment cc:
Southern Nuclear Operating Company Mr. J. T. Gasser, Executive Vice President Mr. T. E. Tynan, General Manager - Plant Vogtle RType: CVC7000 U. S. Nuclear Regulatory Commission Dr. W. D. Travers, Regional Administrator Mr. C. Gratton, NRR Project Manager - Vogtle Mr. G. J. McCoy, Senior Resident Inspector - Vogtle State of Georgia Mr. L. C. Barrett, Commissioner - Department of Natural Resources Vogtle Electric Generating Plant Response to a Request for Additional Information on Proposed Technical Specifications Change for Surveillance Test Interval Extensions for Components of the Reactor Protection System Vogtle Electric Generating Plant Response to a Request for Additional Information on Proposed Technical Specifications Change for Surveillance Test Interval Extensions for Components of the Reactor Protection System NRC Request Verify in writing that the SSCs are covered by the maintenance rule (or other applicable program) and that the performance goals for the SSCs are being met (i.e., consistent with the assumptions of the submittal) and continued performance monitoring (under the maintenance rule or other program) will ensure that the performance goals will continue to be met.
SNC Response Vogtle plans to monitor RTS and ESFAS protection system equipment unavailability and component failures to ensure consistency with the WCAP-15376 modeling assumptions.
These failures will be documented in the site Corrective Action Program and evaluated by engineering. Should the equipment unavailability or reliability fail to meet established monitoring criteria, engineering assessment will determine required corrective action.
With respect to the protection system instrument channels, Vogtle has confirmed that the actual rack drift for the extended surveillance periods is bounded by the rack drift allowances assumed in the supporting setpoint uncertainty calculations. If repeated occurrences of abnormal rack drift occur, the plant corrective action program will define the required corrective actions to restore channel performance to normal.
SNC is developing programs that will encompass this monitoring with an implementation date of one year after the issuance of the Technical Specification amendment. This schedule will allow for at least one and possibly two surveillances under the new STI.
Vogtle Electric Generating Plant Response to a Request for Additional Information on Proposed Technical Specifications Change for Surveillance Test Interval Extensions for Components of the Reactor Protection System Regulatory Commitment
Regulatory Commitment 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 Implement program to monitor RTS and ESFAS protection system equipment unavailability and component failures to ensure consistency with the WCAP-1 5376 modeling assurn~tions.
Scheduled Completion Date (If Required)
Type One year after issuance of Technical Specification amendment.
One-Time Action Continuing Compliance