ML20072F198

Application for Amend to License NPF-68,eliminating Article 2.C.(6) & Associated Attachment 1 of License Re Diesel Maint & Surveillance

ML20072F198
Person / Time
Site:	Vogtle
Issue date:	08/16/1994
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20072F202	List: ML20072F198 ML20072F206
References
LCV-0428, LCV-428, NUDOCS 9408230244
Download: ML20072F198 (7)

Text

G:: n ;;, Vo meCw rw

.M m mo (, . r P.u 4 if pr rry n [y 3, 1/ ,

sir ,c. $

- t Jl It u ,

• * >P?i '*

s C. K. McCoy ( COrgia Power

} [. f ,

s. . ,,,,,m. y ,u August 16, 1994 LCV-0428 Docket Nos. 50-424 50-425 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE OPERATING LICENSE DIESEL MAINTENANCE AND SURVEILLANCE In accordance with the provisions of 10 CFR 50.90, Georgia Power Company (GPC) hereby proposes to amend the Vogtle Electric Generating Plant (VEGP) Unit i Operating License NPF-68. The proposed revision will eliminan article 2.C.(6) and the associated attachment 1 of the license. Article 2.C.(6) references attachment I which lists special diesel generator (DG) maintenance and surveillance re.luirements.

Concern over the reliability of DGs manufactured by Transamerica Delaval, Inc. (TDI) led to the formation of an owners' group plan for providing an in-depth assessment of the adequacy of TDI DGs of the type utilized by the Vogtle Electric Generating Plant. The NRC staft's evaluation of the owners group program was documented in NUREG-1216.

The NRC included some of the periodic maintenance / surveillance actions described in NUREG-1216 as attachment I to the VEGP Unit 1 operating license. On the basis of operational experience and inspection results, the owners' group provided information to demonstrate that the special concerns of NUREG-1216 are no longer warranted, and that improved DG availability can be achieved without the additional requirements of attachment I to the VEGP Unit I license. The NRC has reviewed the information and has agreed that there is adequate justification for removing the license condition. The basis for this conclusion is documented in Topical Report TDI-EDG-001-A " Basis for Modification to inspection Requirements for Transamerica Delaval, Inc., Emergency Diesel Generators." The removal of the license condition will allow changes to the maintenance and surveillance requirements currently contained in attachment I to the license to be made in accordance with 10 CFR 50.59.

v . c-

.. . . ! ., t CJ 9408230244 940816 d PDR ADOCK 0"2000424 P PDR I)

GeorgiaPower A U.S. Nuclear Regulatory Commission PaFe 2 l

Since the NRC has already concurred with the basis for removal of the DG surveillance requirements from the license, Georgia Power Company requests approval of this change by September 1,1994. 1 Enclosure I provides an evaluation pursuant to 10 CFR 50.92 showing that the proposed I changes do not involve significant hazards considerations. Enclosurc 2 contains marked up pages oflicense NPF-68 showing the proposed changes.

In accordance with 10 CFR 50.91, the designated state official will be sent a copy of this letter and all enclosures.

Mr. C. K. McCoy states that he is a vice president of Georgia Power Company and is authorized to execute this oath on behalfof Georgia power company and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

4 GEORGIA POWER COMPANY By:

C. K. McCoy Sworri to and subscribed before me this ay of u(/u4f,1994.

"nwn Ad L Notary Public l

l

Enclosures:

1. Description of Change and 10 CFR 50.92 Evaluation

2. Revised Pages c(w): Georgia Power Compan,y i Mr, J. B. Beasley, Jr. I Mr. M. Sheibani NORMS l j

U. S. Nuc. lear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Ilood, Licensing Project Manager, NRR Mr. B. R. Bonser, Senior Resident Inspector, Vogtle S_ tate _ofGeorgia Mr. J. D. Tanner, Commissioner, Department of Natural Resources 7

,4% -

ENCLOSURE 1 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE OPERATING LICENSE DIESEL MAINTENANCE AND SURVEILLANCE DESCRIPTION OF CHANGE AND 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, Georgia Power Company (GPC) has evaluated the proposed revision to the License and has determined that operation of the facility in accordance with the proposed amendment would not involve any significant hazards considerations.

Descriptian The proposed change to the license will eliminate article 2.C.(6) and attachment 1 to the Vogtle Electric Generating Plant Unit I license. Article 2.C.(6) incorporates attachment 1 into the license. Attachment I contains specific surveillance and maintenance conditions imposed by the NRC to address concerns regarding the reliability of Transamerica Delaval, Inc. (TDI) diesel generators (DGs). The proposed change will remove these conditions from the license.

l 3,. ?.

El-1 tr l

i

ENCLOSURE 1(CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE OPERATING LICENSE DIESEL MAINTENANCE AND SURVEILLA.NCE D_L3CRIPTION OF CHANGE AND 10 CFR 50.92 EVALUATION Ilagkground Following the crank shaft failure at Shoreham in 1983, Georgia Power Companyjoined with other owners ofTDI DGs to address reliability concerns. The owners' group 2

proposed a two phase program for validation of the DGs. Phase 1 of the program provided sufficient justification for operation of the DGs. The NRC review of phase 1 is documented in NUREG-1216. Some of the specific recommendations of NUREG-1216 were incorporated as prescriptive disassemblies and inspections in appendix 1 of the VEGP Unit I license. It was noted in these findings that many of the conditions were imposed due to a lack of operational experience with these TDI DGs in nuclear standby service. Thousands of hours of operation have been logged by TDI DGs since the j issuance of NUREG-1216, and the reliability of the machines has been demonstrated. In addition, many of the surveillance items that are in place have proven to be as effective as inspections for revealing a potential problem. Using surveillances in lieu ofinspections will also contribute to decreased unavailability of the DGs. Removal of the prescriptive teardown and inspection requirements as license conditions will allow flexibility to determine the best way to monitor engine conditions while maintaining reliability and reducing unavailability. The basis for this conclusion was included in submittals to the l NRC on November 30,1992, and December 7,1993. These two submittals have been I reviewed by the NRC staff and the NRC stafTconcurred with the conclusion as stated in the Safety Evaluation Report (SER) for topical report TDI-EDG-001-A " Basis for Modification to inspection Requirements for Transamerica Delaval, Inc., Emergency Diesel Generators," issued by the NRC on March 17,1994.

Analysis The change to the license will delete license conditions related to DG component inspections that were imposed based on the recommendations in NUREG-1216.

Therefore, the detailed steps of preventive maintenance surveillance programs will become subject to the same degree of NRC stafTreview and approval as for DGs provided by other manufacturers. However, future revisions of the maintenance surveillance program are subject to the provisions of 10 CFR 50.59. The owners group in conjunction with the DG manufacturer is developing a generic DG management program. The transition from the current program to the generic program will be accomplished under the provisions of 10 CFR 50.59.

El-2

ENCLOSURE 1 (CONTINUED)

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE OPERATING LICENSE DIESEL MAINTENANCE AND SURVEILLANCE DESCRIPTION OF CHANGE AND 10 CFR 50.92 EVALUATION The requirements imposed by attachment I to the license were in addition to the Technical Specifications surveillance and maintenance requirements for DGs in nuclear service. The requirements of attachment I were imposed due to the unresolved concerns about the reliability of TDI DGs that existed at the time ofissuance of the VEGP Unit I license.

Since that time the concerns have been resolved by substantial operational data and inspection results which have demonstrated that these DGs may be treated on a par with other DGs within the nuclear industry and subjected to the same standard regulations without the special requirements of NUREG-1216. The proposed change will result in continuing DG performance in accordance with NRC requirements for this function, and it is likely to result in improved availability. The current Technical Specification surveillance requirements will continue to assure that the DGs are proven at regular intervals to perform in accordance with NRC requirements. These license conditions have been  ;

technically justified on the basis ofcurrent reliability data and inspection results of 1 operating TDI DGs throughout the last several years. The NRC staff has agreed with these conclusions as documented in the SER for the topical report.

l The current DG maintenance and surveillance program for the VEGP DGs is in agreement l with the applicable portions of the surveillance and maintenance programs described in the j topical report and with the requirements of the Technical Specifications. Any subsequent '

changes to the surveillance and maintenance requirements currently contained in attachment I to the license following the removal of the attachment from the Operating License will be made in accordance with 10 CFR 50.59.

El-3

l ENCLOSURE 1 (CONTINUED) l VOGTLE ELECTRIC GENERATING PLANT l REQUEST TO REVISE OPERATING LICENSE l DIESEL MAINTENANCE AND SURVEILLANCE I I

DESCRIPTION OF CHANGE AND 10 CFR 50.92 EVALUATION l

CP_u91EN9B Dased on the above considerations, GPC has concluded the following concerning 10 CFR 50.92.

1. The proposed change to the license does not involve a significant increase in the probability or consequences of an accident previously evaluated because the  ;

availability and reliability of the DGs will remain within the limits previously assumed in the safety analyses.

2. The proposed change to the license does not create the possibility of a new or different kind of accident from any accident previously evaluated because it does not result in any physical changes to the plant or in its modes of operation and the DGs have been demonstrated to operate at a level of reliability that is consistent with that which was previously determined to be acceptable for this application.

3. The proposed deletion from the license does not involve a significant reduction in a i margin of safety because the results of the operational data and inspection reports have demonstrated that the license conditions are not required to assure that the DGs will be maintained in a state of reliability consistent with that assumed for the safety analyses.  ;

Dased upon the preceding information,it has been determined that the proposed change to the license does not involve a significant hazards consideration as dermed by 10 CFR 50.92.

l l

El-4 l

1 ENCLOSURE 2 VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE OPERATING LICENSE DIESEL MAINTENANCE AND SURVEILLANCE REVISED PAGES Page 4.. . . . . . . . . . .... .. Replace Page 7... . . . . . . . . .. Replace Attachment 1. . .... . . . .. Delete 1

l l

1 l

l l

l l