ML20097A309

Forwards Listed Changes to 950501 Proposed Conversion to Improved Ts,Based on NUREG-1431,in Response to NRC Comments

ML20097A309
Person / Time
Site:	Vogtle
Issue date:	01/30/1996
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20097A312	List: ML20097A309 ML20097A317
References
RTR-NUREG-1431 LCV-0603-E, LCV-603-E, TAC-M92131, TAC-M92132, NUDOCS 9602050251
Download: ML20097A309 (3)

Text

• Georgia Power Company 40 inverner,s Center Parkway Post Ottee Box 1295

.. Birtrangham, Alabama 35201 Telephone 205 877-7122 c.K.uccoy Vce Presdent. Nuclear Georgia Power Vogtie Propct the Southem etexIrc system January 30, 1996 LCV-0603-E Docket Nos. 50-424 50-425 TAC Nos. M92131 M92132 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT PROPOSED CONVERSION OF THE UNIT 1 AND UNIT 2 TECHNICAL SPECIFICATIONS BASED ON NUREG-1431 By letter dated May 1,1995, (LCV-0603) Georgia Power Company (GPC) proposed to amend the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications (TS). The proposed changes would, in part, convert the existing VEGP TS to the improved TS for Westinghouse plants as represented by NUREG-1431. By letter dated December 21,1995. (LCV-0603-D) GPC revised our May 1,1995, submittal in response to requests for additional intbrmation from the NRC staff as well other issues that were identified subsequent to our May 1,1995, submittal. Subsequent to our December 21,1995, submittal, several additional issues have been identified that need to be addressed as described in the following paragraphs.

The following two changes to our proposed conversion to the improved TS are being submitted in response to NRC staff comments. The first revises Condition G of LCO 3.4.15, RCS Leakage Detection Instrumentation, and associated Bases, to clarify that, in the event that all required leakage detection systems are inoperable, LCO 3.0.3 should be entered immediately. The second change revises SR 3.8.1.13, and associated Bases, to specify a kVAR value (corresponding to a power factor of 0.9) for the period of time that the diesel generator is loaded to between 7600 kW and 7700 kW.

The ibliowing three changes are necessary to correct errors in our submittal. The Bases for LCO 3.2.1 Required Action A.3 state that the Overpower AT trip setpoint (value of K 4) must be reduced by 21 % (in AT3 pan) for each 1 % by which F 9 (Z) exceeds its limit. Ilowever, 050056 (Ml\

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U. S. Nuclear Regulatory Commision LCV-0603-E Page 2 in LCO 3.3.1, the Overpower AT trip setpoint equation was revised such that it is expressed l in terms of percent Rated Thermal Power (RTP) rather than in AT span. Therefore, the Bases i l

for LCO 3.2.1 Required Action A.3 should be revised to state that the Overpower AT trip l setpoint must be reduced by 21 % (in % RTP) to correspond with the expression of the Overpower AT trip setpoint in % RTP in LCO 3.3.1.

The next correction needed concerns a statement in Enclosures 1 and 2 to Chapter 3.8 (Discussion of Change 67) that the current requirement 4.8.1.1.2.j.2 regarding the pressure test of the ASME Code ill diesel fuel oil system would be relocated to inservice inspection i

and testing programs. ASME Section XI does not address diesel fuel oil systems. Therefore, i this requirement is more appropriately controlled by plant maintenance procedures.

l l Another needed correction which is similar to :he above is that the Bases fbr Surveillance l Requirement 3.8.3.7 states that this SR requires ASME Section XI examination of the diesel l l fuel oil storage tanks. A change to the Bases fbr Surveillance Requirement 3.8.3.7 is enclosed to remove the reference to ASME Section XI. I l

l l Another change that needs to be made affects the Bases for LCO 3.7.6 which contains requirements for the condensate storage tanks (CSTs). The Bases presently state that a design modification is planned for the CSTs during 1996. That design modification is being rescheduled, and a revised Bases page is enclosed to reflect the change in plans. As stated in the improved TS, both CSTs will be required to be operable in accordance with LCO 3.7.6a after improved TS implementation and until implementation of the design modification.

l Finally, a change is proposed to items 5.5.11.a and 5.5.11.c of section 5.0 to maintain current l licensing basis. Specifically, the requirement of 5.5.11.a that penetration and system bypass be verified < 0.05 % would be revised to s 0.05 %. The current TS acceptance criteria (TS 4.7.6.c.1 and 4.7.7.b.1) is expressed in terms of a filter retention of greater than or equal to 99.95 %. Therefore the proposed change is consistent with current TS requirements when expressed in terms of penetration and system bypass. Similarly, the requirement of 5.5.11.c that methyl iodide penetration be verified "less than" a limiting value is revised to "less than or equal to." This is consistent with current TS requirements 4.7.6.c.2 and 4.7.7.c.

! All of the above changes are consistent with the justifications and significant hazards evaluations provided with our letter dated May 1,1995, as revised by our letter dated December 21,1995.

Sincerely,

1. l' C. K. McCoy

U. S. Nuclear Regulatory Commission LCV-0603-E Page 3 CKM/NJS Enclosures xc: Georgia Power Comoany Mr. J. B. Beasley, Jr.

Mr. M Sheibani NORMS U. S. Nuclear Regulatorv Commission Mr. S. D. Ebneter Regional Administrator Mr. L. L. Wheeler, Licensing Project Manager, NRR Mr. C. R. Ogle, Senior Resident Inspector, Vogtle l

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