ML20113A022

Forwards Proposed TS & Bases Reflecting Listed Submittals & Administrative Changes Based on NUREG-1431 Re Conversion of Existing TS to Improved TS

ML20113A022
Person / Time
Site:	Vogtle
Issue date:	06/17/1996
From:	Woodard J GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20113A024	List: ML20113A022
References
RTR-NUREG-1431 LCV-0603-L, LCV-603-L, TAC-M92131, TAC-M92132, NUDOCS 9606240017
Download: ML20113A022 (6)

Text

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.' Georgia Power Company 333 Piedmont Avenue Atlanta, Geor0ia 30308 Tdephone 404 526-3195 Mailing Address 40 invemess Center Parkway Post Office Box 1295 Birmingham. Alabama 35201 Telephone 205 868 5086 J. D. Woodard tv s %n, sync symm l Senior Vice President June 17, 1996 l

LCV-0603-L l i

Docket Nos. 50-424  ;

50-425 TAC Nos. M92131 M92132 U. S. Nuclear Regulatory Commission i ATTN: Document Control Desk l 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 1 and Unit 2 Technical Specifications (TS). The proposed changes would modify and convert the existing VEGP TS to the improved TS for Westinghouse plants based on NUREG-143L By letters dated September 22,1995, (LCV-0655), November 20,1995, (LCV-0670). December 21,1995, (LCV-0603-D), January 30,1996 (LCV-0603-E), March 5,1996, (LCV-0603-I), and May 6,  !

1996, (LCV-0603-P), GPC revised our May 1,1995, submittal in response to requests for additional information from the NRC staff as well as other issues that were identified subsequent to our May 1,1995, submittal. Enclosed are the proposed TS and Bases that reflect the above submittals.

The enclosed TS reflect four administrative changes. The first applies to specification 5.6.5,

" Core Operating Limits Report (COLR)" This specification contains an incorrect reference to WCAP-9220-P-A, Revision 1," Westinghouse ECCS Evaluation Model- 1981 Version,"

February 1982. The correct reference is WCAP-10266-P-A, Revision 2. "The 1981 Version of the Westinghouse ECCS Evaluation Model Using the BASH Code," March 1987. This is an administrative change because the use of WCAP-10266 was approved for VEGP by the NRC as part oflicense amendments 43 and 44 for Unit 1, and 23 and 24 for Unit 2 that provided for the use of VANTAGE-5 fuel and increased operational flexibility. See NRC letter dated September 19,1991, D. S. Ilood, NRC, to W. G. Hairston. III, GPC.

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LCV-0603-L Page 2 Second, specification 5.5.! 3 should include the following statement:

"The provisions of SR 3.0.2 and SR 3.0.3 are applicable to the Diesel Fuel Oil Testing Program surveillance frequencies."

This is current licensing basis. These provisions are applicable to the corresponding requirements in the current TS.

Third, specification 4.2.1 needs to be revised to reflect the correct spelling of the word "zircaloy" and to reflect that ZlRLO* is a registered trademark. Furthermore, specification 4.2.1 of the enclosed TS reflects a change from current licensing basis in that fuel assemblies using ZIRLO* cladding are no longer restricted to the lead test assemblies. The following discussion is provided to supplement the basis for this change. The use of this cladding has previously been reviewcd and accepted by the NRC on a generic basis through the review and approval of WCAP 12610-P-A and the appropriate revisions to 10 CFR 50.46 and 50.44, which was the basis of the NRC stafrs previous approval for the use of 7lRLO* clad fuel rods at other nuclear plants. This WCAP serves as a reference core design report for a fuel assembly design using ZlRLO* clad fuel rods. It presents the information necessary to support the licensing basis fbr the use of fuel assemblies containing ZIRLO* clad fuel rods for fuel reload regions. It includes mechanical, nuclear, thermal-hydraulic, accident and radiological evaluations. It also includes appendices to document ZIRLO* material properties, support fuel rod performance, and provide LOCA models and evaluations.

WCAP-12610-P-A was approved in NRC Safety Evaluations issued on July 1,1991 and October 9,1991. These Safety Evaluations approved the use of VANTAGE + fuel design, i.e.,7.lRLO" clad fuel and found it acceptable for up to a rod-average burnup level of 60,000 MWD /MTU. Therefore, the proposed change to the VEGP Technical Specifications is an administrative change indicating the expected use of fuel cladding at VEGP which has already been generically accepted by the NRC.

The fourth administrative change involves the frequency for SR 3.3.1.14. This SR requires that a trip actuating device operational test (TADOT) be performed on the turbine stop valve closure channels. Turbine stop valve closure and/or low fluid oil pressure indicates a turbine trip, and this in turn will initiate a reactor trip above the P-9 interlock. The present frequency for SR 3.3.1.14 is prior to reactor startup, but the function is not required to be operable until reactor power is above the P-9 interlock. The low fluid oil pressure channels are subject to a channel operational test (COT)(SR 3.3.1.16) at a frequency of after each Mode 3 entry for unit shutdown and prior to exceeding the P-9 interlock trip setpoint. This frequency is consistent with the applicability requirements for the reactor trip on turbine trip function (above the P-9 interlock trip setpoint). GPC overlooked the need to make the frequency of SR 3.3.1.14 consistent with SR 3.3.1.16. Since the NRC has found the frequency of SR 3.3.1.16 to be acceptable, GPC proposes to make the frequency of SR 3.3.1.14 identical to that of SR 3.3.1.16.  !

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. I U. S. Nuclear Regulatory Commission  :

LCV-0603-L Page 3 The last change to the TS since our last submittal involves the lube oil inventory for the emergency diesel generators (DGs)(LCO 3.8.3). It was necessary to revise the required lube oil volumes specified in LCO 3.8.3 due to revised information from the DG vendor.

Our December 21,1995, submittal shows that Note

• to SR 4.5.3.2 (precedural detail for using a safety injection (SI) pump to fill the accumulators) of the existing TS would be moved to the Bases for LCO 3.4.12. The Bases for LCO 3.4.12 do not discuss actual use of an SI pump to fill the accumulators, but the requirement in the Bases that the SI pump be rendered incapable ofinjecting into the RCS by at least two independent means provides fbr use of an Si pump for filling accumulators. Therefore Note

• to existing SR 4.5.3.2 was not incorporated verbatim into the improved TS Bases, but rather the intent was incorporated.

Please note that our December 21,1995, submittal revision included pages for Enclosures 2, 3, and 5 to Chapter 3.9 that were not current with respect to our September 22,1995, submittal. The current pages for Enclosures 2,3, and 5 for Chapter 3.9, as it relates to the unborated water source isolation valves, are those that were provided with our September 22, 1995 submittal.

In response to our May 6,1996, submittal regarding the proposed extended diesel generator allowed outage time (AOT), the NRC staff has identified two issues. The first issue concerns the lack of reliability data for the Plant Wilson combustion turbines (cts), and the second involves demonstrating the operability of tha Wilson line via testing. With respect to the first issue, the NRC staff has stated that an acceptable alternative would be to start and run a CT while a DG is inoperable during an extended AOT.

In response to the first issue, GPC offers the fbilowing. GPC will demonstrate and maintain the " Plant Wilson enhanced black-start generation reliability" at 2 95%. Plant Wilson has 6 cts, any one of which can support the full capacity of the SAT. Two of the cts (CT A and CT B) have enhanced black-start capability. (Under controlled conditions, GPC has demonstrated that Plant Wilson enhanced black-start generation can be started within one hour.) The " Plant Wilson enhanced black-start generation reliability"is defined as the capability of either, or both, CT A or CT B to successfully supply generation for possible alignment to VEGP. The enhanced black-start generation reliability will initially be demonstrated by requiring, either cumulatively or individually,20 consecutive tests of either CT A or CT B with no more than I failure out of the 20 tests. Successful tests will be defined via our procedures based on the overall criteria of having a CT available to supply power. Therefore, the enhanced black-start generation reliability will be demonstrated and maintained at 2 95%.

Separate from the 20 consecutive tests of the enhanced black-start generation reliability, the black-start diesel will be required to successfully start (and load) with no more than 1 failure out of a total of 20 consecutive tests. This will demonstrate the reliability of the black-start

U. S. Nuclear Regulatory Commission LCV-0603-L Page 4 diesel generator. Detailed computer models have been used to simulate the black-start l system design, and these models were validated with field tert results. Therefore, there is no need to perform 20 consecutive black-start demonstrations. The generation capability of the enhanced black-start cts is not materially affected by the source of motive power for the  !

staning motors. Once the diesel is started, all that is necessary to start the CT is manipulation of the necessary disconnect switches and breakers. In addition,in accordance with Plant Wilson procedures, performing 20 black-starts would involve disconnecting Plant Wilson l from the grid (thereby deenergizing the standby auxiliary transformer (SAT) and removing a l preferred offsite source from service) 20 times. GPC considers this to be an unnecessary i reduction in the number of offsite power sources available to VEGP and would reduce VEGP's loss of offsite power recovery options. GPC will maintain our commitment to demonstrate the complete enhanced black-start generation capability at least once per 18 months.

l Once a reliability of 2 95% has been demonstrated, that reliability will be maintained by l ensuring that an enhanced black-start CT and the black-start diesel are started at least once per quarter. Ilowever, performing a series of 20 consecutive tests requires time. In the interim GPC will commit to running a CT during an extended DG AOT until the necessary enhanced black-start generation reliability can be demonstrated. (An extended DG AOT begins at 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> but must not exceed 14 days from initial failure to meet the LCO.) During this interim period, while in an extended DG AOT, a CT will be able to power the safety loads within one hour, and if this CT fails during an extended AOT, GPC will start another CT within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br />. In addition, if during this period GPC chooses to remove a DG from service for preventive maintenance that will involve an extended AOT, GPC will start a CT prior to removing the DG from service. The commitment to run a CT would also apply in the event that enhanced black-start generation reliability were to decrease below 95% after the i

initial demonstration.

l l The second issue, operability of the Wilson line, will be addressed by, at least once per 18 months, demonstrating that power can be made available to a safety bus via the underground I line within one hour. GPC means this requirement to encompass the electrical alignment necessary to provide power to the safety buses, and does not consist of a requirement to black-start a CT within one hour, in addition, GPC means that this testing can be performed in one test or in a series of sequential tests provided that the entire alignment is tested.

Finally, the enclosed Bases reflect certain minor revisions that were identified as a result of our review of the draft Safety Evaluation Report or as part of our implementation effort.

These Bases changes were incorporated to correct errors or to make the Bases consistent with our submittals and the enclosed TS.

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U, S. Nuclear Regulatory Commission '

LCV-0603-L i Page 5 i

i The changes to the TS proposed herein do not alter the conclusions of the evaluations  !

performed pursuant to 10 CFR 50.92 that were provided with the above referenced l' submittals.

i The conversion involves relocating certain requirements and details to licensee controlled documents as reflected in the submittals referenced above. GPC will ensure that these I requirements and details are appropriately reflected in these documents or that they will be j included in the next required update of these documents. In some cases, information is being l moved from the TS to plant procedures, and this information is not reflected in the FSAR, the -

procedures are not described in the FSAR, and no other regulatory requirement applies (i. e.,

10 CFR 50.55(a),50.54(a), etc.). In these cases GPC will control future changes to this information via 10 CFR 50.59.- That is to say, changes to this information will only be made without prior Commission approval provided those changes do not involve a change to the TS or an unreviewed safety question.

In addition, GPC will maintain an auditable record of, and an implementation schedule for, the procedure changes associated with the conversion to the ITS. Furthermore, GPC will maintain the documentation of these changes in accordance with the record retention requirements in the Quality Assurance plan.

Finally, GPC requests that the license amendment be issued by July 7,1996, with implementation within 150 days ofissuance.

Mr. J. D. Woodard states that he is a senior vice president of Georgia Power Company and is  !

authorized to execute this oath on behalf of Georgia Power Company and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosures are true.

GEORGIA POWER COMPANY IlY: k MA 6 Woodard Sworn to and subscribed before this /7Mday of June _,1996.

My commission expires: f-/9-P)

Notary Publ' -

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, U. S. Nuclear Regulatory Commission l LCV-0603-L I Page 6 1

1 Enclosures xc: Georgia Power Comnany l Mr. C. K. McCoy Mr. J. B. Beasley, Jr.

Mr. M. Sheibani NORMS  ;

U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regiona.' Administrator Mr. L. L. Wheeler, Licensing Project Manager, NRR Mr. C. R. Ogle, Senior Resident Inspector, Vogtle l

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