ML20149M713

Requests That NRC Review Encl Comments Re Safety Evaluation Rept in Support of Amendments That Issued Improved TSs

ML20149M713
Person / Time
Site:	Vogtle
Issue date:	01/20/1997
From:	Mckoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LCV-0956, LCV-956, TAC-M92131, TAC-M92132, NUDOCS 9701270099
Download: ML20149M713 (6)

Text

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Georgia Power Company 40 invsrness Centst Parkway Post Offte Box 1295 Birmingham. Alabama 3s201 l Telephone 205 992-7122 Georgia Fbwer ic P es dent, Nuclear Vogtte Project January 20, 1997 l

Docket Nos. 50-424 I 50-425 l TAC- M92131 M92132 U. S. Nuclear Regulatory Commission i

ATTN: Document Control Desk Washington, D. C. 20555 ,

l Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT UNIT 1 AND UNIT 2 IMPROVED TECHNICAL SPECIFICATIONS l COMMENTS ON NRC SAFETY EVALUATION REPORT j 1

By letter dated September 25,1996, the NRC issued Amendments 96 and 74 to the Unit I and Unit 2 operating licenses, respectively. These amendments were in response to our application dated May 1,1995, as supplemented by letters dated August 3 and 9, September 22, November 20, and December 21,1995, January 26 and 30, February 19 and 29, March 5 and 12, May 6, June 17, i August 23, and September 13,1996. The amendments replaced the current Technical Specifications (TS) with a set based on Revision 1 to NUREG-1431," Standard Technical Specifications Westinghouse Plants," hereafter referred to as the Improved TS or ITS.

In preparation for implementation of the ITS, Georgia Power Company (GPC) has reviewed the NRC Safety Evaluation (SE) in support of the amendments that issued the ITS. As a result of that ll review, GPC has identined certain areas that require clarification; specifically with respect to the i disposition and control of requirements and information relocated or removed from the current TS. #og The attached table identifies each item of concern in the SE and the GPC disposition of each item.

i i GPC requests that the NRC review the attached table, and if necessary revise the SE appropriately.

""' Y' I 9701270099 970120 ,

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$ C. K. McCoy 4

U. S. Nuclear Regulatory Commission

, LCV-0956 Page 2

CKM/NJS Attachment xc

Georgia Power Comnany Mr. J. B. Beasley, Jr.

Mr. M. Sheibani NORMS 1

U. S. Nuclear Regulatorv Commission Mr. L. A. Reyes, Regional Administrator Mr. L. L. Wheeler, Licensing Project Manager, NRR Mr. C. R. Ogle, Senior Resident Inspector, Vogtle l

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5 \VOGTIEVO(iTLE KVETECHSPFOSER LCVW56 DOC

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Attachment GPC Clarification With Respect to NRC SE for VEGP ITS Page

& SE Paragraph Section Applicable Execrpt from SE GPC Clarification Pg. 9; first til Evaluation - "(in its application, the licensee allirmed in our letter dated June 17,1996, GPC full Less Restrictive its existing commitment to the NRC to stated the following:

paragraph Requirements evaluate all changes to plant procedures required by Improved TS 5.4.1, "The conversion involves relocating

" Procedures," (corresponding to current certain requirements and details to TS 6.7.1.a, 6.7.1.b, 6.7.1.g, 6.7.1.h) licensee controlled documents as against the unreviewed safety question reflected in the submittals referenced

- teria of 10 CFR 50.59 and to obtain above. GPC will ensure that these I grior NRC approval of changes to any of requirements and details are these procedures that may involve an appropriately reflected in these unreviewed safety question.)" documents or that they will be included in the next required update of these

i. documents. In some cases, information is being 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 I

this information via 10 CFR 50.59. That I

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."

Please note that the above statement applies only to the relocated information.

This statement was not meant to imply that GPC will evaluate all changes to plant procedures required by improved TS 5.4.1, " Procedures, " (corresponding

to current TS 6.7.1.a,6.7.1.b,6.7.1.g, 6.7.1.h) against the unreviewed safety question criteria of 10 CFR 50.59.

Pg 199; 111.3.5 "The snubber inspection requirements of I)y letter dated August 9,1995,(LCV-first full Evaluation - this specification are also part of the 0653) GPC maae the following statement

, paragraph Relocated inservice inspection (ISI) program and regarding the relocation of the snubber

, Requirements are consistent with the requirements of inspection requirements:

'O CFR 50.55a. In accordance with the

, requirements in 10 CFR 50.55a, ISI must "The specification for Snubbers will be l be performed in uccordance with ASME relocated to the Technical Requirements

Section XI. This regulation and licensee Manual (TRM). Changes to the TRM l commitments to the NRC for VEGP ISI will be controlled consistent with the j contain the necessary programmatic provisions of 10 CFR 50.59 and 10 CFR requirements for ISI. Repeating the 50.55a, including the approved t

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Attachment GPC Clarification With Respect to NRC SE for VEGP ITS Page

& SE Paragraph Section Applicable Excerpt from SE GPC Clarification requirements in the improved TS is exemptions."

unnecessary. Changes to the ISI program are adequately controlled by the Future changes will be controlled in provisions of 10 CFR 50.55a. These accordance with 50.59 & 55a, but the i other requirements and the provisions of current program will be the relocated l the ISI program will ensure that future requirements of the current TS 3.7.8. I changes to the CTS snubber requirements Current TS 3.7.8 requirements differ in the ISI program documents will be considerably from ASME Section XI acceptable. Therefore, CTS 3/4.7.8 may snubber requirements. Vogtle currently j be relocated to the TRM." has an approved relief request from ASME Section XI snubber requirements.

The Vogtle position for the snubber  ;

l program under improved TS is presented l l via Relief Request 43 (RR-43). (See letters dated November 17,1995, LCV-0667 for Unit I and January 22,1996, LCV-0668 for Unit 2.) The NRC response to RR-43 (March 8,1996 and August 13,1996, for Units 1 and 2, ,

respectively) stated that the evaluation of l RR-43 would be performed in connection with the processing of the TS amendment request seeking removal of the program (i. e., relocation of the l current TS 3.7.8 requirements to the TRM). Therefore, now that the ITS has been approved by the NRC (including the relocation of current TS 3.7.8 to the

, TRM) GPC is expecting NRC approval i of RR-43.

Table 1; Pg RMWST Table I to the SE indicates that these By letter dated September 22,1995, 18 of 42; discharge valve valve numbers will be relocated to the (LCV-0655) GPC proposed that valves items numbers 1208- FSAR. 1208-U4-175,176,177, and 183 be 3.4.1.4.2, U4-175,176, removed from the TS so that other valves Note #, 177, and 183 may be used in lieu of these four valves.

4.4.1.4.2.2 GPC stated that the applicable valves and Action regned to isolate the unborated water c sources would be controlled by plant l procedures.

i Table 1; Pg RilR suction Table I to the SE indicates that these Our application and supplemental letters 21 of 42; valve and valve numbers will be relocated to FSAR did not specifically address the location items suction relief section 5.4.7. of these valve numbers. These valve

< 4.4.9.3.2.a valve numbers. numbers already appear in various and b sections of the FSAR, but not in the same context as current TS 4.4.9.3.2.a and b.

For the sake of completeness, GPC plans 2

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l Attxchment GPC Clarification With Respect to NRC SE for VEGP ITS Page

& SE l Paragraph Section Applicable Excerpt from SE GPC Clarification 1

( to relocate these valve numbers to the l ITS Bases for LCO 3.4.12 via the Bases l Control Program by April 3,1997.

Table 1; Pg Channel Table 1 of the SE indicates that this Our revised submittal of December 21, i 22 of 42; Calibration of requirement would be relocated to the 1995, (LCV-0603-D) states this item 4.5.1.2 accumulator FSAR. requirement would be relocated to plant level and procedures.

pressure channels -

indication only instrumentation.

Table 1; Pg Procedural Table 1 of the SE indicates that this Our revised submittal of December 21, 22 of 42; details for requirement would be relocated to the 1995, (LCV-0603-D) states this

! Item 4.5.2.f conducting IST Program procedures implementing requirement would be relocated to plant inservice testing 5.5.8. procedures. The correct controlling (IST) of the requirements would be 5.5.8 and 10 CFR ECCS pumps. 50.59.

Table I; Pg Acceptance Table 1 of the SE indicates that this Our revised submittal of December 21, 25 of 42; criteria for requirement would be relocated to the 1995, (LCV-0603-D) states this Item containment IST Program procedures. requirement would be relocated to plant 4.6.2.1.b spray pump procedures. The correct controlling differential requirement would be 10 CFR 50.59.

pressure flow l test.

l Table I; Pg Procedural Table 1 of the SE indicates that this Our revised submittal of December 21,

! 27 of 42; details for AFW requirement would be relocated to the 1995, (LCV-0603-D) states this items pump testing. IST Program procedures. requirement would be relocated to plant j 4.7.1.2.a.1 procedures. The correct controlling and requirement would be 10 CFR 50.59. l 4.7.1.2.a.2 l Table 1; Pg Requirement to Table 1 of the SE indicates that this Our revised submittal of December 21, 30 of 42; verify DG is requirement would be relocated to FSAR 1995, (LCV-0603-D) states this item aligned to section 8.3.1.1.3.H.4. requirement would be relocated to plant 4.8.1.1.2.a.6 supply standby procedures.

power to its associated i

emergency

]

busses.

Table I; Pg Details of diesel Table 1 of the SE indicates that this Our revised submittal of December 21, 31 of 42; fuel oil requirement would be relocated to the 1995, (LCV-0603-D) states this item sampling and TRM. requirement would be relocated to plant 4.8.1.1.2.f analysis procedures. l and Note # procedure

(mercaptan

, content and neutralization number).

Attachment 4

GPC Clarification With Respect to NRC SE for VEGP ITS I l Page

& SE Paragraph Section Applicable Excerpt from SE GPC Clarification l l

Table I; Pg Veri 6 cation that Table 1 of the SE indicates that this Our revised submittal of December 21, )

31 of 42; auto-connected requirement would be relocated to FSAR 1995, (LCV-0603-D) states this i Item loads are within section 8.3.1.1.3. requirement would be relocated to plant 4.8.1.1.2.h.9 DG load procedures.

capacity. l Table 1; Pg Pressure test of Table 1 of the SE indicates that this in our letter dated January 30,199t.,

I 31 of 42; the ASME Code requirement would be relocated to FSAR (LCV-0603-E) we revised our submittal item 111 fuel oil section 9.5.4. to state that this requirement would be 4.8.1.1.2.J.2 system. relocated to plant procedures.

Table 1; Pg Electrolyte Table I of the SE indicates that this Our revised submittal of December 21, l 32 of 42; reference requirement would be relocated to the 1995, (LCV-0603-D) states this  ;

l Table 4.8-2 temperature in ITS Bases for LCO 3.8.6. requirement would be relocated to the l Note (4) and Bases and plant procedures. The correct l l Boat voltage cont.olling requirements would be 5.5.14 temperature and 10 CFR 50.59.

correction in i

Note (6).

l Table I; Pg Conditions Table 1 of the SE indicates that this Our revised submittal of December 21, 34 of 42; l

! comprising requirement would be relocated to the 1995, (LCV-0603-D) states this j Item 3.9.2 OPERABILITY ITS Bases for LCO 3.9.3. requirement would be relocated to the of the source Bases and plant procedures. The correct j range monitors. controlling requirements would be 5.5.14 j and 10 CFR 50.59.

Table 1; Pg Requirement for Table 1 of the SE indicates that this Our revised submittal of December 21, l

38 of 42; an annual requirement would be relocated to the 1995, (LCV-0603-D) states this item 6.1.2 directive from FSAR. requirement would be deleted.

l the General l Manager - ,

Nuclear '

emphasizing the

, pnmary l responsibility of I

the Operations Supervisor.

Table I; Pg Requirement for Table I of the SE indicates that this Our revised suomittal of December 21, 39 of 42; notification of requirement would be relocated to the 1995, (LCV-0603-D) states this Item 6.6.1.a the PRB and FSAR. requirement would be deleted based on SRB within 24 PRB and SRB review of the LER and the hours of retention of the requirement in Technical determination Specifications that the General-Manager

, that a safety and Vice President be notified within 24

, limit violation hours of the determination that a safety i has occurred. limit violation occurred.

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