ML20195D836

Informs That Instead of Deleting License Condition H,As Proposed by NRC in Telcon,License Condition Will Be Revised to Read as Listed.Licensee Has Adopted Microsoft Word 97 as Word Processing Std.Encl TS Should Be Issue Change

ML20195D836
Person / Time
Site:	Vogtle
Issue date:	11/11/1998
From:	Beasley J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20195D840	List: ML20195D836
References
LCV-1191-A, NUDOCS 9811180177
Download: ML20195D836 (9)

Text

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-4 I. Bernie Beasley, Jr., P.E.

Southern Nuclear -

J Vice President -

Operating Company. Inc.

Vogtle Project 40 inveiness Center Parkway

. RO. Box 1295 Birmingharn. Alabarna 35201 Tel 205992.7110 Fax 205 992.0403 SOUTHERN COMPANY November 11. 1998 LCV-Il91-A Docket Nos.

50-424 50-425 License Nos.

NPF-68 NPF-81 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT REVISION TO REQUEST FOR LICENSE AMENDMENT REMOVAUMODIFICATION OF OBSOLETE CONDITIONS By letter dated October 15,1998, Southern Nuclear Operating Company (SNC) requested a license amendment that would delete or modify license conditions that have been completed or are otherwise no longer in effect. Subsequent to that submittal, SNC was notified by the NRC staff via telephone conversation that the proposed deletion of License Condition H.,

Reporting to the Commission, needed to be revised. Instead of deleting License Condition H., SNC proposes to revise the 1icense condition as follows:

"Except for item 2.C.(2), Southern Nuclear shall report any violations of the requirements contained in Section 2.C of this license in the following manner: initial notification shall be made within twenty-four (24) hours to the NRC Operations Center via the Emergency Notification System with written follow-up within 30 days in accordance with the procedures described in 10 CFR 50.73 (b), (c) and (e)."

The proposed revision has the desired effect of eliminating ambiguous reporting requirements with respect to violations of the Technical Specifications and/or Environmental Protection Plan, while retaining a requirement to report violations of the remaining conditions under Section 2.C of the license.

In addition, SNC has discussed with the NRC staff the process by which the Technical Specifications might be converted from an earlier word processing format to the current s

company standard of Microsoft* Word 97.

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U. S. Nuclear Regulatory Commission l.

LCV-1191-A l

Page 2 l

l I-l The Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications (TS) were originally created using Wordperfect

• for DOS version 5.1 at the request of the NRC. Since that time, the NRC has replaced Wordperfect

• for DOS version 5.1 with a later version of Wordperfect *, and the NRC requested that SNC maintain the electronic copy of the VEGP TS. In the meantime, SNC has adopted Microsoft* Word 97 as a word processing

(.

standard. Therefore, SNC has converted the VEGP TS and Bases word processing format from Wordperfect

• for DOS version 5.1 to Microsoft* Word 97. There were no changes to technical requirements. The only visible changes to the document are as follows: (1) the font j

was changed to Arial 11 point; page numbers were revised to an LCO specific numbering i

scheme; and intentionally blank pages were deleted.

l The process for converting the TS involved the folk wing steps. First, the software was L

allowed to automatically convert the electronic files from the original format to Microsoft*

l Word 97. Then Southern Company Services (SCS) Engineering Publications personnel f

reviewed the files, and format problems created by the conversion process were corrected.

Next, the TS and Bases were reviewed independently by SNC Vogtle Project Corporate licensing personnel. This review identified additional remaining format errors, which were corrected by the SCS Engineering Publications personnel. The SCS Engineering Publications personnel then performed a third review of the converted TS and Bases. This third review was a word-for-word review of the converted documents against the original documents to l

provide additional assurance of the integrity of the converted TS and Bases. Therefore, SNC requests that the NRC issue the enclosed TS and Bases as an administrative change.

A revised evaluation pursuant to 10 CFR 50.92 is enclosed to reflect the revision of License Condition H. rather than its deletion. The conversion of the TS and Bases to Microsoft*

Word 97 is also addressed in the enclosed evaluation.

l Sincerely, J. B. Beasley, Jr.

JBB/NJS I

l i

I i

i-Ii.

1 1

U. S. Nuclear R gul tory Commission I

LCV-1191 A i

Page 3

Enclosures:

Revised 50.92 Evaluation Technical Specifications and Bases xc:

Southern Nuclear Operating Company Mr. J. T. Gasser Mr. M. Sheibani SNC Document Management U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. D. H. Jaffe, Senior Project Manager Mr. J. Zeiler, Senior Resident inspector, Vogtle

l ENCLOSURE l

REQUEST FOR LICENSE AMENDMENT REMOVAIJMODIFICATION OF OBSOLETE CONDITIONS 10 CFR 50.92 NO SIGNIFICANT IIAZARDS EVALUATION l

l In 10 CFR 50.92, the NRC provides the following standards to be used in determining the existence of a signi6 cant hazards consideration:

..a proposed amendment to an operating license for a facility licensed under 50.21(b) or 50.22 for a testing facility involves no significant hazards consideration if operation of the facility in accordance with the proposed amendment would not: (1)lnvolve a significant increase in the probability or consequences of an accident previously evaluated; or (2) Create the possibility of an accident of a new and different kind from any previously evaluated; or (3) Involve a significant reduction in a margin of safety.

Southern Nuclear has reviewed the proposed license amendment request and determined its adoption does not involve a significant hazards consideration. In support of this determination, f

an evaluation of each 10 CFR 50.92 standard follows.

1.

The proposed changes do not involve a sigmficant increase in the probability or consequences ofan accidentpreviously evaluated.

The proposed changes either remove or modify provisions in the VEGP Unit I and 2 Operating Licenses that have been completed or are otherwise obsolete. Each proposed change is summarized below:

Certain Surveillance Requirements (SRs) that were either added or modified at the time ofImproved Technical Specifications (ITS) implementation were listed in the Operating Licenses with a schedule for performance. With the exception of Unit 2 SR 3.8.1.20, all SRs are deleted from the Operating Licenses, because they have since been performed according to schedule, and will henceforth be performed in accordance with the Technical Specifications.

A condition concerning changes to the Unit I initial test program is deleted due to the completion of the program.

A condition related to FEMA procedures and the emergency plan is deleted from the Unit I license due to the obsolescence of the condition.

Conditions requiring the submission of Unit I reports concerning the steam generator tube rupture analysis, the reactor vessel level instrumentation system, the safety parameter display system, the detailed control room design review, and the zine coating of the diesel fuel storage tanks are deleted due to completion of the required activities.

A condition requiring modification of the Unit i ventilation exhaust of the alternate radwaste facility is deleted due to completion of the required activity.

An exemption related to the seismic adequacy of the Unit I spent fuel racks is deleted because the required actions are completed and the exemption has been determined to be l

no longer in effect.

LCV-Il91-A E-1

s ENCLOSURE REQUEST FOR LICENSE AMENDMENT REMOVAI> MODIFICATION OF OBSOLETE CONDITIONS 10 CFR 50.92 NO SIGNIFICANT HAZARDS EVALUATION A condition in both the Unit I and Unit 2 iicenses containing reporting requirements for e

other license conditions is revised due to ambiguities between the requirements in the license condition and those published in NRC regulations, j

A schedular exemption for the Unit 2 decommissioning funding report is deleted because e

the report was submitted as required and the exemption is no longer in effect.

The Technical SpeciScations and associated Bases have been converted from e

Wordperfect

• for DOS version 5.1 to Microsoft* Word 97. There were no changes to technical requirements. The only visible changes to the document are as follows: (1) the font was changed to Arial 11 point; page numbers were revised to an LCO speciGc numbering scheme; and intentionally blank pages were deleted.

1 The proposed changes discussed above are strictly administrative / editorial and do not affect the operation or function of any plant system, component, or structure. Therefore, the proposed changes do not increase the probability of occurrence or the consequences of a previously evaluated accident.

2.

The proposed changes do not create thepossibility ofa new and di(ferent type ofaccident from anypreviously evaluated.

The proposed administrative / editorial changes do not alter the operation of any plant system or equipment and do not introduce a new mode of operation. Each requirement contained in the license conditions proposed for deletion has either been completed or is obsolete. Since these parts of the license are no longer applicable, deletion of these items does not provide the potential for an accident to be created. The conversion of the Technical Speci0 cations from one word processing format to another did not involve any changes to technical requirements.

Thus, the proposed changes cannot create a new accident initiating mechanism, and do not create the possibility of a new and different type of accident from any previously evaluated.

3.

The proposed changes do not involve a significant reduction in the margin ofsafety, l

The license conditions proposed for deletion are obsolete and each requirement has been completed. The conversion of the Technical SpeciGcations from one word processing format to another did not involve any changes to technical requirements. Since the proposed changes are strictly administrative / editorial and do not involve any physical or procedural changes to the plant, the margin of safety, as deHned in the bases for any Technical SpeciGcation is not affected by the proposed changes.

l LCV-1191-A E-2

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- VOGTLE UNITS 1 AND 2 TECHNICAL SPECIFICATIONS ACTIVE PAGE LIST Unless noted otherwise, all Technical Specifications pages are Amendment No. 96 (Unit 1) and 74 (Unit 2). The latest amendment is Amendment No.103 (Unit 1) and Amendment No. 81 (Unit 2).

i l

PAGE AMENDMENT / REVISION v

99 (Unit 1) 77 (Unit 2)

L viii 102 (Unit 1) 80 (Unit 2)

- ix 102 (Unit 1) 80 (Unit 2) 3.3.1-14 101 (Unit 1) 79 (Unit 2) 3.3.1-15 101 (Unit 1) 79 (Unit 2) 3.3.1-16 101 (Unit 1) 79 (Unit 2) 3.3.1-17 101 - (Unit 1) 79 (Unit 2) 3.3.1 18 101 (Unit 1) 79 (Unit 2) 3.3.1 19 101 (Unit 1) 79 (Unit 2) 3.3.1-20 101 (Unit 1) 79 (Unit 2) 3.3.1-21 101 (Unit 1) 79 (Unit 2) l 3.3.2-9 101 (Unit 1) l 79 (Unit 2) l l

Vogtle Units 1 and 2 i

7/31/98

VOGTLE UNITS 1 AND 2 TECHNICAL SPECIFICATIONG ACTIVE PAGE LIST (continued)

AMENDMENT / REVISION PAGE 3.3.2-10 101 (Unit 1) 79 (Unit 2) 3.3.2-11 101 (Unit 1) 79 (Unit 2) 3.3.2-12 101 (Unit 1) 79 (Unit 2) 3.3.2-13 101 (Unit 1) 79 (Unit 2) 3.3.2-14 101 (Unit 1) 79 (Unit 2) 3.3.2-15 101 (Unit 1) 79 (Unit 2) 3.4.10-1 98 (Unit 1) 76 (Unit 2) 3.7.17-1 99 (Unit 1) 77 (Unit 2) 3.7.18-1 102 (Unit 1) 80 (Unit 2) 3.7.18-2 102 (Unit 1) 80 (Unit 2) 3.7.18-3 102 (Unit 1) 80 (Unit 2) 3.7.18-4 99 (Unit 1) 77 (Unit 2) 3.8.1-2 100 (Unit 1) 78 (Unit 2) e Vogtle Units 1 and 2 il 7/31/98

i i-

[_

VOGTLE UNITS 1 AND 2 TECHNICAL SPECIFICATIONS l

ACTIVE PAGE LIST (continued) l PAGE AMENDMENT / REVISION L

l 3.8.1-3 100 (Unit 1) 78 (Unit 2) l l

3.8.1-4 100 (Unit 1) l 78 (Unit 2) 3.8.1-5 100 (Unit 1)

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78 (Unit 2)

L i-3.8.1.6 100 (Unit 1) 78 (Unit 2)'

4.0-2 102 (Unit 1) 80 (Unit 2) 4.0-3 102 (Unit 1) 80 (Unit 2) l

'4.0-4 102 (Unit 1) 80 (Unit 2) l 4.0-5 102 (Unit 1) 80 (Unit 2) 4.0-6 102 (Unit 1) j.

80 (Unit 2) 4.0-7 99 (Unit 1) u 77 (Unit 2) 4.0-8 99 (Unit 1) 77 (Unit 2) 4.0 102 (Unit 1) 80 (Unit 2) 4.0-10.

99 (Unit 1) 77 (Unit 2) i Vogtie Units 1 and 2 iii 7/31/98 l

i VOGT1.E UNITS 1 AND '2 TECHNICAL SPECIFICATIONS ACTIVE PAGE LIST (continued)

AMENDMENT / REVISION PAGE 102 (Unit 1) 4.0-11 80 (Unit 2) 102 (Unit 1) 4.0-12 80 (Unit 2) 99 (Unit 1) 4.0-13 77 (Unit 2) 99 (Unit 1) 4,0-14 77 (Unit 2) 103 (Unit 1) 5.5.5 81 (Unit 2) 5.5.6 103 (Unit 1) 81 (Unit 2) 5.5-21 100 (Unit 1) 78 (Unit 2) l l

Vogtle Units 1 and 2 iv 7/31/98 l

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