ML20199G568

Rev 5 to VPAP-2001, Station Planning & Scheduling. Even Numbered Pages of Incoming Submittal Not Included

ML20199G568
Person / Time
Site:	North Anna
Issue date:	06/30/1997
From:	VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.)
To:
Shared Package
ML20199G403	List: ML20199G399 ML20199G416 ML20199G446 ML20199G568
References
VPAP-2001, NUDOCS 9711250212
Download: ML20199G568 (19)

Text

_ - . . . - - . - . - . - . - - . . - . - . - - . . - . . . - . . . . . . .- - - .. -

t  :

t i

i i

4 1

4 i

i F

I r

t

[

4 Attachment 5 VPAP 2001 Online Maintenance 1

(

North Anna Units 1 and 2 }

f 9

E f

i t

4 i

^

9711250212 971118 i PDR ADOCK 05000338 l p PDR-. .

) . - .

., _. . , _ . . . _ . , . , . , . . - . _ , . . . - . . . . _ _ . - , . . . . , . _ . _ _ - _ . . . . . _ . , . . . . . _ . . - . , _ _ . _ . . ~ _ - _ . . . . . . _ - ~ . . . . - - . . . .

Level 2 C:nttil:d Distributi:n Mantained by this Department W 1T/N W i*I/5 8f *y y 1

9VIRGINIA POWER Station Administrative Procedure a ,,, s,,, u,,,n ne n,,,

Title:

Station Planning and Scheduling Process / Program Owner: Superintendent Outage & Planning Procedure Number Revision Number Effective Date VPAP 2001 5 6 30-97 Revision Summary

. Levised to include additionalinstmetions concerning the Maintenance Rule (MR)

. Added 5.2.3 and 6.7.6 Note Assistant Station Manager O&M approval is required for

)lanned/ scheduled removal of MR SSCs from service when performance criteria or goals would 3e exceedcd

. Changed 5.3 " Nuclear Analysis and Fuel" to " Nuclear Safety Analysis" to correct group with responsibility and revised responsibility for expansion of listing for equipment important to on line maintenance risk

. Deleted 5.4.2 " train" for clarity

. Added to 5.4.4 and 6.1.3.d " scheduled" to make applicable for scheduled maintenance for clarity

. Added 5.4.6 to Superintendent - Outage and Planning responsibilities to ensure equipment removed from service for on-line maintenance adheres to evaluation guidelines required by PS A

. Revised 6.1.3.d to expand listing for equipment important to on-line maintenance risk

. Revised 6.3 Title from "Long Range Planning" to "Three Month Work Schedule" and deleted 6.3.1 Long Range Strategic Planning due to no longer needed !n procedure (process enhancement)

. Revised 6.3.2 to have three month work schedule distributed or made available for review by PSA engineering for evaluation of risk informed configuration (process enhancement)

. Revised 6.4.1.b to have monthly work schedule available for review by PS A engineering for evaluation of risk informed configuration (process enhancement)

. Deleted 6.4.1.i due to no longer needed in procedure

. Revised 6.4.2.c to have weekly work schedule distributed or made available for review by PS A engineering for evaluation of risk informed configuration (process enhancement)

. Added 6.5.1 POD format last bullet " Risk configuration evaluation" to have this activity included in the POD report

. Added 6.5.2.b to have POD report include ..sk configuration evaluations

. Changed 6.7.1.d and 6.7.12 "two FEGs" to " multiple FEGs" to address if more than two FEGs are unavailable at a time when evaluating PSA risk Revision Summary continued on Page 2 Approvals on File FOR YOUR INFORMATION

- m, .n

VIRGINIA VPAP 2001

~

POWER REVISION 5 PAGE 3 OF 29 i

- TABLE OF CONTENTS Section Page 1.0 PURPOSE 5

0 SCOPE 5

3.0 REFERENCE / COMMITMENT DOCi1MENTS 'S 4.0 DEFINITIONS 6 5.0 RESPONSIBILITIES 7 i

6.0 INSTRUCTIONS 11

., 6.1 Organization 11 6.2 General Requirements 13 6.3 Three Month Work Schedule 13 6.4 Short Range Planning 14 6.5 Plan of the Day (POD) 17 6.6 Management Review of Work Activities 20 6.7 On Line Maintenance 22 7.0 RECORDS 27 ATI'ACHMENTS 1 Plan Of The Day Effectiveness Report - 724%4(Dec 96) 29

VIRGINIA VPAP 2001 POWER REVISION 5 PAGE 5 OF 29 1.0 PURIOSE This procedure provides requirements and guidelines for planning and scheduling maintenance -

and other work activities at the Station to maximize plant operational safety, reliability, and availability. [ Commitments 3.2.1 and 3.2.2) 2.0 SCOPE 2.1 'l ils procedure applies to Station personnel involved in planning and scheduling work activities at the Station, including contractor personnel.

2.2 This procedure addresses the planning and scheduling of the following acuitie.s:

+ Corrective, Prevent've, and Pre Determined (i.e., Planned or Repetitive) Main,tenance

+ On Line Maintenance

. Periodic Testing

. Installation of Design Change Packages 3.0 REFERENCE / COMMITMENT DOCUMENTS 3.1 References 3.1.1 INPO 83-010, Surveillance and Periodic Task Scheduling Program 3.1.2 INPO 83-010, Survaulance and Periodic Task Scheduling Program 3.1.3 INPO 85-037,I'rogram to Enhance Reliable Power Station Operation 3.1.4 INPO 85-038, Conduct of Maintenance 3.1.5 INPO MA-318, Work Planning -

3.1.6 ASNS-3000, Nuclear Safety Policy 3.1.7 VPAP-0803, Preventive Maintenance Program 3.1.8 VPAP-0815, Maintenance Rule Program 3.1.9 VPAP-1101, Periodic Testing 3.1.10 VPAP-2002, Work Requests and Work Order Tasks 3.1.11 VPAP-2004, Outage Management and Planning 3.1.12 PLAP-0001, Outage and Planning Denartment Organization, Responsibilities, and Authorities -

3.1.13 PLAP-0005, Work Order Processing 3.2 - Commitments 3.2.1 INPO Surry Assessment,1988

VIRGINIA . VPAP-2001 '

1 POWER REVISION 5 i PAGE 7 OF 29 l I

l 4.7 Preventive Maintenam.e (PM) .I Preventive Maintenance includes periodic, planned and predictive maintenance activities l which are planned and scheduled on a routine basis to prevent equipment failure (breakdown )

or malfunction), extend the life of equipment- and optimize reliability based on probability of failure versus safety and cost benefit considerations, l

4.8 Probabilistic Safety Assessment (PSA)

A quantitative assessment of the risk associated with plant operation and maintenance. The risk is measared in terms of the estimated frequency of the occurrence of different events including severe core damage. The PS A is divided into two categories, Ixvel 1 and Level 2. Level 1 includes initiating events to severe core damage. Level 2 includes core damage to off-site dose consequences.

4.9 PSA Risk Significant FEG Those FEGs that are significant contrioutors to risk as determined by PSA.

4,10 System Outage A period when a specific plant system or sub-system is unable to perform its required function.

5.0 RESPONSIBILITIES 5.1 Station Manager The Station Manager is responsible for ensuring Station planning and scheduling activities support the safe and reliable operation of the Station.

5.2 Assistant Station Manager Operations and Maintenance (O&M)

The Assistant Station Manager O&M is responsible for:

5.2.1 Ensuring planning and scheduling activities are managed and accomplished in a safe and timely manner to support the safe and reliable operation of the Station.

5.2.2 Ensuring operational and maintenance activities support approved Station schedules.

5.2.3 Approval of planned / scheduled removal of MR SSCs from service when performance criteria or goals would be exceeded. This removal may be specified on the POD.

VIRGINIA- VPAP 2001 POWER REVISION 5

. PAGE 9 OF 29 5.6 Supervisor Long Range / Daily Scheduling The Supervisor Long Range / Daily Scheduling is responsible for:

5.6.1_ Preparing and maintaining the three month, monthly, and weekly work schedules.

5.6.2 Preparing and issQg the POD.

5.7 Supervisor Daily Planning Th: Supervisor Daily Planning is responsible for:

5.7.1 Ensuring work order packages are properly planned in accordance with approved procedures.

5.7.2 Ensuring all support activities required to perform maintenance and maintenance related activities are adequately identified, prior to issuance of work to craftsmen.

VIRGINIA VPAP-2001 POWER REVISION 5 PAGE.ll OF 29 6.0 INSTRUCTIONS 6.1 Organization The organizational structure for planning and scheduling work activities at the Station includes the Management Review Team, Supervisors Planning Group, and the Outage and Planning Department.

6.1.1 Management Review Team

a. The Management Review Team is responsible for reviewing work schedules, including the Plan of the Day, to ensure that maintenance and other work activities effectively support plant operations,

b. The Management Review Team shall consist of the following personnel, or their -

appointed designee:

. Assistant Station Manager Operations and Maintenance (Chairperson)

. Superintendent Outage and Planning (Alternate Chairperson)

• Superintendent Maintenance

. Superintendent Operations

. Superintendent Radiologicall'rotection

. Superintendent Engineering *

. Superintendent Materials *

. Feaperintendent She Services *

• Optional Members 6.1.2 Supervisors Planning Group

a. The Supervisors Planning Group is responsible for identifying, reviewing, and coordinating maintenance and other work activities at the Station for review by the Management Review Team.

. _ - - - -. - - . - -.. - ~ _ . - - . - . - - - .

~

-- VIRGINIA VPAP 2001 POWER _-  ; REVISION 5 PAGE 13 OF 29  ;

E

- 6.2 ' ' General Requirements j

6.2.l! Scheduling of maintenance activities should be optimized to complete outstanding i work on an item when it is removed from service.--

6.2.2 Maintenance activities shall be ' minimized under the following situations:

a. During activities that increase risk or safety consequences (e.g., during reduced inventory, refueling operations, or risk significant equipment outages).>  ;

i

b. When materials are not in-route or on site. -

c. When optimum maintenance methods have not yet been established.'

e d. When adequate environmental controls have not yet been established.  :

e

e. When retum to service testing requirements (PMT) have not been establishea.

?

6.2.3 Safety awareness should be maximized during maintenance evolutions conducted '

during increased operating risks and On Line maintenance activities.

6.2.4 Maintenance, modification, and testing activities that have the potential to reduce decay heat removal or shutdown margins shall be performed with either the reactor vessel defueled or the maximum numbs of safety and key support systems in service.

6.3 Three Month Work Schedule The three month work schedule serves as a management tool for planning maintenance and'-

other work activities. The three month schedule serves as a general baseline for preparation of monthly work schedules.

6.3.1 'Ihe Supervisor Long Range / Daily Scheduling shall prepare the three month work {

schedule for upcoming work expected to be accomplished. The three month work schedule should include, as applicable:

. Corntive Maintenance Work Orders identified in the work control system-

. Preventive Maintenance Work Orders identified in the work control system

. Pre-Determined Maintenance Work Orders identified in the work control system

. Periodic Tests as identified on the Periodic Testing Schedule / work control system

. Plant modifications requiring major equipment / system outages

'i.

y w

VIRGINIA VPAP-2001 POWER REVISION 5 PAGE 15 OF 29

b. The Supervisor Long Range / Daily Scheduling should distribute or make available the monthly work schedule to affected department heads for review and PS A engineering for evaluation of risk informed configuration.

c. Department Heads shall ensure that the monthly work schedule is reviewed for:

• New work items and their priority

. System / equipment availability and configuratiori requiremerits to perform maintenance and maintenance related activities -

. Long lead procurement items

. Manpower resources and availability

. ALARAimpacts -

. Other Station resource requirements

. Budget concerns

d. Problems associated with the monthly schedule should be resolved with the department responsible for the item. Schedule changes shall be coordinated with the Supervisor Long Range / Daily Scheduling.

c. When necessary, the Supervisor Long Range / Daily Scheduling will convene with members of the Supervisors Planning Group to coordinate planning and scheduling issues.

f. The dupervisor Long Rar.g' Daily Scheduling shall ensure that Preventive Maintenance work items are scheduled in conjunction with equipment scheduled for periodic testing, when practical. [ Commitment 3.2.3]

g. The Supervisor Long Range / Daily Scheduling should update the monthly work schedule based on input provided by affected departments.

h. The Superintendent Outage and Planning should distribute the proposed monthly work schedule to the Management Review Team for review and discussion.

i. The Supervisor Daily Planning should initiate preparation of Work Order packages in accordance with PLAP-0005, Work Order Processing.

VIRGINIA VPAP 2001

- POWER REVISION 5 PAGE 17 OF 29 4

c. The Supervisor Long Range / Daily Scheduling shall distribute or make available?

copies of the weekly work schedule to applicable Department Heads, the Supervisor Daily Planning, and PS A engineering for evaluation of risk informed configuration,

f. The Supervisor Daily Planning shall ensure work orders identified on the weekly work schedule are planned in accordance with PLAP-0005, Work Order Processing. - -

6.5 Plan of the Day (POD)

- The Plan of the Day serves as the management tool for identifying work activi.ics to be

- performed during a specific time span. The Superintendent Outage and Plar.ning may adjust the time span, as deemed necessary.

6.5.1 POD Format

a. The 'i OD report should include the following:

. Operations Actiuties

. Electrical Craft Activities

. Mechanical Craft Activities

. Instrumentation Craft Activities 7

. NSS Construction Activities

. Management Priority Activities *

• Special Operations Work Activities *

. Engineering Activities *

. Labor Activities *

• Non Destructive Testing (NDE) Activities *

. Insulation Activities *

. Contractors Activities *

. Health Physics Activities *

• Risk configuration evaluation l

• Optional

b. Work to be performed on the POD should be denoted as day shift or evening shift.

, -. - + ,

7__._

LVIRGINIA ' , VPAP 2001

• J- POWER -- REVISION S

. PAGE 19 OF 29

f. Senior Planning Specialists shall be responsible for de aiopment, of the Electrical.  :

Mechanical,' and Instrumentation Depanment portions of the POD at North Anna -

i; and all depanmental ponions of the POD at Surryi '

~

g.- Senior Planning Specialists, and other depanment representatives responsible for .;

planning activities, are responsible for denoting HP support in the POD.

4 6.5.3 POD _ Meeting .

a. The Supervisor Long Range / Daily Scheduling shall ensure all POD related -

documentation is collected and assembled. The POD shall include:

• Work items identified on the previous POD not completed

. Work items . intified requiring work based on plant conditions or station needs -

• New work items identified from the weekly _ work schedule added to the POD L NOTE: A thorough review'of the POD by the Supervisors Planning Group may be performed prior to the POD meeting, as directed by the Assistant Station Manager O&M. When I'

this occurs, a cursory review of the POD by the Management Review Team will only be performed.

e

b. The Management Review Team should review and discuss items identified on the POD for:

. Status'of work items

. Work priorities

• System / equipment availability and configuration requirements to accomplish work activities, including review of Risk Significant train unavailability against

the MRule database pesformance criteria

. Support requirements (i.e., tagging, scaffolding, insulation, HP, etc.)

• On Line maintenance activities involving Risk Significant trains -

• Post maintenance testing activities

.

• Material and manpower restraints

. New work items identified as a result of plant conditions J

. _ . . . . . - - , - , . . _ .. . - . . _ _ .- .__ _. _m-~ . ~ . - -

~

VIRGINIA- VPAP-2001-

"  : REVISION 5-POWER.-

- PAGE 21 OF 29 -

c 1

b. The work order backlog shall be reviewed by Station and Corporate personnel 'to - i I

determine the effectiveness of the work control process. 'Ihe review should -

consider: *

• Number of backlog corrective maintenance work orders'- ,

. Age of the backlog corrective maintenance work orders -

i Reason why backlog corrective maintenance work orders are open- ,

• Ratio of safety related to non safety related corrective maintenance work orders

c. - Appropriate corrective action plans to resolve work order backlogs shall be

- developed and monitored periodically by applicable Station and Corporate q j personnel.

2 6.6.2 Review of Open Safety Related Wos k Orders p A review of all open safety related Work Orders shall be performed prior to unit start-'

4 up following a planned outage, and as required by station management, and every _90 F days (+ 25% grace period) following, to ensure that systems, equipment, and components safety functions have not been degraded or not in compliance with the -

Station's design basis. If a outage is within 'he 90 day review period for review of all' open safety related work orders, the review may be performed prior to unit start up.

Unscheduled / forced outages of 30 days duration or greater shall be considered a ,

. - planned outage in the context of this step and require review of open safety related' work orders, prior to start up.

l

a. The Outage and Planning Department shall compile an Open Safety Related Work Order Review Book that identifies open safety related Work Orders by system.

! b. The Superintendent Outage and Planning shall coordinate a review with Superintendent Operations, Superintendent Engineering / Supervisor Station Nuclear Safety to determine if any system safety functions are degraded.

c. Reviews of all open safety related work orders performed by Operations, Planning, Station Nuclear Safety, or Station Engineering shall be performed independently.

[ Commitment 3.2.4]'

E i

? '.

+ . , . . . - , ~ ~ . -...-,,,.,.,....~.,;:-,.-, - . , -.,;-_,.,, ,,a,-., , , . . , - . , _

'C VIRGINIA 1 ' VPAP-2001

, POWERL REVISION 5 -

.PAGE.23 OF 29 Ee.' Consideration is given to the possibility of complications due to weather and other

externa' effects, such as electrical distribution system stability, during the period of

- planned equipment unavailability.

6.7.2 Each vaek may include several FEG work windows. For FEGs addressed by the-On-Line maintenance matrix, see guidelines presented in 6.7.12. For FEGs not addressed by the On-Line maintenance matrix, only one PS A Risk Significant FEG for a unit should be unavailable at a time. If two or more PS A Risk Significant FEGs.for a unit (not addressed in the On-Line maintenance configuration matrix) are to be =

l unavrdlable, then:

' a. The safety impact should be ret lewed by the Supervisors Planning Group and a

- contingency plan Liv.ining compensatory actions should be developed, if.-

necessary.-

b. The approval of the Assistant Station Manager Operations and Maintenance shall be obtained.

6.7.3 FEG work windows should be scheduled to minimize the frequency of testing such that the post maintenance operability test (PMT) satisfies the normally scheduled

' periodic test (17). This should be done by scheduling the maintenance the same week as the periodic surveillance test.

6.7.4 FEG outages may be rescheduled to accommodate forced shutdowns or unplanned equipment outages.

6.7.5 -' FEG outages on PS A Risk Significant FEGs and components important to plant reliability, should not be scheduled during planned plant transients (e.g., change to

_ powerlevel).

NOTE: Assistant Station Manager O&M approvalis required for removal of equipment from

, service if performance criteria or goals will be exceeded (See 5.2.3).

6.7.6 - The length of FEG outages should be minimized by proper preplanning and

-scheduling, and governed by the necessity of the maintenance. Routine work that has no reliability benefits should be performed during periods of low risk. MRule unavailability should also be reviewed and addressed.

4 1

~ VIRGINIA VPAP-2001 POWER REVISION 5 PAGE 25 OF 29 ,

c. Planned ' activities that will result in entrance into multiple LCOs shall consider all systems, structures, and components that are out of service in order to determine the 1 overall effect on performance of safety functions.

d.' Scheduled maintenance activaies should be planned such that, to the extent -

practical, time spent in an associated LCO action is minimized. Planned work should not be scheduled to encompass more than half of the allowed LCO time .

without additional Station Management Review Team review and approval prior to -

commencement of the work.

e.; Repeated entry and exit from LCOs shall be avoided.

- 6.7.12 For those FEGs addressed by the PSA On-Line maintenance configuration matrix, the -

matrix should be used to evaluate PSA risk when multiple FEGs are unavailable at a time. Step 6.7.2 provides guidance for FEGs not addressed by the On-Line ,

maintenance configuration matrix. "Ihe following guidance should be considered when _ l-applying the On Line maintenance matrix:

3 a. The matrix specifies four FEG maintenance configuration event durations, l indicated by color:

. Green is 168 hours0.00194 days <br />0.0467 hours <br />2.777778e-4 weeks <br />6.3924e-5 months <br /> or less J

. Yellow is 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or less

. Orange is 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or less

. Red is not allowed without appmval of the Assistant Station Manager Operations and Maintenance (See 6.7.11) 4 These durations are the maximum time allowed per maintenance event in order to comply with the PSA calculations. Other Virginia Power criteria may require even o shorter maintenance event duration, and the most restrictive duration should be used (e.g. 6.7.11).

b. For FEG maintenance configurations with a red matrix window, a planned l maintenance configuration is prohibited as an initial screen. In special situations, involving short duration, a contingency plan outlining compensatory or mitigative

~

-- actions, or additional PS A evaluation, can be considered with approval by the Assistant Station Manager Operations and Maintenance.

-VIRGINIA VPAP-2001 POWER REVISION 5 PAGE 27 OF 29 7.0 RECORDS 7.1 - The following individual and packaged documents and copies of any related correspondence completed as a result of the implementation or performance of this procedure are records.

They shall be transmitted to Records Management in accordance with VPAP-1701, Records Management. Prior to transmittal to Records Management, the sender shall assure that:

. Each record is packaged when applicable

. QA program requirements have been fulfilled for Quality Assurance records .

. Each record is legible, completely filled out, and adeg iately identifiable to the item or activity involved

. Each record is stamped, initialed, signed or otherwise authenticated and dated, as required by this procedure 7.1.1 Individual Records Safety Related Work Order Review 7.1.2 Records Package None 7.2 The following documents completed as a result of the implementation of this procedure are not records and are not required to be transmitted to Records Management.

. POD

. Weekly Schedule Monthly Schedule

. Three Month Work Schedule

l .

VPAP-2001 1 -

REVISION S l PAGE 29 OF 29 A Plan Of The Day Effectiveness Oam n n=em Report VPAP 2001 - Attac hment 1 Staton Date North Anna Power Station O Surry Power Station Line items On Plan of Dey Line home on Hold Cr:ft &

1 M:nning Mer, pient seenn wriie.

Av:lleble Scheduled Completed Working Power Mate tal Operatione Condition Engineer Phyence RWP Croft Planning Miecolla neoue 6ns Mich:nical El:ctrical

. Instrument cnd Contr:I _

Tot:1 POD Ettectiveness Rate POD Effectiveness Rate . Scheduleo L ..

, Mzenanical i

, hiuctrcai instrumsnt Electrical: (instrument and Control:-  ; Mechanical 1 -

Status 30 or less Status 30 or less Status 30 or less Status 40, 42 or 48 Status 40,42 or 48 Status 40,42 or 48 Total Total Total Goal Goal Goal

, Pre-Determined Maintenance Pre Determined Maintenance Pre-Determined Maintenance Total Backlog:

e = % rue.Sc .e> l I

i i

6 Attachment 6 Significant Hazards Consideration Determination North Anna Units 1 and 2 d

1 N

5

, .c, m- -- n-

Significant Hazards Consideration Virginia Electric and Power Company (Virginia Power) proposes to change the North Anna Units 1 and 2 Technical Specifications to extend the AOT to fourteen (14) days,

-for each emergency diesel generator (EDG). The primary purpose for the extended AOT is ths performance of a preventive maintenance inspection, appropriate for diesels used for this class of standby service, which requires disassembly of the EDG, Currently this maintenance inspection is performed during refueling outages. The proposed changes permit this maintenance inspection to be performed during Modes 1 to 4 in addition to the current allowance during Modes 5 or 6.

A probabilistic safety analysis (PSA) has been performed which demonstrates that a fourteen (14) day AOT for each EDG, results in a small change in core damage frequency assuming adequate compensatory measures are in place. The compensatory measures include requirements that the other EDGs, off site power supply, and the attemate A.C. diesel (AAC DG) be operable whenever the action statement is entered.

The effect of the proposed change has been calculated to be an increase in core damage frequency of approximately 1E-6 per year from the baseline core damage frequency of 4.1E-5. Considering that credit was not taken for the AAC DG previously in the IPE nor was the- AAC DG specified in Technical Specifications the proposed changes remain bounded by the core damage frequency identified in the Individual Plant Examination.

Virginia Electric and Power Company has reviewed the proposed Technical Specifications changes against the criteria of 10 CFR 50.92 and has concluded that the changes do not pose a-significant hazards consideration. Specifically, operation of North Anna Power Station in accordance with the Technical Specifications changes will not;

a. Involve a significant increase in the probability or. consequences of an accident previously evaluated. Credit for the AAC DG was previously not tal:an nor was the AAC DG previously included in the Technical Specifications. Furthermore, 'ne probabilistic safety analysis (PSA) demonstrates that the increase in core damage frequency due to extending the EDG AOT of a fourteen day period is not significant as long as the AAC DG is operable to act as a source of emergency power-to replace the EDG. The period of time during which the EDG is unavailable is short enough to limit the impact of using th manually operated AAC DG as a replacement for the automatically operated EDG.

b. Create the possibility of a new or different kind of accident from any accident previously evaluated. The proposed Technical Specifications changes only modify the AOT of an EDG, The UFSAR accidents are aMyzed assuming that the EDG is the worst single failure. This assumption is more severe than the proposed Page 1 of 2

Technical Specifications changes which replaces the EDG with the AAC DG.

Similarly, the PSA performed to evaluate the proposed Technical Specifications changes considered all of the initiating events defined for the PSA performed for the Individual Plant Examination. No new initiators were defined as a result of a review of the PSA model. Therefore, it is concluded that no new or different kind of accident from any previously evaluated has been created.

c. The proposed Technical Specifications changes do not result in a reduction in margin of safety as defined in the basis for any Technical Specifications.. The PSA was performed to evaluate the concept of a one time outage. The results of the analyses show a small change in the core damage frequency. As described above the proposed Technical Specifications changes only modify the AOT of an EDG, Thus, operation with slightly increased EDG unavailability due to maintenance is acceptable given the operabihty of the AAC DG and the other EDG.

Virginia Electric and Power Company concludes that the activities associated with these proposed Technical Specifications changes satisfy the no significant hazards consideration criteria of 10 CFR 50.92 and, accordingly, a no significant hazards consideration finding is justified.

1 i

I l

Page 2 of 2