ML20217D703

Informs That USNRC Had Dicussions with Licensee on 990908 Application for License Amend to Relocate 18-month Standby Diesel Generator Insp Sr.Forwards Preliminary Info Submitted by Licensee Re Supplement to Application

ML20217D703
Person / Time
Site:	South Texas
Issue date:	10/07/1999
From:	Alexion T NRC (Affiliation Not Assigned)
To:	NRC (Affiliation Not Assigned)
References
TAC-MA6441, TAC-MA6442, NUDOCS 9910180098
Download: ML20217D703 (1)

Text

,- 5 October 7, 1999 MEMORANDUM TO: File FROM: . Thomas W. Alexion, Project Manager, Section 1 ORIGINAL SIGNED BY Project Directorate IV & Decommissioning Division of Licensing Project Management

SUBJECT:

DISCUSSIONS WITH LICENSEE ON ITS FUTURE SUPPLEMENT TO APPLICATION FOR RELOCATION OF THE 18-MONTH STANDBY DIESEL GENERATOR INSPECTION (TAC NOS. MA6441 AND MA6442)

' The U. S. Nuclear Regulatory Commission (NRC) staff has had discussions with the licensee on its September 8,1999, application for a license amendment to relocate the 18-month standby diesel generator inspection surveillance requirement. The licensee is planning a supplement to the application and has requested further discussions with the NRC staff.

In order to facilitate future discussions between the licensee and the staff, the licensee provided the information in the attachment. The licensee has informed me that this information is preliminary and it plans to follow-up this information with a formal submittal. The purpose of  ;

this memorandum is te place the attachment in the Public Document Room, j Docket Nos. 50-498 and 50-499

Attachment:

As stated hk k

- DISTRIBUTION:,, ,,, , , _

. Docket Files (50-498 and 50-499)d, .

l PUBLIC l PDIV-1 RF Io receive a copy of this document, l indicate "C" in the box OFFICE PDIV-% C PDIV-D/LA ,C NAME TAlexih[ CJamersonQb DATE kO / 7 /99 to / 7 /99[]

DOCUMENT NAME: G:\PDIV-1\SouthTex"as\MEMA6441.WPD OFFICIAL RECORD COPY

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Safety Evaluation In part, the A. C. Sources Specifications are provided to ensure that the Standby Diesel I

' Generators (SBDGs) are OPERABLE. As stated in the current Bases, the purpose of tly- 1 surveillance requirement is to ensure that unexpected degradation is discovered. This degradation, if discovered, would not necessarily result in the OPERABILITY of the SBDGs being compromised. An evaluation of the condition would be performed and appropriate corrective actions taken. The relocation of this requirement does not change the coutre of action j associated with the discovery of degradation.

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The relocation of the inspection requirement to the TRM has been evaluated and determined to be acceptable under 10CPR50.36(c)(2)(ii) and 10CFR50.36(c)(3). ' This change involves the relocation of a Surveillance Requirement for an existing Technical Specification Limiting Condition For Operation. The Limiting Condition for Operation in the TRM refers the reader back to the applicable Technical Specification , therefore the criteria of 10CFR50.36(c)(2)(ii) is adequately addressed. 10CFR50.36(c)(3) requires that surveillance requirements be contained in  :

the Technical Specifications. It goes on to define surveillance requirements as "... requirements relating to test, calibration, or inspections to assure that the necessary quality of systems and ,

_1 components is maintained, that facility operation will be within safety limits, and that the limiting conditions for operation will be met." The limiting conditions for operation are adequately satisfied by the remaining sur.eillance requirements within section 4.8.1.1.2; which also ensures attendant safety limits are addressed. The quality of the SBDG systems and components is better addressed by other codified requirements that identify, in a more timely manner, those conditions that qualify as unexpected degradation. These requirements are established in the Station Blackout Rule (10CFR50.63 & Regulatory Guide 1.155) and Maintenance Rule (10CPR50.65 & Regulatory Guide 1.160). STP Nuclear Operating Company has a program in place to implement these rules for the SBDGs Changes to the TRM are subject to 10CFR50.59 evaluations. The 10CFR50.59 evaluation will l ensure that changes to this requirement will not have any adverse impact on the safe opera: ion of the plant. This change is consistent with NUREG-1431, " Standard Technical Specifications Westinghouse Plants Specifications".

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