ML20247K489

Suppl Application for Amend to Licenses NPF-78 & NPF-81 Ts. Amend Will Revise New Program 5.5.18 to Extent That Items B,C & D Ref to LCO Action Statement & Revises Bases Insert for New Required Actions B.5.1 & B.5.2

ML20247K489
Person / Time
Site:	Vogtle
Issue date:	05/15/1998
From:	Woodard J SOUTHERN NUCLEAR OPERATING CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20247K494	List: ML20247K489 ML20247K504
References
LCV-1111-C, TAC-M96769, TAC-M96770, NUDOCS 9805220110
Download: ML20247K489 (5)

Text

I

. e ,

J. D. Woodard SoAhern Nucle:r Executive Vice President Operati;g Company. Inc.

40 Inverness Center Parkway Post Office Box 1295 Birmingham.Nabama 35201 Tel 205.992.5086 SOUTHERNk h COMPANY Energy to Serve YourWorld" May 15, 1998 LCV-lll l-C Docket Nos. 50-424 50-425 TAC Nos. M96769 M96770 U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 Ladies and Gentlemen:

VOGTLE ELECTRIC GENERATING PLANT REVISION TO REQUEST TO REVISE TECHNICAL l SPECIFICATIONS, "AC SOURCES - OPERATING" EMERGENCY DlESEL GENERATOR EXTENDED AOT REQUEST By letter dated January 22,1998, LCV-1111, Southern Nuclear Operating Company (SNC) proposed to amend the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications (TS) to extend the emergency diesel generator allowed outage time ( AOT).

The proposed amendment involved r. revision to Section 5.5 of the TS to include a new program 5.5.18, Conf ~guration Risk Management Program (CRMP). Based on comments from the NRC staff, SNC hereby proposes te revise the new program 5.5.18 to the extent that items b., c., and d.

refer to the "LCO Action Statement." The words " Action Statement" will be replaced with the ward " Condition" in four places in items b., c., and d. of new program 5.5.18.

Also based on comments from the NRC staff, SNC has revised the Bases insert for new Required Actions B.S.1 and B.S.2. The proposed wording in LCV-1111 contained the following sentences:

"If the running CTG should fail while in Condition B, any one of the remaining CTGs

must be started within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />. If one of the six CTGs cannot be started within 3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br />, l Condition C becomes applicable."

These two sentences will be deleted to prevent confusion with the gnidance that already exists in f

l 9905220110 900515 PDR ADGCK 05000424 0 0\

P PDR I

l ~

U. S. Nuclear Regulatory Commission LCV-1111-C Page 2 the "Use and Application" section of the TS.

Marked up pages from our previous submittal and new clean typed pages reflecting the changes are included for your use.

In addition, the NRC staff has requested that SNC address our conformance to section 4.3.1,

" Quality of the PRA," ofdraft Regulatory Guide DG 1065. SNC notes that the staff has asked us to address a version of DG-1065 subsequent to the version published for comment in June 1997.

Our position regarding this later version of section 4.3.1 of DG-1065 is provided as an attachment to this letter. SNC wishes to point out that the probabihstic risk analysis was provided as an informational supplement to the deterministicjustification for the proposed emergency diesel generator extended allowed outage time. None of the guidance of DG-1065 was available at the time that the original PRA was performed, and the status of DG-1065 continues to be a draft. Therefore, SNC can only describe the process that was employed in performing the PRA.

In accordance with the requirements of 10 CFR 50.92, LCV-1111 included a Significant llazards Evaluation for the proposed changes. That evaluation is not affected by the changes proposed by this submittal.

Mr. J. D. Woodard states he is Executive Vice President of SNC, is authorized to execute this oath on behalf of SNC, and to the best of his knowledge and belief, the facts set forth in this letter are true.

SOUTifERN NUCLEAR OPERATING COMPANY By:' h

'J. D. W6odard 3 Sworn to and subscribed before me' this C#1 day of drw / 1998 A &

V'-] opry Public My Com ission Expires: 7-N'N JDWhijs

~ ' "

U. S.'Nucl ar Regulitory Commission LCV-Illl-C Page 3 Attachments cc: Southern Nuclear Operating Company Mr. J. B. Beasley, Jr.

Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. L. A. Reyes, Regional Administrator Mr. D. II. JafTe, Senior Project Manager, NRR Mr. John Zeiler, Senior Resident Inspector, Vogtle

5.5'.18 ConHguration Risk Management Program The Configuration Risk Management Program (CRMP) provides a proceduralized risk-informed assessment to manage the risk associated with equipment inoperability. The program applies to technical specification structures, systems, or components for which a risk-informed allowed outage time has ben granted. The program shall include the following elements:

a. Provisions for the control and implementation of a Level 1 at power internal events PRA-informed methodology. The assessment shall be capable of evaluating the applicable plant configuration.

b. Provisions for perfc.cning an assessment prior to entering the LCO Mirn 9:'::::: for preplanned activities.

CentdH)w1

c. Provisions for performing an assessment after entering the LCO A ~i~

Swameefor unplanned entry into the LCO .^ :9 c~ _:: .

Coqcfj//pA dcAt: fit /orf

d. Provisions for assessing the need for additional actions after the discovery of additional equipment out of service conditions while in the .

LCO ' ..L........

Se~Adiflon I

e. Provisions for considering other applicable risk significant contributors such as Level 2 issues and external events, qualitatively or q quantitatively. I 1

l l

S :\VoGTLEVOGTLEXvDTECIIS PEC\ l 4 DYDGTS\14 DYD /.s2. DOC

INSERT FOR NEW REQUIRED ACTION B.S.1 AND B.5.2 B.S.1 and B12 Required Action B.5.1 provides assurance that an enhanced black-start combustion turbine generator (CTG) is functional when a DG is out of service for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Required Action B.5.1 is modified by a Note that states that it is only applicable provided that the two enhanced black-start CTGs and black-start diesel generator have a combined reliability of 2 95% based on a minimum of 20 tests per enhanced black-start CTO and quarterly testing thereafter. This quarterly testing will subject each enhanced 1

black-start CTG to a start and load-run test. The black-start diesel generator will also be tested quarterly, but separately from the enhanced black-start CTGs. Regtiired Action B.5.1 may be met by starting either of the enhanced black-start CTGs and the black-start diesel generator and verifying that they achieve steady state voltage and frequency. The black-start diesel generator may be started separately.

if a DG is to be removed from service voluntarily for greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, it may be advantageous to test an enhanced black-start CTG prior to taking the DG out of service.

In such cases where advance notice of removing a DG from service is available, Required Action B.5.1 may be perfonned up to 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> prior to entry into Condition B. In other cases, Required Action B.5.1 must be performed within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> after entry into Condition B.

If the combined reliability of the enhanced black-start CTGs has not been demonstrated or maintained 2 95%, the option of starting and running any one of the six CTGs while in Condition B is available in the form of Required Action B.S.2. In the event of preplanned maintenance that would exceed 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, any one of the six CTGs must be started prior to entry into Condition B and allowed to run for the duration of Condition B. Otherwise, any one of the six CTGs must be started within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> (and allowed to run) after entry into Condition B if the DG is to be out of service for more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. 'T2: m:M_-_;;

CTC d='d ^" "!E E C 2.. . " ; m cfi: r:xM.JTC ..=v " - _2 9' ? hcr-- %: 2.... :! - CTC., ..x:: '- _9 4'L.:'.. _ C:..dL..%

5 ::--- g Note that Required Action B.5.1 requires that one of the two enhanced black-start CTGs be started, but any one of the six CTGs could be started to satisfy Required Action B.5.2. Since a CTG is started and running while the DG is inoperable, it is not necessary that the CTG have enhanced black-start capability.

S.WOGTLE'.v0GTLE.KvDTECilS PEC\l 4 DYDGTSil 4 DYD As2. DOC