ML052000053

Request for Additional Information, Surveillance Test Interval Extensions for Components of Reactor Protection System

ML052000053
Person / Time
Site:	Vogtle
Issue date:	07/26/2005
From:	Martin R NRC/NRR/DLPM/LPD2
To:	Grissette D Southern Nuclear Operating Co
Martin R, NRR/DLPM, 415-1493
References
TAC MC5863, TAC MC5864
Download: ML052000053 (5)

Text

July 26, 2005 Mr. D. E. Grissette Vice President Southern Nuclear Operating Company, Inc.

P.O. Box 1295 Birmingham, AL 35201-1295

SUBJECT:

VOGTLE ELECTRIC GENERATING PLANT, UNITS 1 AND 2 RE:

REQUEST FOR SURVEILLANCE TEST INTERVAL EXTENSIONS FOR COMPONENTS OF THE REACTOR PROTECTION SYSTEM (TAC NOS. MC5863 AND MC5864)

Dear Mr. Grissette:

By letter dated January 27, 2005, you applied for an amendment to the Facility Operating License Nos. NFP-68 and NFP-81 for the Vogtle Electric Generating Station, Units 1 and 2. The proposed change would modify the facility technical specifications (TSs) by extending the surviellance test intervals for components of the reactor protection system. The Nuclear Regulatory Commission (NRC) staff has identified a need for additional information as set forth in the Enclosure. We discussed this request with your staff on July 13, 2005. We request that this information be provided by September 30, 2005, to support the timely continuation of our review.

Sincerely,

/RA/

Robert E. Martin, Sr. Project Manager, Section 1 Project Directorate II Division of Licensing Project Management Office of Nuclear Reactor Regulation Docket Nos. 50-424 and 50-425

Enclosure:

As stated cc w/encl: See next page

ML052000053 NRR-106 OFFICE PDII-1/PM PDII-1/PM SPSP/SC EEIB/SC PDII-1/LA PDII-1/SC NAME CGratton RMartin MRubin AHowe CHawes EMarinos DATE 07/ 19 /05 07/ 21 /05 07/ 21 /05 07/ 25 /05 07/ 19 /05 07/ 26 /05 Request for Additional Information VEGP Request for Surveillance Test Interval Extensions for Components of the Reactor Protection System 1.0 For Condition 2 on page of E1A-12 of the licensees submittal, dated January 27, 2005, (submittal), the licensee stated that the recommended Tier 2 restrictions will be incorporated into the work planning procedures and the Tier 3 requirements are addressed through the normal work planning process consistent with the requirements of Title 10 of the Code of Federal Regulations (10 CFR) Part 50.65, Requirements for monitoring the effectiveness of maintenance at nuclear power plants, Section (a)(4).

1. Page E1A-12 of the submittal states that the Tier 3 requirements are addressed through the normal work planning process consistent with the requirements of 10 CFR 50.65(a)(4). Provide a discussion on the applicability of the Vogtle Electric Generating Plant (VEGP) 10 CFR 50.65(a)(4) configuration risk management program (CRMP)-based program regarding whether it meets the additions and clarifications provided in Regulatory Guide (RG) 1.177, An Approach for Plant-Specific, Risk-Informed Decision Making: Technical Specifications, Section 2.3.7.2, Key Components 1 through 4, for CRMP programs that implement Section a(4) of 10 CFR 50.65(a)(4).

2. Identify the manner in which VEGP programs will address the following restrictions identified in the Nuclear Regulatory Commission (NRC) staffs approval of the Westinghouse Commercial Atomic Power (WCAP)-15376 report, Risk-Informed Assessment of the RTS and ESFAS Surveillance Test Intervals and Reactor Trip Breaker Test and Completion Times. Confirm that the following Tier 2 restrictions as identified by WCAP-15376 remain bounding for the plant specific implementation at VEGP.

• Activities that could degrade the availability of the auxiliary feedwater system, reactor coolant system pressure relief (pressurizer power-operated relief valves and safety valves), AMSAC, or turbine trip should not be scheduled when a reactor trip breaker (RTB) is out of service.

• Activities that could degrade other components of the reactor protection system, including master relays or slave relays and activities that cause analog channels to be unavailable should not be scheduled when a logic cabinet is unavailable.

• Activities on electrical systems that support the systems or functions listed in the first two bullets should not be scheduled when an RTB is unavailable.

2.0 Provide a discussion on the following aspects of probabilistic risk assessment (PRA) quality as applicable to the VEGP PRA.

1. Whether, the plant-specific PRA reflects the as-built, as-operated plant.

Enclosure

2. Applicable PRA updates conducted since completion of individual plant examination (IPE) and individual plant examination of external events (IPEEE) and the status of any improvements identified by the IPE and IPEEE.

3. Conclusions of the peer review including any facts and observations (A and B) applicable to the proposed extended surveillance test interval (STI) and completion times (CTs) and their resolution. If not resolved, provide justification for acceptability (e.g., sensitivity studies showing negligible impact). Indicate the PRA revision that underwent peer review and the PRA revision used in this application.

4. Reference PRA quality assurance programs/procedures, including expected PRA revision schedules.

5. PRA adequacy and completeness with respect to evaluating the proposed STI and CT extensions.

6. Plant design or operational modifications not reflected in the PRA revision used in this application that are related to or could impact this application. Justify the acceptability of not including these modifications in the PRA as part of this application.

3.0 Provide an evaluation of external events risk impact including, seismic, fire, and external floods/high wind risk with respect to the proposed CT and STI extensions.

4.0 Provide an evaluation of cumulative risk impact including previous TS changes per RG 1.174, An Approach for Using Probabilistic Risk Assessment in Risk-Informed Decisions on Plant-Specific Changes to the Current Licensing Basis, Section 3.3.2 guidance.

5.0 Regarding the Additional Condition on page E1A14 of the submittal, the NRC staff requires that each plant review its setpoint calculation methodology and assumptions to determine the impact of extending the STI of the COT from 92 to 184 days. Please address in detail the results of the licensees review of the setpoint calculation methodology and assumptions.

Vogtle Electric Generating Plant, Units 1 & 2 cc:

Mr. N. J. Stringfellow Mr. Harold Reheis, Director Manager, Licensing Department of Natural Resources Southern Nuclear Operating Company, Inc. 205 Butler Street, SE, Suite 1252 P.O. Box 1295 Atlanta, GA 30334 Birmingham, AL 35201-1295 Attorney General Mr. Skip Kitchens, General Manager Law Department Vogtle Electric Generating Plant 132 Judicial Building Southern Nuclear Operating Company, Inc. Atlanta, GA 30334 P.O. Box 1600 Waynesboro, GA 30830 Mr. Laurence Bergen Oglethorpe Power Corporation Mr. Jeffrey T. Gasser 2100 East Exchange Place Executive Vice President P.O. Box 1349 Southern Nuclear Operating Company, Inc. Tucker, GA 30085-1349 P.O. Box 1295 Birmingham, AL 35201-1295 Arthur H. Domby, Esquire Troutman Sanders Mr. Steven M. Jackson NationsBank Plaza Senior Engineer - Power Supply 600 Peachtree Street, NE Municipal Electric Authority of Georgia Suite 5200 1470 Riveredge Parkway, NW Atlanta, GA 30308-2216 Atlanta, GA 30328-4684 Resident Inspector Mr. Reece McAlister Vogtle Plant Executive Secretary 8805 River Road Georgia Public Service Commission Waynesboro, GA 30830 244 Washington St., SW Atlanta, GA 30334 Office of the County Commissioner Burke County Commission Waynesboro, GA 30830