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Application for Amends to Licenses NPF-68 & NPF-81, Converting TSs to Improved TSs for Westinghouse Plants as Represented in NUREG-1431
	ML20082T559
Person / Time
Site:	Vogtle
Issue date:	05/01/1995
From:	Mccoy C; GEORGIA POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20082T561	List: ML20082T559;
References
	RTR-NUREG-1431 LCV-0603, LCV-603, NUDOCS 9505040080
	Download: ML20082T559 (11)
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Georgia Power Company ;

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[ 40 inverness Center Parkway J Post offce Box 1295 "I s~

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C. K. McCoy Georgia Power =

Ng*tNd May 1,1995 "*"#""*'"*'*'" '

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LCV-0603 -

Docket Nos. 50-424 50-425 2 4 a U. S. Nuclear Regulatory Commission 1 ATTN: Document Control Desk

Washington, D. C.

Gentlemen-

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VOGTLE ELECTRIC GENERATING PLANT PROPOSED CONVERSION OF THE UNIT I AND UNIT 2 =

TECHNICAL SPECIFICATIONS B ASED ON NUREG-1431 -

In accor6 tate with tSe provisions of 10 CFR 50.90, Georgia Power Company (GPC) proposes to 5 amend the Vogtle Electric Generating Plant (VEGP) Unit I and Unit 2 Technical Specifications j (TS), Appendix A to the Operating Licenses NPF-68 and NPF-81. The proposed changes i consist primadly ofa conversion of the existing VEGP TS to the improved Technical -

Specifications ihr Westinghouse plants as represented by NUREG-1431. In addition GPC =

proposes other changes beyond those that are based on NUREG-1431 as discussed in f

Attachments 1 and 2 to this letter. Attachment 1 is a listing of the proposed changes to the existing VEGP TS that are currently under review by the NRC and that have an effect on the g

chanfes proposed herein. Attachment 2 is a listing of those changes that are not currently under i review by the NRC and that go beyond those changes based on NUREG-1431.

The version of NUREG-1431 that was used to prepare this proposed license amendment was

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Revision 0 as issued September 28,1992, and as modified by NRC approved changes to the best ;

of our knowledge. The NRC approved changs are hand-marked onto the Revision 0 version 2 and identified by the associated generic " traveler" identifier. One notable exception is the -

changes that are associated with BWR-26. Due to the scope of those changes, GPC requires further time to evaluate the implementation of BWR-26 at VEGP. GPC proposes to resolve this issue during the review process. =

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U. S. Nuclear Regulatory Connaission LCV-0603 Page 2 The enclosed amendment is organized in accordance with the NUREG-1431 layout. That is the amendment is divided into chapters that correspond to the NUREG-1431 chapters. Each chapter includes five enclosures as follows.

Enclosure 1 is a markup of the existing VEGP TS associated with that NUREG chapter.

The changes to the VEGP TS are numbered.

Enclosure 2 discusses each numbered change identified in the markup of the existing VEGP TS (Enclosure 1) and identifies an appropriate evaluation pursuant to 10 CFR 50.92 for each change.

Enclosure 3 contains the evaluations pursuant to 10 CFR 50.92.

Enclosure 4 consists of a markup of the NUREG chapter. Enclosure 4 is divided into Enclosure 4A for a markup of the NUREG TS requirements (each change from the NUREG TS is numbered) and Enclosure 4B for a markup of the NUREG Bases (Bases changes are generally annotated with a category for the type ofchange). A typed version of the Enclosure 4 markups will be provided to the NRC staff on a schedule to meet the needs of the NRC staff.

Enclosure 5 discusses each deviation from the NUREG TS requirements indicated in Enclosure 4A.

In addition, the enclosed amendment includes a Criteria Application Report (CAR) that documents the application of the criteria of the NRC Final Policy Statement on Technical Specification Improvement. Please note that where the CAR or the Enclosure 1 marktps indicate that a requirement may be relocated and the target document for that requirement is indicated, GPC may elect to relocate that requirement to another licensee controlled document subject to the requirements of 10 CFR 50.59. GPC will finalize the locations for relocated requirements with NRC staff during the review process.

Finally, GPC proposes to meet with the NRC staff at their earliest convenience to discuss the organization of the submittal and answer any initial questions regarding that organization, to establish a review schedule for each chapter of the submittal, to establish lines of communication and the means of communicating requests for additional information and responses to those requests, and to establish an implementation schedule upon receipt of NRC approval of the proposed amendment.

U. S. Nuclear Regulatory Commission LCV-0603 Page 3 Mr. C. K. McCoy states that he is a vice president of Georgia Power Company and is authorized to execute this oath on behalf of Georgia Power Company and that, to the best ofhis knowledge and belief, the facts set forth in this letter and enclosures are true.

GEORGIA POWER COMPANY BY:

C. K. McCoy Sworn to and subscribed before this / day ofMay,1995.

Maju4 N b b My commission expires: Th b _ /998 Notary PulAic I ' #

CKM/NJS Attaclunents

Enclosure:

Vogtle Electric Generating Plant Unit I and 2 Conversion to the Improved Standard Technical Specifications Based on NUREG-1431 xc: Georgia Power Company Mr. J. B. Beasley, Jr.

Mr. M. Sheibani NORMS U. S. Nuclear Reenlatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood, Licensing Project Manager Mr. B. R. Bonser, Senior Resident Inspector, Vogtle State of Geornia Mr. J. D. Tanner, Commissioner, Department ofNatural Resources l

ATTACHMENT 1 PROPOSED CHANGES TO THE VEGP UNIT I AND 2 TS PRESENTLY U@EB.EEyIEW BY THE NRC The following pending proposed chango to the VFCF L' nit I and Unit 2 TS that are currently under review by the NRC are the only pencling changes f. tat affect the enclosed conversion of the VEGP TS. These proposed changes are reflected m tne enclosed submittal.

1. TS change to allow containment air lock to be open during fuel movement and core alterations - Submitted March 17,1995. See Chapter 3.9.

2. Accident monitoring TS change - Submitted March I8,1994. See Chapter 3.3.

3. TS change to revise the leak test frequency on containment purge v.lves with resilient seals -

Submitted December 27,1994. See Chapter 3.6.

4. TS change concerning standby auxiliary transformer (with power feed from GPC Plant Wilson switchyard) and performing RAT maintenance at power - Submitted January 3,1995.

5. TS change on automatic load sequencer - Submitted on December 29,1994.

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ATTACHMENT 2 PROPOSED CHANGES TO THE VEGP UNIT I AND 2 TS IN ADDITION TO CHANGES DUE TO THE CONVERSION BASED ON NUREG-1431 Note that in the following list Enclosure 2 of the referenced chapter refers to the description of the changes to the current or existing VEGP TS. Enclosure 5 refers to the description of the deviations from NUREG-1431. The chapter numbers refer tc the NUREG-1431 chapters unless otherwise noted.

Chapter 1.0

1. A definition of a Pressure and Temperature Limits Report will be incorporated into the VEGP TS in accordance with NUREG-1431. However, the NUREG definition would be revised to incorporate a reference to the nominal PORV setpoints for the cold overpres ure protection system. In addition, the references to LCOs 3.4.3 and 3.4.12 would be replaced with the words " individual specifications." See Enclosure 2, item 13 and Enclosure 5, items 5 and 6.

Chapter 2.0

1. The requirement to notify the NRC Operations Center within I hour pursuant to 10 CFR 50.72 and the preparation of an LER pursuant to 10 CFR 50.73 in the event of a safety limit violation would be deleted. See Enclosure 2, item 2, and Enclosure 5, item 1.

2. The equations for the overtemperature delta-T (OTDT) and the overpower delta-T (OPDT) functions were manipulated algebraically and editorially so as to improve their presentation and be consistent with the control board indication. See Enclosure 2, items 4, 7, 8, 9, and 10, and Chapter 3.3, Enclosure 5, item 24 under LCO 3.3.1 RTS.

Chapter 3.0 No changes were proposed that alter the current licensing basis except those necessary for the conversion to the improved standard TS.

Chapter 3.1

1. Shutdown margin requirements for Mode 2 with K, < l.0 were deleted. See Enclosure 2, items 1 and 2, and Enclosure 5, item 1.

2. NUREG-1431 PHYSICS TEST Exceptions LCOs 3.1.9 and 3.1.11 (VEGP existing Special Test Exceptions 3.10.1 and 3.10.2) are deleted. See Enclosure 2, item 1 of the markup of existing VEGP TS Chapters 3.10,3.11, and 3.12, and Enclosure 5, items 6 and 12 for Chapter 3.1.

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ATTACHMENT 2 (continued)

3. The applicability of the TS requirements for shutdown bank insertion limits was revised. See Enclosure 2, item 44, and Enclosure 5, item 9.

4. The requirement to verify the position of a nonindicating rod immediately after movement of more than 24 steps would be revised to within 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months . See Enclosure 2, item 38, and Enclosure 5, item 13.

5. An action to suspend physics testing within 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months if shutdown margin is not restored was added to the special test exception. See Enclosure 2, item 64, and Enclosure 5, item 20.

Chapter 3.2

1. The required actions and surveillance requirements for quadrant power tilt ratio would be revised as discussed in Enclosure 2, items 37, 41, and 43, and Enclosure 5, items 5, 6, 7, 8, 10,and11.

Chapter 3.3 RTS

1. Required Actions L.2 and L.3 of Condition L in proposed LCO 3.3.1, Reactor Trip System are deleted. Based on the addition of the new VEGP LCO 3.3.8, High Flux At Shutdown Alarm. This change is discussed in Enclosure 5 items 6,6a,21 and in Enclosure 2 items 16, 61, and 61a.

2. The VEGP ITS surveillances SR 3.3.1.2, SR 3.3.1.3, and SR 3.3.1.6 are revised based on correct operating practice and vendor recommendations. The associated changes are discussed in Enclosure 5 items 25,26,26a,28 and Enclosure 2 items 43a,45a, and 56.

3. Notes I and 2 to VEGP Improved Technical Specifications (ITS) Condition T are revised.

The change is discussed in Enclosure 5 item 30

4. The VEGP ITS surveillance requirements for the P-7 interlock are revised. The change is discussed in Enclosure 5 item 31.

5. The Completion Time for VEGP ITS Condition F is revised from 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months to 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months . The change is discussed in Enclosure 5 item 32.

6. The Applicable Modes or other specified conditions for the Reactor Trip System Interlocks P-7, P-8, P-9, P-10, and P-13 are revised. These changes are discussed in Enclosure 5 item 35 and Enclosure 2 item 62.

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ATTACHMENT 2 (continued)

ESFAS

7. The Loss of Voltage and Degraded Voltage function automatic starts for the AFW pumps are moved out of the ESFAS TS into the NUREG-1431 LCO 3.3.5. This change is discussed in Enclosure 5 items 9,19 and Enclosure 2 item 27.

8. The Mode of Applicability for the Semi-automatic Switchover to the Containment Sump function is revised consistent with the requirements for one train of ECCS required in Mode

4. This change is discussed in Enclosure 5 item 28 and Enclosure 2 item 53.

9. The surveillance interval for the Channel Operational Test of the RWST level Low-Low signal for Semi-Automatic Switchover to Containment Emergency Sump function is increased from monthly to quarterly. This change is discussed in Enclosure 2 item 34.

10. The surveillance interval for the Channel Operational Test of the Low RCS Tavg Function is increased from monthly to quarterly. This change is discussed in Enclosure 2 item 48.

Remainder of Chapter 3.3

11. The proposed VEGP ITS PAMS TS is revised consistent with current licensing action submitted under letter LCV-0192 on March I8,1994. This submittal is also listed in Attachment 1. These changes are discussed in Enclosure 5 ( Post Accident Monitoring Section) items 1,3, and Enclosure 2 (Accident Monitoring Instrumentation Section) items 5, 7,8,9,10,11,12, and 13.

12. The proposed VEGP ITS Loss of Power DG Start Instrumentation, LCO 3.3.5, is revised to incorporate the AFW pump start function of this instrumentation as well as the DG start function consolidating the functions performed by this instrumentation into one TS. This change is discussed in Enclosure 5 (Loss of Power DG Start Instrumentation Section) items 1,4,5,6,9,11 and Enclosure 2 (ESF Bus Loss of Power Instrumentation Section) items 4, 8, 11, and 12.

13. The current VEGP TS Note modifying the CREFS LCO Action requirement so that the B Train CREFS is preferentially started whenever a CREFS train is required to be started is deleted. This change is discussed in Enclosure 2 (Control Room Emergency Filtration Section) item 27.

14. The requirements for the Condensate Storage Tank (CST) level instrumentation in the Accident Monitoring and Remote Shutdown TS are revised consistent with the proposed CST LCO. These changes are discussed in Enclosure 2 (Remote Shutdown System Section) item 11 and Enclosure 2 (Accident Monitoring Instrumentation Section) item 24.

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ATTACHMENT 2 (continued)

Chapter 3.4

1. - The criteria for secondary side water level for an operable steam generator was revised from a 17 % of wide range to above the highest point of the steam generator U-tubes. See Enclosure 2, item 56, and Enclosure 5, item 4.

2. The lift setpoints for the RHR suction reliefvalves and the RCS vent capacity for cold -

overpressure protection have been moved to the Bases of the VEGP improved TS. See Enclosure 2, item 23, and Enclosure 5, item 13.

3. LCO 3.4.19, "RCS Loops - Test Exceptions," ofNUREG-1431 (existing VEGP TS 3/4.10.4) would be deleted. See Enclosure 2, item 1 of the markup of existing VEGP TS Chapters 3.10,3.11, and 3.12, and Chapter 3.4 Enclosure 5, item 20.

4. The surveillance interval for the pressurizer heater capacity would be revised from 92 days to 18 months. See Enclosure 2, item 18, and Enclosure 5, item 26.

5. The pressurizer safety valve lift settings would be moved to the Bases. See Enclosure 2, item 53, and Enclosure 5, item 28.

6. The Completion Time for depressurizing the RCS in the event of an inoperable Md overpressure protection system would be revised from 8 hours9.259259e-5 days 0.00222 hours 1.322751e-5 weeks 3.044e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . See Enclosure 2, item 55, and Enclosure 5, item 32.

7. The requirements for performing reactor coolant system water inventory balances would be revised as discussed in Enclosure 2, item 36, and Enclosure 5, item 33.

Chapter 3.5

1. The requirements for seal water injection flow would be revised to locate the limits for seal injection flow to the Bases. See Enclosure 2, items 35 and , and Enclosure 5, items 7 and 12.

- 2. The requirements for the emergency core cooling system in Mode 4 were revised as discussed in Enclosure 2, items 26, 34, and 38, and Enclosure 5, items 11,12,16, and 17.

Chapter 3.6

1. The Required Action and surveillance Frequency for valves with resilient seals are revised consistent with the current VEGP licensing submittal transmitted by letter LCV-0483 dated December 27,1994. This letter is listed in Attachment 1. These Changes are discussed in Enclosure 5 items 2a, 2b, and Enclosure 2 item 40.

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,, i ATTACHMENT 2 (continued)

2. ' The current allowed outage time for the Containment Spray and Cooling Systems is revised from 72 hours8.333333e-4 days 0.02 hours 1.190476e-4 weeks 2.7396e-5 months to 14 days. The proposed change is in accordance with the recommendations of WCAP-13788, VEGP Limiting Conditions for Operation Relaxation Study, September, 1993. This study used the VEGP Individual Plant Examination results to justify the .

relaxation. This change is dir;ussed in Enclosure 5 items 4, 5, and Enclosure 2 items 60 and

61. #

3. The air lock door interlock mechanism surveillance frequency is revised from the current .

VEGP frequency of 6 months to 18 months. This change is discussed in Enclosure 5 item 12 - l and Enclosure 2 item 29. !

4. An allowance to open the 14 inch purge valves for maintenance testing is added to SR 3.6.3.2. This change is discussed in Enclosure 5 item 14 and Enclosure 2 item 35a.

Chapter 3.7

1. The Condensate Storage Tank (CST), LCO 3.7.6, is revised consistent with a planned design ,

modification that will result in two 100% capacity tanks. - This change is discussed m !

Enclosure 5 items 7, 8, Sa, and Enclosure 2 items 28 and 29. ;

2. The current VEGP LCO for the Control Room Emergency Filtration System (CREFS) is L reformatted into three separate LCOs with different applicabilities and Actions. This change although not strictly consistent with NUREG-1431 does follow the precedent established in NUREG-1431 for LCOs based on " Operating and Shutdown" conditions. This change is l discussed in Enclosure 5 items 20, 21, and Enclosure 2 items 60, 60a, 63, 64, 65, and 69.

! 3. The surveillance requirement (SR 3.7.13.1) to operate the Piping Penetration Area Filtration l

and Exhaust System, LCO 3.7.13, monthly for.210 continuous hours is revised to operate for 215 minutes and the heater capacity verification is deleted. This change is discussed in Enclosure 5 item 24 and Enclosure 2 item 76.

4. The Applicability, Required Action, and Completion Time for the Atmospheric Relief Valve (ARV) LCO 3.7.4, are revised. These changes are discussed in Enclosure 5 items 32, 33, and

34. Since this is a new TS for VEGP there are no Enclosure 2 discussions.

5. A standard NUREG-1431 Note allowing separate Condition entry is added to the Main Steam Isolation Valve (MSIV) TS, LCO 3.7.2. Although NUREG-1431 does not use this note in the MSIV LCO, it is appropriate for VEGP based on plant specific design considerations. This change is discussed in Enclosure 5 item 11 and Enclosure 2 item 35.

6. The Completion Time to reduce the Power Range Neutron Flux High Trip setpoints is I

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ATTACHMENT 2 (continued) revised from the currently licensed 4 hours4.62963e-5 days 0.00111 hours 6.613757e-6 weeks 1.522e-6 months to 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months . This change is discussed in Enclosure 5 item 1 and Enclosure 2 item 3.

7. The currently licensed footnote in the CREFS LCO that requires Train B CREFS to be started whenever a CREFS train must be placed in service to comply with Actions is deleted.

This change is discussed in Enclosure 2 item 66.

8. ' A Note is added to the current VEGP specific LCO for ESF Room Coolers and Safety-Related Chiller System, LCO 3.7.14. The Note provides an exception to the LCO for surveillance testing. This change is discussed in Enclosure 2 item 84.

Chapter 3.8

1. Numerous revisions to the proposed LCO 3.8.1, AC Sources-Operating, were made to support the addition of the new Standby Auxiliary Transformer (SAT) as a unit I and 2 common offsite circuit. The SAT related changes are discussed in Enclosure 5 items la,2, 2a,3, 4, and Enclosure 2 items 4a, 9, 9a,13, and 14.

2. The Diesel Generator accelerated test frequency requirements of Table 3.8.1-1 (4.8-1) in the AC Sources-Operating LCO are relocated outside of the Technical Specifications. The

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relocation of this Table is discussed in Enclosure 5 item 6 and Enclosure 2 item 25. l

3. In the AC Sources-Shutdown LCO (3.8.2) surveillance SR 3.8.2.1, the list of LCO 3.8.1 '

l. surveillances that are not required to be performed or met in Modes 5 and 6 has been i expanded to include all the surveillances that demonstrate capabilities which are not required -

in Modes 5 and 6. This change is discussed in Enclosure 5 item 10 and Enclosure 2 item 78.

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4. A VEGP specific Note is proposed for inclusion in LCO 3.8.9, Distribution Systems-Operating. The proposed Note will allow the transfer of emergency safety loads independent of Diesel Generator operation between any one of the original preferred off-site power sources, the Reserve Auxiliary Transformers, and the new Standby Auxiliary Transformer.

This change is consistent with current licensing action in a separate VEGP. submittal (LCV-0387B) listed in Attachment 1. This change is also discussed in Enclosure 5 item 20 and

Enclosure 2 item 114.

5. The Notes prohibiting the performance of SRs 3.8.1.8 (single load rejection test), 3.8.1.9 (full I load rejection test), and SR 3.8.1.13 (24 hour2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months DG run) during Modes 1 and 2 are deleted.

l These changes are discussed in Enclosure 5 item 21 and Enclosure 2 item 38a.-

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6. Note 4 to VEGP Table 4.8-3, Performance Discharge Test Surveillance Requirements, is revised to be consistent with IEEE-450. A modified performance discharge test may be '

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I i ATTACHMENT 2 (continued) substituted for a service test at any time. This change is discussed in Enclosure 2 item 104. ,.

l Chapter 3.9

1. The Containment Penetrations LCO (3.9.4) requirement for the air lock doors is revised !

consistent with current VEGP licensing action submitted in letter LCV-0527. This letter is .

also listed in Attachment 1. This change is discussed in Enclosure 5 item 4a and Enclosure 2 item 17a'.

l Chapter 4.0 l I i

( No changes were proposed that alter the current licensing basis except those necessary for the conversion to the improved standard TS. '

Chapter 5.0

1. The Ventilation Filter Testing Program is revised consistent with the proposed change in the Plant Systems Chapter (3.7) regarding the deletion of the heater capacity test for the Piping ,

l Penetration Area Filtration and Exhaust System. This change is discussed in Enclosure 5 !

l item 10. .

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' 2. The reference to the ASTM standard in 5.5.13.c is deleted. This is discussed in Enclosure 5 item 12a. ,

3. Paragraph 5.5.5 is revised to reflect the fact that a VEGP specific list of component cyclic and transient limits to be tracked will be added to FSAR, Section 3.9. This change is discussed in Enclosure 5 item 17.

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ML20082T559

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Enclosure:

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