ML20153F708

Provides Summary of 980909 Meeting Held to Discuss TS & Other Regulatory Issues Re Vogtle Electric Generating Plant. List of Meeting Attendees & Copy of Presentation Slides Encl

ML20153F708
Person / Time
Site:	Vogtle
Issue date:	09/11/1998
From:	Skinner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Beasley J SOUTHERN NUCLEAR OPERATING CO.
References
NUDOCS 9809290209
Download: ML20153F708 (19)

Text

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{ l September 11, 1996 i

)

Southern Nuclear Operating Company. Inc.

I ATTN: Mr., J. B. Beasley j Vice President  !

Vogtle Electric Generating Plant j

P 0; Box-1295 a Birmingham. AL 35201-1295

SUBJECT:

MEETING

SUMMARY

- DISCUSSION OF TECHNICAL SPECIFICATION AND OTHER I REGULATORY ISSUES PERTAINING TO THE V0GTLE ELECTRIC GENERATING l

,. PLANT - DOCKET NOS. 50-424 AND 50-425

Dear Mr. Beasley:

This refers to the September 9. 1998, meeting held to discuss Technical Specification and other Regulatory Issues pertaining to the Vogtle Electric Generating Plant. I have enclosed a list of attendees and a copy of the slides that were used at the presentation, l

In accordance with Section 2.790(a) of the NRC's " Rules of Practice." Part 2.

Title 10. Code of-Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

No reply to this letter is required. However, if you have any questions concerning this matter, please contact me at 404-562-4520.

Sincerely.

(Original signed by Pierce H. Skinner)

Pierce H. Skinner, Chief Reactor Projects Branch 2 Division of Reactor Projects

[.

Docket.Nos. 50-424. 50-425 License Nos..NPF-68. NPF-81

Enclosures:

1. -List of Attendees

2. Presentation Slides l cc w/encls: (See Page 2) l' .g0095 l

l' 9809290209 990911 !

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SNC 2 cc w/encls:

J. D. Woodard Executive Vice President Southern Nuclear Operating Company. Inc.

P. O. Box 1295 Birmingham. AL 35201-1295 J. T. Gasser General Manager. Plant Vogtle Southern Nuclear Operating Company. Inc.

P. O. Box 1600 Waynesboro. GA 30830 J. A. Bailey Manager-Licensing Southern Nuclear Operating Company. Inc.

P. O. Box 1295 Birmingham. AL 35201-1295 Director. Consumers' Utility Counsel Division Governor's Office of Consumer Affairs 2M L. King. Jr. Drive Plaza Level East: Suite 356 Atlanta, GA 30334-4600 Office of Planning and Budget Room 615B 270 Washington Street. SW Atlanta. GA 30334 Office of the County Commissioner Burke County Commission Waynesboro. GA 30830 Director. Department of Natural Resources 205 Butler Street. SE. Suite 1252 Atlanta, GA 30334 Manager. Radioactive Materials Program Department of Natural Resources 4244 International Parkway Suite 114 Atlanta, GA 30354 Attorney General Law Department 132 Judicial Building Atlanta. GA 30334 cc w/encls cont'd: (See Page 3) l

__-__m_-______.

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1 SNC 3 1 l

cc w/encls: Continued Program Manager Fossil & Nuclear Operations i Oglethor:)e Power Corporation 2100 E. Exchange Place Tucker, GA 30085-1349 i i

Charles A. Patrizia. Esq. '

Paul, Hastings, Janofsky & Walker 10th Floor 1299-Pennsylvania Avenue i Washington, D. C. 20004-9500 Senior Engineer - Power Supply l Municipal Electric Authority of Georgia 1470 Riveredge Parkway NW Atlanta, GA 30328-4684 Distribution w/ encl:

L. Plisco. Rll P.. Skinner RII ,

M. Ernstes, RII '

D. Jaffe, NRR PUBLIC NRC Senhr Resident Inspector U.S. Nuc. ear Regulatory Commission 8805 Rivr.r Road Waynesboro, GA 30830 i

0FFICE- All:0RP -

SIGNATURE QM; V -

NAE BLNothrock:da i DATE 9/JO /98 9/ /98 9/ /98 9/ /98 9/ /98 9/ /98 9/ /98 GPY7 (YES) MD YES NO YES ND YES No YES ND YES NO YES NO OFFI M L RECORD CDPY DGQ2EENT NAME: C:\WOGTLE\MGTMEET.Stal l

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l list of Attendees i 1 i l

NRC Attendees W. Beckner. Chief. Technical Specifications Branch. Office of Nuclear Reactor Regulation (NRR) l H. Berkow. Director. Project Directorate II-I. Division of Reactor Projects  !

I/II. NRR N. Gilles. Sr. Operations Engineer. Technical Specifications Branch. NRR B. Holbrook. Sr. Project Eng Meer. Reactor Projects Branch 2. Division of Reactor Projects (DRP)

D.. Jaffe, Project Manager. Vogtle Electric Generatir,g Plant. NRR J. Luehman Sr. Reactor Engineer. Technical Specifications Branch. NRR J. Johnson. Deputy Regional Administrator l V. McCree. Deputy Director. Division of Reactor Safety (DRS)

L. Plisco. Director. Division of Reactor Projects C. Rapp. Project Engineer. Reactor Projects Branch 2. DRP W. Rogers. Sr. Reactor Analyst, DRS K. O'Donohue. Resident Inspector. Vogtle Electric Generating Plant. DRP P. Skinner Chief. Reactor Projects Branch 2. DRP J. Zeiler. Sr. Resident Inspector. Vogtle Electric Generating Plant. DRP Southern Nuclear Ooeratino Comoanv. Inc. (SNC) Attendees J. Bailey, Manager. Licensing. Southern Nuclear Operating Company. Inc.

L. Ward Manager. Nuclear Engineering and Licensing. Vogtle Electric Generating Plant (VEGP)

J. Stringfellow. Project Engineer. VEGP B. Beasley, Vice-President. VEGP M. Sheibani. Supervisor Nuclear Safety and Compliance. VEGP G. Frederick. Assistant General Manager. Plant Support. VEGP i

l I Enclosure 1

NRC MEETING September 9,1998 Introduction / Barnie Beasley Organizational Changes TS/ Corrective Actions George Frederick TS Bases / Interpretations Jack Stringfellow Operability / Maintenance Lewis Ward i

)

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Enclosure 2 I

VOGTLE ELECTRIC GENERATING PLANT JULY 1998 _

ACTUAL: 885 GENERAL MANAGER t F

Jeff T. Gasser SECRETARY, SR Melba Kicklighter ,

i R -. .:L : 'ti35mm. .

- AS GEN MGR 1' SRO SCHOOL

• 9 ASST GEN MGR 1 INPO LOANED PLT SUPPORT ,

II Paul Burwinkel O&

PLT OPERATIONS EMPLOYEE- Paul Rushton ,

^ h,s Tony Parton ompson j

Steve H. Chesnut .T a s w ~~n a.w av, ,. ;w ,,,,,m d

3 , w 4 - ,

James Williams Christopher Wright i,

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1 SECRETARY, SR SECRETARY, SR Gloria Walker Cynthia Brady a

k GR U  ? MGR ENGR  ?

.j MGR MAINTENANCE ADMINISTRATION - -- SUPPORT MGR OPERATIONS 1 Ken Holmes Curtis Stinespring Bill Burmeister ,

George Frederick V

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s r 1. &

MGR PLT TRNG MGR PLT MODS MGR OUTAGE & 1 MGR HP & & MNT SUPPORT CHEMISTRY & EMER PREP PLANNING i --

Indira Kochery Bob Brown Melvin Griffis Jim Swartzwelder i 2

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• schoolstartsin August 1998 4

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USE OF TECHNIC.AL SPECIFICATION BASES

- Recent conversations with NRC staff have introduced an element of confusion within SNC with regard to the proper role of the TS Bases and TS compliance.

- Specifically, we were told that the Bases cannot be used to address TS compliance (because the Bases is our document and we can change it under 10 CFR 50.59), and the NRC does not review and approve TS Bases.

- It is our hope to clarify with this discussion that the above statements were made in the context that the Bases should not represent a potential conflict with the TS requirements but rather they should facilitate proper interpretation and application of TS requirements.

- To this extent, the Bases are essential for ensuring compliance with the TS.

b e

USE OF TECHNICAL SPECIFICATION BASES

- Examples where Bases are used to address TS compliance:

- Recent VEGP TS amendments 101 and 79, dated June I,1998.

- Compliance with OPDT and OTDT gain and reference value inequalities (TS Table 3.3.1-

!, Notes I and 2).

Airlock door / bulkhead (LCO 3.6.2)

- Bases revised to clarify that bulkhead is equivalent to door provided that other bulkhead / door is OPERABLE.

- In general, LCO descriptions in the Bases are used to define the scope of the LCO requirements - what exactly is required to be OPERABLE.

- Examples where NRC has reviewed and approved Bases:

- In September 1992, the NRC issued Revision 0 to NUREG-1431 with associated Bases. In April 1995, Revision I was issued with corresponding Bases. liach and every Technical Specification Task Force (TSTF) traveler that involves a Bases change (aside from the editorials) undergoes NRC review.

USE OF TECHNICAL SPECIFICATION BASES

- Examples where NRC has reviewed and approved Bases (continued):

The current VEGP TS Bases (based on NUREG-1431) were reviewed and approved by the NRC. The following is an excerpt from the SER for the VEGP improved TS:

- "The STS (Standard Technical Specifications) and associated Bases reflect the results of a detailed review of the application of the criteria in the interim policy statement to generic system functions. .... Accordingly, the STS Bases offer an abundance of generic information regarding the extent to which the STS present requirements which are necessary to protect the public health and safety."

- The Bases Control Program requires NRC review and approval of Bases changes that are associated with TS changes.

- The Bases Control Program restricts implementation of Bases changes without prior NRC approval to those changes that do not involve an unreviewed safety question as delined by 10 CI R 50.59.

- Recent NRC approved amendments to the VEGP TS.

USE OF TECHNICAL SPECIFICATION BASES

- In January 1988, the use of the TS Bases was identified to the NRC as a key implementation issue with respect to the development of the improved standard TS.

- Mr. Murley of the NRC responded with the following:

- "TS Bases will provide infonnation to facilitate proper interpretation and application of I S requirements. Bases are also used for determining the purpose of existing requirements when changes to the TS are being considered. In short, Bases provide the technical underpinning for TS requirements. Any change to this technical underpinning that would influence the way the requirement might be interpreted or applied should be subject to prior staff approval because it would, in elrect, be a 'l S change. Ilowever, changes that do not crode this technical underpinning should not require staff approval."

- The Bases should never be in conflict with or override the TS requirements.

Nevertheless, the Bases are essential for proper interpretation and application of TS requirements, and therefore, TS compliance.

1 OPERABILITY OF SYSTEMS, STRUCTURES AND COMPONENTS DURING PREPLANNED NIAINTENANCE/ MODIFICATIONS I

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Reason for Discussing This Toijic ,

e Recent Vogtle issue: fliilure of'a component to meet seismic requirements _was equated with inoperability of the component or system.

. Similar questions regularly arise due to temporary degradation of design features related to missile protection, EQ, flooding, high energy line break, fire protection, etc.

. Vogtle uses several methods of treating these temporary conditions, which will be discussed.

. Rigorous treatment of these temporary conditions as alrecting equipment operability will adversely alTect the ability to perform maintenance and modifications, and could impact plant safety and reliability.

}

Historical Treatment

. Temporary reduction of seismic capability that, by itself does not render the equipment incapable of perfbrming its intended function has not generally been treated as an LCO condition for the component.

Examples: . Removal of a snubber-TRM specifically allows this for 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />.

. Removal of card clamps during card replacement.

. Removal of battery rack seismic rail fbr cell replacement.

. Similarly. other temporary conditions necessary to perfbrm maintenance and modifications have not neen treated as LCO conditions fbr the associated equipment:

1'.xamples:

• Itcinoval ol'lXi exliaust stack inissile l>arrier li>r niodification.

. Opening ofIIEl B and watertight doors to access equipment.

. Removal of floor plugs for filter access

. Excedence of replacement interval for EQ equipment

. If appropriate, engineering evaluations and/or 10 CFR 50.59 reviews are perfbrme for these temporary conditions

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f Recent Examples

. Battery rack seismic rail removal during replacement cell.

- Pre-planned, engineering evaluation, procedure with 50.59

. DG missile barrier removal during exhaust stack modification. ,

- Pre-planned, engineering evaluation as part ol' design change package with 50.59

• Routing ol' hoses through IIEl.Il doors l'or spray additive tank draining.

- Pre-planned, engineering evaluation t

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Status

• Continue to apply G.L. 91-18 guidance, where appropriate, to allow operation with degraded conditions, even when the degraded conditions has been created as pa the maintenance or modification.

. 1 or pre-planned work, continue to apply engineering evaluations as appropriate.

. 17 0llow NEI/NRC elTorts on development of risk-informed approach to evaluating reduced seismic loads under temporary conditions.

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Failure to Correctly Identify TS Limiting Condition for Operation (LCO)

Categorically the several violations or events represent different degrees of safety significance:

, - Those involving compliance with plant procedures.

- Those involving instances where all applicable LCO's were not properly identified.

- Those instances involving a failure to comply with applicable T/S LCO's.

Determine Causes

- Licensed Operator knowledge of the Improved Technical Specification (ITS). Some Operators may rely on their knowledge of TS.  !

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- Inadequate procedure / guidance to control Mode changes i

and LCO entry and exit.

- A lack of supervisory follow-up to ensure operator ,

compliance.

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Corrective Action Plan 1

- A review of all violations and events since January 1997 ,

a was performed.

- Corrective actions were developed to address these events  ;

using a " barrier" defense. i

Corrective Action Plan

- Key elements of the plan based on root causes include:

Additional licensed operator training in 1998 and all of 1999 on the content and application of the ITS.

Enhancing the Unit Operating Procedures and surveillance procedures so that LCO entry and exit conditions are more clearly and completely controlled.

Developing expectations and monitoring licensed operator implementation and application of the TS.