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Application for Amends to Licenses NPF-68 & NPF-81,revising TS by Adding Requirements for Load Sequencer
	ML20127N766
Person / Time
Site:	Vogtle
Issue date:	01/22/1993
From:	Mccoy C; GEORGIA POWER CO.
To:	; NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20127N769	List: ELV-03945, Application for Amends to Licenses NPF-68 & NPF-81,revising TS by Adding Requirements for Load Sequencer; ML20127N788;
References
	ELV-03945, ELV-3945, NUDOCS 9302010068
	Download: ML20127N766 (6)
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January 22, 1993 ELV-03945 Docket Nos. 50-424 50-425 U.S. Nuclear Regulatory Comminsion ATTI.: Document Control Desk Washington, D.C. 20555 Gentlemen VOOTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECllNICAL SPECIFICATIONS hQDITION OF LOAD SEQ]).El[CER SPECIU.CATlQ.li In eccordance with the provisions of 10 CFR 50.90 and 10 CFR 50.59, Georgia Power Company (GPC) hereby proposes to amend the Vogtle Electric Generating Plant (VEGP) Unit 1 and Unit 2 Technical Specifications, Appendix A to Operating Licenses NPF-68 and NPF-81.

a This amendment modifies the Technical Specifications by adding requirements for the load sequencer. The addition of this item )

will clarify the actions to be taken if a sequencer is temporarily out of service and avoid the possibility af an unnecessary plant shutdown due to specification 3.0.3.

Georgia Power CoDpany requests approval of this change by the end of July 1993.

The proposed changes and the bases for the changes are described in enclosure 1 to this letter. Enclosure 2 provides an evaluation pursuant to 10 CPR 50.92 showing that the proposed changes do not involve significant hazards considerations. Instructions for incorporation of the proposed changes into the Technical Specifications and a markup of the affected pages are provided in enclosure 3.

In accordance with 10 CPR 50.91 the designated state official will be sent a copy of this letter and all enclosures.

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l (In Hl'ist h 4\'Cl L ki U. S. 11uclear Regulatory Commission EIN-0 3 9 4 5 Page 2 Mr. C. K. McCoy states that he is a vice pronident of Georgia Power Company and la authorized to executo thin oath on behalf of Georgia Power Company and that, to the best of his knowledge and belief, the facts set forth in this letter and enclosurca are true.

Georgia Power Company

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By: .

C. K. McCoy Sworn to and subscribed before me thin 2_ 2CD day of .. 1M N , 1993.

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Notary Public CKM/HWM/gmb Enclocures:

1. Basis For Proposed Change

2. 10 CFR 50.92 Evaluation 3 Instructions for Incorporation ar.d Revised Pages c(w): fg;2r9hFowC.t_C.92. dimly Mr. W. B. Shipman Mr. M. Sheibani NORMS L f?a_lhtq10M Re9Rliltpry Coln.p.ipfdg.0 Mr. S. D. Ebneter, Regional Administrator Mr. D. S. Hood,-Licensing Project Manager, NRR Mr. B. R. Donser, Senior Resident Inspector, Vogtle

d. tate Jf GegIgla Mr. J. D. Tanner, Commissioner, Dept. of Natural Resources am

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ENCLOSURE 1 !

VOGTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATIONS ,

, ADDITION OF LOAD SEQUENCER DAS.L1.JOR PROPOSED CHANGE -

PIORO.WMLChanga The rovinion will add the following requiremont to limiting l condition fot operation (LCO) 3.8.1.11

" c. Automatic load soyooncors for train A and B" The ossociated action statomont will be amended by adding the following requiremontt.

' " g. with one automatic load sequencer inoperable, rentore the inoperablo load sequencor to OPERABLE status within 12 hours1.388889e-4 days 0.00333 hours 1.984127e-5 weeks 4.566e-6 months .

vr be in at least HOT STANDBi within the next 6 hours6.944444e-5 days 0.00167 hours 9.920635e-6 weeks 2.283e-6 months and in l COLD SHUTDOWN within the following 30 hours3.472222e-4 days 0.00833 hours 4.960317e-5 weeks 1.1415e-5 months ." :

The following conton00 will he added to action statements 14, 20, and 23 of table 3.3-2: '

"(With charnols inoperable due to an inoperable load sequencer, apply the ACTION statomont of specification 3.8.1.1 for an inoperablo load sequencor.)"

The following paragraph will be inserted into the bases section fc r specification 3.8.1.1:

"The ACTION timos specified for an inoperable automatic load ,

sequencer are based on the timos allowed when a combination I of one diesel generator and one offsito circuit lu- .

inoperable. This conservatively addressen any consequential ;

offects of an inoperable load sequencer on other engineered safety features and avoids having to evaluato-the ACTION based on tablo 3.3-2." t HAD1H

Although engineered safety-features are sequenced into operatlon ,

through the load sequencor following an accident,-the-Tochnical Specifications do not have a specific specification for the load sequencer. Surveillanco and operability requirements are covered by the specifications for engineered safety features (ESP) ;

instrumentation and electrical power systems. This loavos a '

question concerning the appropriate actions to take in=the event that a load sequencer must be taken out of service or becomes i inoperable. Therefore, an additional specification is being .

, proposed that will clearly delineate the appropriate actions. This will reduce the possibility for a Technical Specification-

, application error.

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1 ENCLOSURE 1 (CollTINUED)

VOGTLE ELECTRIC GENERATING PLANT i

REQUEST TO REVISE TEC11NICAL SPECIFICATIONS I

ADDITION OF LOAD SEQUEllCER BASIS FOR PROPQSED CHANGE The proposed specification is contained in enclosure 3. It is not a result of any plant changes in dealgn or operation. Enclosure 2 provides an evaluation to demonstrate that 'he proposed specification will not involve any significant hazards considerations.

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4 E!1 CLOSURE ?

VOGTLE ELECTRIC GENERATING PLANT 4

REQUEST TO REVISE TECl!NICAL SPECIPICATIONS ADDITION OF LOAD SEQUENCER 10 CPR 50.92 EVA1J)ATJpf,{

Purauant to 10 CPR 50.92, Georgia Power Conpany has evaluated the I proposed revision to the Technical Specifications and has determined that operation of the facility in accordance with the proposed ,

amendment would not involve any significant hazards considerations. j D11Eh9t93nd j The load sequencer automatically starts the diesel and connects class l 1E loads to the 4.16-kV bus following an accident or a loss of i effsite power (LOSP). In the event of an accident the diesel -l generator for each train of emergency power la started but _ is not i connected to the 4.16-kV bus unless an undervoltage condition occurs. l The instrumentation used to actuate the engineered safety features is i identified in table 3.3-2 of the Technical Specifications. The load i sequencer is not specifically listed in thic tabic although its I operability may be implied. Currently, if the load sequencor is !

inoperable it is necessary to evaluate the appropriate actions based j on table 3.3-2 for inoperable engineered safety features actuation system instrumentation. Current plant practice is to refer to action j i statements 14, 20 and 23. The addition of a sentence in thene action '

statements that refers to the action statement of specification >

3.8.1.1 will help avoid confusion concerning the appropriate action when a sequencer is inoperable. The purposes of the addition of this

specification are to identify the appropriate action to take when a sequencer is inoperable, to avoid the applicatJon of specification ,

3.0.3 and to avoid having to evaluate the offacts of an inoperable '

sequencer on instrumentation listed in table 3.3-2.

Analy.dE This additfon to the Technical Specifications is not the result of ,

any design change or change in operating procedures or requirements.

Specific surveillance requirements for the load sequencers are already included in Specification 4.8.1.1.2.h.4, 6,_ and 12.

Therefore, it is not necessary to provide an additional surveillance requirament for the new limiting condition for operation _(LCO) and i action statement. The change will eliminate any confusion that night

exist concerning the effects of an inoperable load sequencer on instrumentation listed in table 3.3-2. When a load sequencer is ;

inoperabic the safety related loads for the train served by that '

, sequencer may not load as assumed in the safety analyses, even if the ,

preferred offsite power or the onsite power sources are available for that train. The Technical Specifications already contain appropriate 1

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EtiCLOSURE 2 (CollTillUED)

! VCGTLE ELECTRIC GEllERATIl1G PLAllT REQUEST TO REVISE T2Cll!11 CAL SPECIFICATIOlis '

! ADDITIOli OP LOAD SEQUEllCER

, .ULCDLM.dLIYldBAIl011 l 1 l actions to take in the event of the unavailability of both the :

proforred of f aite and onsito power sources for a train. The severity of such a condition will be greater than the offects of an inoperablo ;

sequencer. Therefore, the proponed 12-hour action timo for an inoperablo nequencoc was conservatively choson to be the same au when an offnite oower source and diesel generator are inoperable. This .

l assures tha't the loval of protection provided by the Technical '

Specifications is not reduced by the addition of this requirement.

The proposed LCO and actior, statements are consistent with the j proposed taquirements in llUREG-1431, reviulon 0, the now standard [

l Technical Specifications for Westinghouno plants. Although the load sequencer is not required for automatically connecting loads to the 4.16-kV buses during 14cdos 5 and C, it doen function to automatically start the diesel generator on a lost, of of frito power. This f unction ;

is required f or dional generator operability; therefore, no specific l coquencor LCO is needed for 14odos 5 an-1 6. -

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l CDn9hWL9B Based on the above considerations, CPC has concluded ?.he following ,

concerning 10 CPR 50.92.

I 1.. The proposed revision to the Technical Specifications doca not .

l Involve a significant increano in the probability or consequences .

l of an accident previously evaluated because the action to be taken when a load sequencer is inoperable is consistent with an already specificed condition that is more signficant than an -

inoperabic sequencer, namely, the loss of an entire train of ,

emorgency power. '

2. The proposed revision to the Technical Specifications does not !

create the possibility of a new or d3 fferent kind of accident ,

from any accident previously evaluated because it does not involve any chango to the dcaign, operation, or performance of the load nequencer. It only serves to clonrly identify the.

l appropriato conservative renponse to an inoperable load l sequencor.

! L l 3. The proposed addition to the Technical Specifications does not !

involve a significant reduction in a margin of safety because the proposed action to take when a sequencer is not operable is the ;

same as the action. already required by the Technical Specifications when no power is available to the entire train.

Based upon the preceding information, it has been determined that the ,

proposed "echnical Specifications revision does not involve a ,

l significant hazards consideration as defined by 10 CFR 50.92(C).

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ELV-03945, Application for Amends to Licenses NPF-68 & NPF-81,revising TS by Adding Requirements for Load Sequencer

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