ELV-05045, Suppls 920831 Application for Amends to Licenses NPF-68 & NPF-81,amending TS to Separate LOOP ESFAS Test from 24 H Full Load Carrying Capability Test,Per Telcon W/Nrc

Suppls 920831 Application for Amends to Licenses NPF-68 & NPF-81,amending TS to Separate LOOP ESFAS Test from 24 H Full Load Carrying Capability Test,Per Telcon W/Nrc

ML20128D598
Person / Time
Site:	Vogtle
Issue date:	02/02/1993
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20128D600	List: ELV-05045, Suppls 920831 Application for Amends to Licenses NPF-68 & NPF-81,amending TS to Separate LOOP ESFAS Test from 24 H Full Load Carrying Capability Test,Per Telcon W/Nrc ML20128D636
References
ELV-05045, ELV-5045, TAC-M84474, TAC-M84475, NUDOCS 9302100184
Download: ML20128D598 (5)

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,, Georg<a Power Company l I 40 toverness Center Parkway

. Post O>tce 0o5129s 0;rmirgbam, A!abama 35201

. Teiephone 205 877 7122 C. K. McCoy - Georgia Power A

Vce Prosdert Nudear Vogtse Propct  !!m southern etectic system February 2, 1993 ELV-05045 .I

.000669 Docket Nos. 50-424 50-425 TAC-M84474 M84475 U. S. Nuclear Regulatory Commission ,

ATTN: Document Control Desk Washington, D. C. 20555 i

Gentlemen:

V0GTLE ELECTRIC GENERATING PLANT PrQ'l CST TO REVISE TECHNICAL SPECIFICATION 4.8.1.l.2.h.7 s

By letter dated August 31, 1992, (ELV-03841) Georgia. Power Company (GPC)'

, proposed to amend the Vogtle Electric Generating Plant (VEGP) . Unit I and Unit'2 Technical Specifications to separate the loss of offsite. power (LOOP) engineered safety feature actuation system (ESFAS) test (surveillance requirement (SR) 4.8.1.1.2.h.6) from the 24-hour full-load-carrying capability test- .

(SR 4.8.1.1.2.h.7). Surveillance requirements.4.8.1.1 2.h 6:and'4.8.1.1.2.h.7 would have been affected by the proposed change. As.a result of aLtelephone.

conversation with the NRC staff, GPC has agreed to revise our-pr.oposed amendment.

of August 31, 1992, as described in enclosures 1, 2,,and 3.:

Sincerely',

}hf .

C. K. McCoy' CKM/NJS-

Enclosures:

1. Basis for-Proposed ~ Change 2.10 CFR 50.92 Evaluation 3 3 Marked Up Page-080077 f ts4 930202 ph21pDock03000424

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U. S. Nuclear. Regulatory Comission

> c Request to Revise' Technical _ Specifications

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c(w): Georata Power Company '

- M;'. - W. B. Shipman Mr. M. Sheibani

-. NORMS-o V. S. Nuclear Reaulatory Commission _ .:

Mr. S. D. Ebneter, Regional Administrator.

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-Mr. D. S. Hood,- 1.icensing. Project' Manager, NRR-g.

Mr. B.. R. Bonser, -Senior, Resident Inspector,1Vogtle;

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State of Georaia+

• Mr. J. D. Tanner, Comissioner, Department .of: Natural. Resources; ,

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ENCLOSURE 1 V0GTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECH 8tCAL SPECIFICATION 4.8.1.1.2.h.7 BASIS FOR PROPOSED CHANGE proposed Chanae The Vogtle Electric Generating Plant (VEGP) Unit-1 and Unit 2 Technical' Specifications-(TS) require, in part, that the diesel generators (DGs) be tested at least once per 18 months, during shutdown, by operating the DGs-at specified loads for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (surveillance requirement-(SR) 4.8.1.1.2.h.7). Within 5 minutes after completing this 24-hour test, the DGs are-to be subjected to another test by simulating a loss of offsite power (LOOP) in conjunction with an engineered safety feature actuation system (ESFAS) test signal and verifying the loading sequence. The DG is to be operated for at least 5 minutes while' loaded with the emergency loads (SR 4.8.1.1.2.h 6)._ However, if the second test is not successfully completed, the 24-hour test does not have to be repeated. Instead, the DG may be operated at the load specified by SR 4.8.1.1.2.a.5 for .1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> or until the-DG operating temperature has stabilized, prior to reperforming the LOOP /ESFAS test.

The proposed change would remove the requirement to perform the LOOP /ESFAS test within 5 minutes after completing the 24-hour test and substitute the ,

requirement to start the-DG in accordance with SR 4.8.1.1.2.a.4 within-5 minutes  !

after the 24-hour test. In addition, if the start after.the 24-hour test was unsuccessful, footnote ## to1SR 4.8.1.1.2.h 7 would be revised to require the DG to be operated for a minimum of 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at _the load specified by SR 4.8.1.1.2.a.5 prior to repeating-the. start pursuant to SR'4.8.1.1.2.a.4. As provided-in the existing TS, the-24 hour tcst would not have-to be repeated -

simply because the. subsequent start was unsuccessful.

Basis The existing surveillance requirements are derived from Regulatory Guide 1.108, Revision-1, " Periodic _ Testing of Diesel Generator Units Used.as Onsite Electric Power Systems at Nuclear Power Plants,"'which provides guidelines for monitoring ~

DG-performance and reliability _via an assortment of periodic tests. _.The-basis for the existing requirement to perform a. LOOP /ESFAS test.within 5 minutes of' completing the 24-hour test Lis to demonstrate. hot restart capability under full-load operating temperature: conditions. However, it is' not1necessary to -

perform-the LOOP /ESFAS' test within 5= minutes _ of the 24-hour test to demonstrate the' hot _ restart- capability' of the DG.' Simply' starting _ the DG and verifying that 4 it achieves _the required voltage.and frequency within_the required time =is sufficient to ensure hot 1 restart-capability. Furthermore, if the hot'restarti subsequent to.the 24-hour test-should be; unsuccessful, requiring the DG to-be operated atethe. loads specified by SR 4.8.1.1.2 a.5 for a minimum of 2. hours prior to repeating ~the hot restart test-will provide additionalEassurance that the [XI has achieved full-load operating temperature. Therefore the proposed amendment is~ consistent withLthe. intent of Regulatory Guide.l.108.

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ENCLOSURE 1 ,

-V0GTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL. SPECIFICATION 4.8.1.1.2.h.7

. BASIS FOR: PROPOSED CHANGE-In addition, the proposed amendment would provide additional ~ flexibility for outage planning and execution. 'Under the existing requirement, the 24-hour test,-in combination.with the LOOP /ESFAS test,- must be scheduled at a time during the outage when;all of the DG emergency loads are operable and capable. of satisfying the requirements of- the LOOP /ESFAS test. Under the. terms of the proposed amendment, these surveillance tests could be scheduled: independently,

thereby-improvingfoutage scheduling and execution.-

- Finally, the' proposed amendment is. also- supported- by the April -1992' draft; Revision 3 to Regulatory-Guide-l.9, " Selection,1 Design, Qualification, Testing, ,

and Reliability of Emergency Diesel Generator. Units Used as' Class IE Onsite-Electric Power Systems at Nuclear Power Plants." 'This: guidance describes a-g " Hot Restart. Test" which simply-requires the DG to be started from full-load temperature conditions by a manual:or autostart: signal :This test?is not the: LOOP /ESFAS test currently specified by the VEGP.TS.-

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ENCLOSURE 2 V0GTLE ELECTRIC GENERATING PLANT REQUEST TO REVISE TECHNICAL SPECIFICATION 4.8.1.1.2.h.7 10 CFR 50.92 EVALUATION Pursuant to 10 CFR 50.92, GPC has evaluated the proposed amendment and has determined that operation of the facility in accordance with the proposed amendment would not involve a significant hazards consideration. The basis for this determination is as follows:

1. The proposed change does not involve a significant increase in the probability or consequences of an a:cident previously evaluated.

Separating the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test from the LOOP /ESFAS test and revising footnote ## will have no effect on the initiating events assumed for any existing accident analysis. The basis for the existing recuirement is to ensure the hot restart capability of the DGs. The propotec change in requirements will continue to demont,trate that capability, and the DGs will remain able to perform their safety function as assumed in the accident analyses. Should the hot restart test subsequent to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test fhil, the change to footnote ## will pmvide additional assurance that the DG has achieved ful' load operating temperature prior to repeating the hot restart test. Therefore, the DGs will continue to be able perform their safety function and there will be no effect on the consequences of any existing accident analyses.

2. The proposed change does not create the possibility of a new or different kind of accident from any accident previously evaluated. The change does not introduce any new eculpment into the plant or require any existing equipment to be operatec in a manner different than that for which it was designed to operate. The proposed change will continue to demonstrate the hot restart capability of the DGs. Therefore, the performance, reliability, or capability of the DGs to perform their design function will not be affected.

3. The proposed ch:nge does not involve a significant reduction in a margin of safety. The basis for the existing requirement is to ensure the hot restart capability of the DGs. The proposed change will continue to ensure that capability, thereby maintaining the margin of safety afforded by the existing surveillance requirements.

Based on the preceding analysis, GPC has determined that the proposed change to the Technical Specifications will not significantly increase the probability or consequences of an accident previously evaluated, create the possibility of a new or different kind of accident from any accident previously evaluated -or involve a significant reduction in a margin of safety. Georgia Power Company therefore concludes that the proposed change meets the requirements of 10 CFR S0.92(c) and does not involve a significant hazards consideration.

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