ML20005F838

Application for Amends to Licenses DPR-57 & NPF-5,revising Tech Specs Re Testing of Emergency Diesel Generators

ML20005F838
Person / Time
Site:	Hatch
Issue date:	01/10/1990
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML20005F839	List: ML20005F838 ML20005F842
References
RTR-REGGD-01.009, RTR-REGGD-01.108, RTR-REGGD-1.009, RTR-REGGD-1.108 HL-790, NUDOCS 9001170307
Download: ML20005F838 (23)

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4 I#" i GeorD'a Powr Compa ny 333 Piedmont Aeous i- ' Atlada, ocarg a 30300 4' ' ldephone 404 L26 3196 M'ahng Address 4 n neu Ceri er Po4.way

= Damingha4 Alabama 35?01

Tetephone 205 BGB 5581 pc aeven acc sysfKi W. G Ha6rston, Ill :

Senge vice President Nuclear Operations

HL-790

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January 10, 1990

.U.S. Nuclear Regulatory Commission- -4 ATTN: Document Control Desk:

Hashington, D.C.- 20555 PLANT-HATCH:- UNITSEl, 2 NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 .

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS

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. Gentlemen:

In accordance. with the provisions of '10 CFR 50.90, asi required by 10 CFR 50.59(c)(1), Georgia Power ' Company- (GPC) hereby proposes changes to '

W the Plant Hatch Units 1 and 2 Technical. Specifications (TS), Appendix A.

to Operating Licenses DPR-57 and NPF-5.

The. proposed changes involve ' a revision of L the.' Plani! Hatch Units? -l i and 2 TS relative to'the testing of Emergency Diesel Generators--(EDGs)'.

During . the ' Safety' System Functional ' Inspection (SSFI) of.- the EDGs, GPC committed to perform a1 comparison ?of the Technical Specifications (TS) and NRC Regulatory Guide (RG) 1.108 to. evaluate ; discrepancies. and=-

revise the' TS, if necessary. He, also committed :to' revise. the TS 'to require additional fuel storage' capacity. Proposed _ changes. include the ~ j following: ,

1. Voltage- and frequency 'acceptanceJcriteria-have been added ~ for EDG-testing consistent with o BHR/4- Standard Technical- Specifications (STS), RG 1.108, andlRG l'.9.

2. Several new Surveillance Requirements- (SRs): have been .'added ' to the Unitr1 TS, primarily the 18-month SRs currently in' the Unit 2; j

.TS. The. proposed changes" will 'make both Unit 1 - and' Unit 2 :TS consistent with ' RG l'.108,- even ~ though -. Unit 1 -is not officially committed to- this RG. New Unit 1 requirements : include a. 24-hour load ' test and a full and partial load . rejection test . every 18-months. '

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Georgb Power l

U.5.NuclearRegulatoryCommission January 10, 1990 Page Two

3. Plant Hatch has a swing diesel- which is required to' be operable for both units._ Surveillance testing -is perform 6d and tracked diesel-being tested twice asloften.for Plant The HatchUnit proposed Units 1 and 2 separately, resulting i 1 18-month testing requirements from. item (2) will cause even more :" double -

testing" of the IB swihg diesel. It is proposed to relax " double-testing" for the periodic (monthly or weekly), six-month, and selected 18-month tests.

4. The storage tanks of all five EDGs will. be required to' contain at -

least 33,000 gallons of fuel, and additional' testing requirements for. fuel oil transfer pumps will-be added to the Unit 1 TS.

The enclosures to this letter detail the actual proposed changes.

Enclosure 1 provides a. detailed description of the proposed changes >

and the circumstances necessitating the change request.-

Enclosure 2 details the- basis for GPC's determination' that- the  ;

proposed changes-do not involve significant hazards considerations, i Enclosure 3 provides; page change instructions for incorporating- the proposed changes. The proposed revised TS pages-follow Enclosures-3.

To allow time for procedure revisionsLaniorderly incorporation into copies -of the Technical Specifications, GPC - rlquests the proposed 7

amendments, once approved by the NRC, be issued with an effective date to be no later than 60 deys from'the issuance of the amendments.

Normally .the 60-day effective date allows for the implementing procedures to- be approved and validated. Required testing- would be.

performed to keep the- surveillance current on.'the affected: component; or a system. However, this TS revision adds many new'SRs, many of which '

should be performed during a maintenance / refueling (M/R)' outage. For this ' amendment we would propose that the 18-month SRs lneed; not be performed until the next ' M/R outage (i.e., will be assumed " current"),

provided that the amendment is issued more than 60 days: prior to- the-start of the outage. The new 10-year Unit - 1 surveillance requiring '

simultaneous starting of the EDGs will be performed during the same Unit 1 M/R outage, s f

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' Our review also concluded that changes to the TS-were not required to meet an SSFI commitment relative to fuel oil sampling. 'However, changes ,

to procedures which incorporate parameters, acceptance criteria, and -

l sampling techniques have been made, as stated in our July 7,1989 letter l to=the NRC.

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w GeorgiaPower A U.S. Nuclear Regulatory Commission-January 10, 1990

-Page.Three In accordance with the requirements of 10 CFR 50.91, a copy of this letter and all applicable enclosures will be sent to Mr. J. L. Ledbetter of the Environmental Protection Division. of_ the -Georgia Department ' of' Natural Resources.

Mr. H. G. Hairston, III states. that he is a Senior Vice-President of..

Georgia Power Company and. is authorized to execute this 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 enclosures are true.

GEORGIA POWER COMPANY

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4'H. G. Hairston, III

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i Sworn to and subscribed before me this N aday of

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// otary Public' l

Commission Expires May 22,1993  ;

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Enclosures:

1. Basis for Change Request

2. 10.CFR 50.92 Evaluation

3. Page Change Instructions j c: Georaia Power Comoany .

Mr. H. C. Nix, General Manager - Nuclear Plant )

Mr. J. D. Heidt, Manager Engineering and. Licensing - Hatch l GO-NORMS i

U.S. Nuclear Reaulatory Commission. Washinaton. D.C.

Mr. L. P. Crocker, Licensing Project Manager - Hatch.

U.S. Nuclear Reaulatory Commission. Reaion II Mr. S. D. Ebneter, Regional Administrator i Mr. J. E. Menning, Senior Resident Inspector - Hatch j 0344V i

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ENCLOSURE 1 l

PLANT HATCH.- UNITS l','2.

NRC DOCKETS 50-321 50-366 ,

OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

I ERGENCY' DIESEL GENERATORS BASIS FOR CHANGE RE00EST BACKGROUND: 2 During' the Safety System Functional: Inspection (SSFI) of the Emergency ,

Diesel' Generators (EDGs), 'GPC committed to _ perform 1a comparison 'of the' 4 Technical Specifications. (TS) and NRC Regulatoryf Guide _(RG) 1.108 to. ,

evaluate discrepancies and revise the TS, if necessary. He also committed '

, to revise the TS to require ' additional- fuel' storage capacity. The. 3 proposed changes would do the following:. j

( 1) Voltage and frequency acceptance-criteria have been added for EDG;  ;

' testing consistent with BNR/4- Standard Technical Specifications ,

(STS) RG 1.108. - and RG 1.9.' Steady-state acceptance criteria >

for - EDG tests are > discussed in Proposed ' Change =1, and dynamic  :

acceptance criteria: for. load rejection testing _,ist discussed in Proposed Change 3.

L (2) Several new Surveillance Requirements ' (SRs) have -b'een ' added to 1

l the Unit 1. TSP primarily the 18-month'SRs' currently in' the Unit- 2

! TS. The proposed changes will make both Unit 111 and ' Unit 2.TS _i o fairly consistent - with , RG '1.108, even- though ' Unit E l- _is" not - '

officially committed to this RG. . New Unit :1.. requirements' include. .

a 24-hour load' test and -a' full and partial > load rejectionMtest every :18-months. These requirements are-' discussed 1in ~ Proposed Changes-2, 3, 4, and 6.

(3) - Plant Hatch -has a swing diesel'which is Lrequired to be operable -

for both units. Surveillance testing is' performed' and tracked' for- l Units l' and -2 separately, resulting in- the swing'_EDG beingrtested twice' as often. The proposed. Uni _t .1 18-month -testing requirements from item '(2). will .cause even more" double testing"  :

y of the.IB' swing diesel. It is' proposed to relax " double testing" p for. the periodic- (monthly - or -- weekly) 'six-month, and .. selected -

L 18-month _ : tests. Proposed Change.7 discusses : these . revised i i ' requirements. .

(4) The storage tanks =of _ all' five EDGs will be required to containLat i least 33',000 gallons of' fuel, and additional testing _ requirements -

for fuel oil transfer. pumps: will be5 added to lthe - Unit 17TS.- '

Proposed Change SLdiscusses these revisedJrequirements.

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' ENCLOSURE I (Continued)'

RE()UEST TO REVISE TECHNICAL SPECIFICATIONS: l

,. EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE REOUEST PROPOSED CHANGE 1:

Proposed Change 1.would add' steady-state: voltage and frequency. acceptance-criteria to= several EDG' survelliance requirements.- Specifica11y, Unit 2

- 4 SR 4.8.1.1.2.a.4 and- Unit' 1 SR . 4.9. A.2.a.1 - (monthly; or weekly - test  !

depending on EDG failure rate)1 will require the . EDG- to maintain ' voltage-  ?

withinD i 10% -(t l420 volts)-' and frequency; within i 2% (1 1.2.Hz) after

. reaching- steady state. These same steady-state voltage and- frequency _. -1 acceptance criteria ~ are ' proposed for the six-month test in Unit '2

- SR 4.8.1.1,2.b 'and Unit 1 SR ~4.9.A~.2.a.2. .. Additionally,-_ Unit 2-SR 4.8.1.1.2.d.5.b and Unit 1 L SR4.9. A.7.b.1 (simulated loss of offsite power [LOSP] and/or degraded -voltage) and : Unit: 2, SR 4.8.'1.1.2.d.8.b and '

~ Unit 1 SR '4.9.A.7.c.1 (simulated LOSP plus: ECCS signal) will have the same steady-state voltageL and frequency = acceptance criteria. During these- i tests, it. will 'be' considered acceptable; to' verify the: voltage Land

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' frequency - once during the: first five . minutes and approximate 1y' . every .I 15 minutes thereafter. .Also,: _a requirement to' energize the emergency  !

- buses 1within ~ 12. seconds has been added to Unit 2 / SRs 4=.8.1.1.2.d.5.b 2 and J

4. 8.1".1. 2. d . 8. b . - Unit 1 SRs 4.9.A.7.b.1' and= 4.9.A.7.c.1. have been j reworded 'to -bc consistent with. the corresponding Unit:2 requirements'. In J l

addition, a requirement for - the periodics test . to' verify . the; pressure , in both air start- receivers isr at least1225 - psig has been s added cto Unit-- 1. H SR 4.9.A.2.a.1~. This change is consistent with thes existing E Unit '2 1 requi rement _ (4. 8. I'.1.2. a. 6) . i l

l BASIS:.

- This proposed ~ change adds. requirements - to' both the-

' Unit .1'and Unit 2 TS.

l The acceptance criteria: for voltage'and frequency:are consistent with the- "

l diesel generator; STS transmitted with ' NRC Generic Letter (GL)E 84-15,

" Proposed' Staff! Actions to~ ' Improve- = and LHaintain t Diesel - Generator . j Reliability," dated July 2,- 1984. : Adding the acceptance" criteria of less  !

thanf or equal to 12 seconds, to energize the emergency buses 1during. the

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18-month test simulating a degraded' voltage or~ LOSP1 condition (with - and '

without a simulated ECCS-signal) is 'also consistent with: the STS contained {

in GL 84-15. i I

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h ENCLOSURE 1 (Contim!ed)

- I REQUEST TO REVISE TECHNICAL SPECIFICATIONS:.

-EMERGENCY DIESEL-GENERATORS  ;

BASIS FOR' CHANGE RE00EST i

PROPOSED CHANGE 2:

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This proposed change modifies cr.1teria for 'the 24-hour 1oad test required

. each 18-months by c Uni t - 2 . SR , 4.8.1.1.2.d.9. It also adds a similar  ;

requirement to Unit 1 - (proposed SR 4.9. A.2.a.6) which would be performed

, 'each 18-months. The proposed TSnwould require the first .two hours of the l l24-hour test-be performed .at loads equal to or_ larger than 2950 kH, which.

is above the'EDG continuous rating of 2850 kH. For the~ remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of the test, the EDGs would be loaded'between 2775-2825'kH. ,

4 BASIS:

The -proposed - loadings - are' higher than those currently in Unit 2 SR l - 4. 8.'1.1. 2.d . 9, . ' but substantially.~ lower.'thanLthose- recommended by RG ,

p _1.108.- The RG, recommends the EDG bei run at itsa two-hour rating for the

i. first two hours. This -is unrealistic since ~ the o EDG' would require. t e ' substantial maintenance after running at the two-hour rating for two-_ hours

-(i .e. .. the - test would 'be abusive. to the < EDG). The proposed. load ranges are consistent with-:the crecommendations 'of our EDG vendor:-and are ,'

l compatible with the' recommendations of GL 84-15. Proposed Change 2'also--

i addsDa 24-hour- load _ test requirement in - the' Unit 1- TS ..with the same-loading' requirements. ' This= new SR -is. identical e with the revised Unit 2 -

requirement, and will make~the SRs on the'5'EDGs more consistent.

It should be noted . that, under certain conditions, t emergency - operating procedures could permit loading of the EDGs to 3250_kH.- However, testing of the EDGs at this level _'would greatly accelerate wear. to= the engine and is :not prudent. ' Discussions . with -our 'EDG vendor' have concluded that overload testing of'EDG's.to 1 2950 kN is acceptable. ,

PROPOSED CHANGE 3:

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This . proposed change -modifies- the criteria for: the. partial . and full load' rejection.. tests currently performed .every 18-months per Unit 2- SR 4.8.1.1 ;2.d.3_ and SR ' 4.'8.1.1 ' 2.d.4, . respectively. It. also adds 'similar requirements to. the Unit 1 - TS . in proposed SR 4.9. A.2.a.4 and 4' 9. A'.2.a.5.

[ The surveillance frequency for the' Unit 1 tests would be:every 18-months.

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ENCLOSURE'1'(Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE REOUEST' BASLS:

Current L Unit 2 SR ' 4.8.1.1.2.d.3 requires - the. EDG. reject 798 kW and-maintain certain voltage and frequency limits every 18-months. L A; review of RG 1.108 indicates the ~ load rejected should - be t. the largest ' single emergency-load. - The largest single emergency ' load- for EDGs 2A,::1B and 2C.

is aE Residual Heat Removal Service Water (RHRSH): pump -which could- draw more'than'798 kH.: A. review of:the STS in GL 84-15 and RG 1.9- indicates our current acceptance- - criteria J is too stringent _ relative. to permissible EDG overspeed (frequency). Therefore, the Unit - 2. SR. has been - -

changed to verify the- capability to reject a load equal to the RHRSH pump at' rated flow,'while maintaining a frequency' no higher _ than the nominal speed plus' 75% of the difference between nominal speed and. the overspeed trip setpoint or 15% above nominal, .whichever is less.: Acceptable voltage  ;

limits are specified as 4160'i 420V, which are virtually identical'with-the current Unit 2 requirements. Proposed Change 3 also adds a partial load rejection test for - Unit 1 - per proposed SR 4.9. A.2;a.4. Maximum single emergency-load for EDG11A and 1C corresponds? to -a: Core l Spray. pump load.- - The test will- be' performed each -18 months, and-wil_1 be very similar to -the proposed Unit 2- requirements .(i.e.,; reject Jaiload equivalentV to -

the core spray pump at rated- flow).

Proposed' Change 3' also modifies the criteria for'the-fullfload rejection.

test (Unit 2 SR 4.8.1.1.2.d.4) to ' require- all EDG's be capable of .;

- rejecting at least "2775 kW while maintaining : voltage: of less than =4800-volts and not tripping the'EDG; The required 2775'kH= load is.closeito the EDG continuous > rating s of 2850 kH, and ' _ equal to the lowest permissible loading required during the last 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of the' 24-hr: EDG loaditest (see.

Proposed Change _2). The full load rejection test could 'therefore be -1 performed at the conclusion of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test, if desired. The maximum' ,

acceptable voltage acceptance criteria .of 4800 volts' for. the load '

rejection test has-'been reviewed by- our EDG- vendor and determined to be within' the- design . limits of the Plant - Hatch EDGs. Overspeed (frequency) limits .although less stringent than the current Unit:2'TS, are: consistent 4 with: the STS and RG 1.9 : The current Unit 2 surveillance frequency for this test is each months, which would not be modified. Proposed Unit 1 SR 4.9.A.2.a.5 has also been added to require a similar -full load rejection test every 18-months. :The requirement to perform a full load rejection ' test would be the same for both units, and the ~ proposed- t

-acceptance criteria for the test are consistent with-the STS and RG 1.9.

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I ENCLOSURE 1 (Continued)'

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:  !

EMERGENCY DIESEL GENERATORS -

BASIS FOR CHANGE RE00EST' PROPOSED CHANGE 4:;

Unit 2 TS 4.8.1.1.2.d.9 currently requires that within 5 minutes following;

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~the 24-hour load test, the _ EDG be restarted via'a simulated LOSP, and that

. automatically connected emergency loads be' energized and loaded; on the EDG - .

(i.e., re-perform SR 4.8.1.1.2.d.5). Proposed -- Change 4 - would add a j*

U similar requirement: to immediately retest the EDG- to thenUnit'l TS 1

(proposed SR 4.9.A.7.b.2). However, both requirements would' allow!the EDG .

restart.- test to .be performed following - either the. 24-hour load test or immediately following. any running of the. EDG which raises it to _ normal, operating temperature (e.g. .. one hour at r 60't, of rated load). .

BASIS:

Allowing the EDG to be retested immediately following any test 'which1 bring l

-it to normal: operating temperature'(rather than just following - the: 24-_ hour test) is not addressed in RG I.108. However, it .is justified.because .the ,

purpose of the retest .lsi to- verify. thel EDG . will start, energize _the emergency buses : within ?122 seconds, .and! energize thei emergency (shutdown) j Ioads properly when the EDG is warm. If the EDG were to fail: this- restart s

l.- test after the- 24-hour test under 'the" current. Unit TS, it would 3 be. -i l- necessary to rerun' the' 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test. This could. : be considered <

L unnecessarily abusive to the EDG and contrary to the intent;of GL 84-15.

-PROPOSED CHANGE 5:

Unit 2 TS 3.8.1.1.b.2 and 3.8.1'.2.b.2 will be modified to r'equire .each of the 5 EDG's oil -tanks contain 33,000 gallons of fuel. Uni t.1 TS 3.9. A.2.d -

wi.11 require 99,000- gallons for > the three: EDGs. . Unit' 2 Bases Section 3/4.8, and Unit 1. Bases '3.9. A.2.d have: been modified accordingly. Unit.1 Li mi ti ng '. Cond i ti on for .' Op erati on 1 ( LCO) 3.9. A.2.d and - SR 4.9. A.2.d will be-modified to require a 900 gallon minimum supply in~ each EDG day: tank to be J veri fied1 monthly, _ consistent' with current . Unit 2 LC0 3.8.1.1.b.1- and

.. 3.8.1.2.b.1.. A note has been-.added to Unit 2- TS . 3.8.1.1.b.1 . and L 3.8.1.2.b.1 and_ Unit 1 modified TS' 3.9 A.2.d.. . allowing the ~ EDG to be:

l considered operable-(up to four hours) with 'less than 900 gallons _in the day tank during verification of fuel transfer pump flow. 3 Js L I i- o 0344V HL-790 El-5 l

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REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS: j I

BASIS FOR' CHANGE RE00EST j l

BASIS: ]

The 33,000 gallons required to be maintained in each of the fuel oil tanks L represents a- total volume of oil sufficient to operate.any 4 EDGs at .3250 I L kW for a period of 7 days.; The onsite fuel capacity will-last longer than the' time; it - would take to replenish-ithe onsite supply from offsite;  ;

sources. The proposed Specifications also add;: consistency to' the -!

requirements fc the 5 EDGs. Adding a requirement on the-day tank volume to Unit 1-is a conservative change which also adds consistency.

The operability of the fuel oil transfer-- pumps is verified monthly lper  !

Unit 2 .SR 4.8.1.1.2.a.3 and Unit 1 proposed SR' 4.9. A.2.e.l .' : This test,-

however, simply verifies the pumps run and' transfer fuel to.the-day . tank.

'The-' fuel oil transfer pump has . excess capacity. relative' to- the EDG ,

consumption rate, so, if the pump is not secured, the day tank will have '

at least 900 gallons of fuel.

During periodic testing, the fuel transfer. pump -is secured, 'the .EDG runs and 'the pump operability is verified. The> day tank may- have :slightly .;

below.900 gallons prior to starting- the fuel transfer pumps. ,In addition,- j GPC may be adding a periodic test to verify the fuel transfer pump flow-- >

capability. - similar to pump testing currently. performed. on safety system pumps per ASME - Section XI in-service testing. This will require - an accurate,. reproducible test which verifies pump . flow. - The- fuei transfer pumps at Plant ~ Hatch do not- have flow instrumentation. Also, the transfer pump flow capability is high enough and the day ttank: high andilow' level '

setpoints close .enough so the pump ' would normally. run only: about 3 minutes. In order to accurately ' determine pump flow and account for transient effects of filling the transfer piping,:it may be necessary to '

lower the level in the day tank below 900 gallons. Therefore, notes'have been added to the Unit 1 and Unit 2 LCOs toi allow for less than 900 gallons in the day tank while. performing these tests. A time - limit of four hours has~ been specified before the EDG would be declared inoperable '

and the unit placed in a Limiting Condition ~ for Operation..

PROPOSED CHANGE 6: l L

L The proposed change would add many other SRs to the Unit 1 TS, in addition.

to - those discussed in Proposed Changes 1-5. Most' of these additional- ,

requirements are 18-month tests. currently in the; Unit 2 TS. Specifically, Unit 1 SR 4.9.A.1.b would be added -to demonstrate e manual and automatic H transfer of unit power supply from the normal circuit to alternate circuit j

, for each offsite required circuit each 18-months. The new Unit- 1 - l requirement corresponds to Unit'2 SR 4.8.1.1.1.b.

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ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:! ,

, EMIRGENCY DIESEL GENERATORS

. BASIS FOR CriANGE REOUEST-L Proposed Unit.1 SR. 4.9.A.2.a.3 requires an; EDG inspection each L18-months. H This corresponds to existing Unit-2 SR 4.8.1.1.2.d.1.

Proposed Unit .1' SR '4.9. A.2.a.7 adds the 18-month surveillance requirement ')

to~ - verify automatically connected -loadssto each ~EDG :do- not exceed 3100 kH.- . This- new - requirement is consistent with Unit 2 SRL ,

4.8.1.l.2.d.10. Note that the: Unit 2 requirement - has .been modified-. to i reflect the - verification: of loads . less 3 than or equal to the:2000 hour i rating of 3100 kH.-

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Prop'osed Unit: 1 SR 4.9. A.2.a.8 requires the EDG ' to: synchronize - with' the offsite power source- while -it' is loaded with shutdown loads upon a-r.imulated restoration of offsite: power, and transfer its loads and proceed to shutdown. This .new requirement is consistent with existing Unit 2 -SR:

4.8.1.1.2.d.11.

i Proposed Unit 1 SR 4.9. A.2.a.9,would require - that the . E'DG, operating in L the test mode, will be overridden from the' test mode by a simulated safety-injection esignal,: return .to _ standby, and automatically.~ energize: the

emergency -loads, with- offsite power. .- This new requirement is Econsistent L - with existing Unit 2 SR 4.8.1.1.2.d.12. H l Proposed' Unit 11 SR- 4.9.A.2.e.2 ' requires 1the i fuel (011 transfer. pumps be W verifled capable

of. transferring - fuel from each: fuel storage tankito .the 1 dayitank ofc each EDG via cross-tie lines. . This-' surveillance, which would '

be performed every;18 months, is consistent:with Unit 2.SR'4.8.1.1.2.d.13.

Proposed Unit .1 SR- 4.9. A.2.a.10 would require simultaneous starts of- the l- EDGs once per 10 years or after. any modifications 'which -could affect- EDG' L interdependence. This new requirement' is ~ consistent with. existing'(but L renumbered)- Unit 2 SR 4.8.1.1.2.e. The new Unit 1 SRL wouldL require a-l: simultaneous start of EDGs lA, IB, and 1C, since the L 1B.' (swing) EDG .is normally aligned to Unit 1.

! Proposed Unit 1 LCO 3.9.A.2.e- and SR 4.9.A.2.e require that'. the. EDG fuel

? transfer pump - be ' operable, : capable of transferring. fuel- from, the storage; i tank- to the day tank, and that it be demonstrated operable during: thei i

' periodic :(monthly) test. This new SR is ' consistent .with Unit- 21 SR L 4.8.1.1.2.a.3.

L l Existing- Unit -1 SR 4.9.A.7.b.1 has been modified to be consistent with i Unit 2t SRs . 4.8.1.1.2.d .2, 4.8.1.1 '.2. d .5 8 and ' 4. 8.1 '.1.2.d.7. The modified: l SR would include verifying the load sequence timer'is operable and the. EDG-

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performs properly under simulated degraded voltage and LOSP' conditions. j o

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l ENCLOSURE IJ(Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:  :

l EMERGENCY DIESEL GENERATORS  :

BASIS FOR CHANGE RE00EST- I N

o .

a

Also, existing Unit -1 SR 4.9.A.7.c.1D has been ' modified to be consistent 1 with existing Uniti 2 - SR 4.8.1.l'.2.d.8.a and 4.8.1.1.2.d.8.b. This SR i calls; for

the EDG to be tested separately: Under both a simulated degraded l voltage condition andia simulated LOSP concurrent with. an ECCS . actuation signal, Land verifies proper performance. -i

. Proposed Unit .11 SR .4.9.A 7.c.3 would require ' that all. EDG trips except- i engine overspeed, low lube. 01_1. pressure, and generator differential, are  !

automatically bypassed' upon loss of voltage on the emergency bus, concurrent' with an: ECCS. actuation- signal. This new requirement: is- ,

consistent with Unit 2 SR 4.8.1.1.2'd.8.c.:

1 The proposedi change Will delete the requirement to verify the- 600 volt; l c load shedding logic systemLis operablez in TS ' 3.9. A.7.d and 4.9. A.7.d. 'The. .

I: Unit '2 TS, and the STS transmitted with GL- 84-15 do not explicitly specify 3 such a requirement.

Minor Unit 1 changes include changing "every scheduled- refueling -outage" to "each 18-months" .on several- SRss for consistency with..thex Unit 2 wording. Also Unit _1: Bases > Section - 3.9.A.2 ~'has: been modified - to J reflect i the current EDG continuous .: rating of- 2850 kN ' and allow a simultaneous. '

L start per Proposed <SR 4.9.A.2.a.10.

]

BASIS:

Except for the deletion of the requirement to verify. the 600-V. load -

shedding system is operable, Proposed Change 6' adds -requirements to the Unit'~1 TS, and is therefore a conservative change. This change (along. ,

with Proposed Changes 1-5) make the Unit l'and.2 TS : requirements. for EDG '

testing more consistent.

- Deletion of. TS <3;9. A.7.d ;and 4.9.A.'7.d-- (600-V load shedding logic system test) is justified 'because the' additional requirements described 1in Proposed Changes 1-6 make the Unit 1 TS consistent with the Unit 2 TS and the- BHR/4 STS transmitted with GL 84-15. ~These TS, do' not contain requirements to demonstrate ~ initiation of -load' shedding on- the -' diesel auxiliary boa'rds, reactor ^ MOV' boards, and .the 600-V shutdown boards.

However, both the Unit-2 TS and the- proposed- Unit 1 :TS contain:

requirements to verify- EDG load shedding ' capability, including the

! non-esser 4tial 600 V loads. For example, existing Unit -TS 4.9.A.7.b.1 and .

4.9.'A.7.c.1' have- been ' modified to be consistent with' Unit 2 and . STS requirements', and verify proper de-energization of the emergency buses and '

load shedding from the emergency buses.

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0344V l HL-790 El-8 t i

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1 3

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS

'. BASIS FOR CHANGE REOUEST' ,

PROPOSED CHANGE 7: .,

As' discussed .previously, Plant Hatch has 5' EDGs.. Emergency diesel

- generator = 1B is a swing-diesel, and may supply' power to emergency bus in.

Leither unit.- Since it is shared, operability, testing,- and failure- ,

tracking have ~ historically been performed for each unit separately.  ;

Adding all the new requirements toL Unit 1 aggravates .,the: . situation - of

" double testing"- the IB EDG even more.. The following is proposed for the periodic, six-month and 18-month testing. The periodic- test is ccurrentlyc- '

performed on a schedule listed in Unit 1 Table 4.9-1. and Unit .2 Table -

4.8.1.1.2-1, . and is. either monthly or. weekly depending:on the EDG' failure

' rate. j t '

Explanatory notes have been' added to Unit-il TS 3.9.A.2 and UnitL 2 TS 3.8.1.1.b allowing control of the EDG to be' taken locally,while warming up and barring over the diesel engine during surveillance testing.

, Periodic Testina - Currently the IB diesel is usually tested twice- per L month (once per unit) per VI TS 4.9.A.2.a.1"and U2:1TS 4.8.1.1.2.a.4. 'The

periodic test callsfor taking contro1 r of the diesel- locally, lowering

governor setting,- prelubing, and starting engine with. the local start

! button. Once the EDG is warm the local; switch is:placed back to remote.

It is proposed to only test the 1B once per month-by starting it locally, connecting it to the.first units emergency bus and Lloading it to 1710-2000. a kH, running it for 130 minutes, then separating from the first unit and connecting to the other unit for 1 30' minutes while loading it -to This method has the obvious advantage- of reducing. by'-

1710-2000 kW.

approximately - 50% the number . of IB diesel starts. Tracking of ' start L failures of the IB would be on a common: unit. basis.

4 Notes reflecting ' periodic testing requirements _ on the IB 'EDG. are' I

referenced in Unit l'TS 4.9.A.2.a.1 and Units 2'TS 4.8.1.1.2.a.4. 4 >

Six-Month - Testina - During this test, 5th~e . diesel is Lstarted from the corresponding unit's control. room. 'The " fast-cold"' start of the 1B would i

only havetto be done once every six-months' and would be initiated using l- the starting . circuitry on one unit for one' six-month test... and the L starting circuitry on the other unit at the next six-month test. Notes i

.have been added. to Unit 1 'TS 4.9.A.2.a.2 and Unit 2 TS 4.8.1.1.2.b

~

reflecting these revised requirements. - t i

i 0344V '

-HL-790 El-9

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ENCLOSURE 1 (Continued).

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:.- ,

j -EMERGENCY DIESEL GENERATORS l BASIS FOR CHANGE RE00EST c ;t

'18-Month Testing - The- EDG inspection,l24 hour load test, partial and full:

load rejection tests will be performed only once: per 18-months and--will-Esatisfy both the Unit:1 'and Unit 2 requirements. All other . tests will be-done ' separately for both! units since they : involve .more' than a' l

. demonstration of EDG capability to-carry and- reject loads.. Notes- have ,

been added to proposed Unit 1 :TS 4.9.A.2.a.3. .a.4, a.5, .a.6 and. Unit. 2 TS 4.8.1.1.2.d.1, d.3, d.4 d.9 reflecting these revised requirements.

BMIS:

The periodic (' monthly) test demonstrates' the ' capability . of the EDG to  :

start,- run, and . supply load to- thei associated emergency bus. The EDG is '

started _ locally, > not_ from the. main control room .(MCR),,and~ run for i approximately I hour, per the EDG vendor : recommendations;and those of GLL

. 84-15. The IB EDG is currently. started twice ~ monthly from the same' local j panel and; connected to one ' unit's emergency bus = -during 'one test, and to the other unit's emergency: bus, during the other- test. , Since the monthly i test does not verify the auto: start from the MCR ~ or _ verify- the EDG's - ,

ability to ' reach synchronous speed 'and accept accident ? loads, it- is. not necessary to run the:1B-EDG twice each month. :The requirement to run the EDG on'each emergency bus for 130 minutes is justified. The tracking of-start failures; and increased testing resulting from1 any start failure of the IB would be on a "per diesel" basis '(common Lto both units). As .is >

currently the case,. operability of the IB EDG is required for both units.

The six-month- test starts

the EDG from the MCR ~ and verifies: the EDG i

! accelerates to- synchronous speed in d '12 seconds. . Prior' to~ the issuance- J l of GL 84-15 : (and Unit 1 and Unit. 2- TS. Amendments based on GL 84-15) all I L EDG tests were " fast cold" start ~ tests. . However, the < frequency of . these .

tests was reduced because they were considered : abusive to the: EDG. The-1 IB EDG-currently is tested twice per six-months. .The revised requirement I

wo'uld " fast cold" start the 1B ' EDG each six-months from -alternating control rooms, such that it would' be started from each unit at least once

'per 12 months. Logic system functional testing ist performed' on. EDG. R starting' logic routinely ~ at both units. -

Certain 18-month surveillances on the EDG verify its -capability 1to carry and reject- loads, and certain SRs -verify EDG emergency load- sequencing and performance under simulated LOSP and- LOCA conditions.- For the- 18. swing EDG, it is proposed that the 24-hour. load test, and the full. and partial -l load rejection test be performed once per 18 months -frequency, since -these .

SRs verify. EDG load carrying- capability. The requirement to perform an-  :

L inspection of the EDG will also be requi1 red only once per 18 months.

0344V  !

HL-790 El-10 '

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_._____________1______m___ _ _ _ _ m e

ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

D E H CY DIESEL GENERATORS BASIS FOR CHANGE RE00EST _

==,

Adding numerous 18-month SRs to the Unit 1 TS th0t were already required by Unit 2 TS will aggravate " double testing" of the 18 EDG, for example, the 24-hr load test, the full and partial load rejection test, c.qd the inspection are not required by current Unit 1 TS and would have to be done twice to the IB swing EDG unless specific exception is taken.

Ti e following SRs will be performed every 18 months for RCh unit. Q ef fectively meaning the IB will t'e tested twice each 18 months. -

Surveillante Bgguirements Descrintion -2 Proposed Unit 1 SR 4.9.A.2.a.8 Requires EDG to synchronize with Existing Unit 2 SR 4.8.1.1.2.d.11 the offsite power source while it _

is loaded with shutdown loads upon a simulated restoration of offsite M pcwer, and transfer its loads and proceed to shutdown.

Proposed Unit 1 SR 4.9.A.2.a.9 Requires that the EDG, operating in Existing Unit 2 SR 4.8.1.1.2.d.12 the test mode, be overridden from the test mode by a simulated safety injection signal, return to standby, -

and automatically energize the emergency loads with offsite power. -

Modified Unit 1 SR 4.9.A.7 b.1 Requires verification that the load Existing Unit 2 SRs 4.8.1.1.7.d.2, sequence timer is operable and the d.5, d.7 EDG performs properly under simulated degraded voltage and _

LOSP conditions. -

Modified Unit i SR 4.9. A.7.c.1 Requires EDG to operate properly Existing Unit 2 SR 4.8.1.1.2.d.8.a. under both a simulated LOSP and and d.8.b. concurrent ECCS signal and under a --

simulated degraded voltage _

condition. _

Proposed Unit 1 SR 4.9.A.7.c.3 Requires that all EDG trips except Existing Unit 2 SR 4.8.1.1.2.d.8.c engine overspeed, low lube oil -

pressure, and generator differential be automatically bypassed upon loss of voltage on the emergency bus, concurrent with an ECCS actuation signal. -

0344V HL-790 El-11

l ENCLOSURE 1 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE REOUEST Generic Letter 84-15 and our EDG vendor recommended reducing the number of fast cold starts on the EDGs, and Unit 1 TS Amendment 147 and Unit 2 TS Amendment 83 allow gradual loading of the EDG during periodic (monthly or weekly) testing. Also, our EDG vendor recommends barring or rolling over the diesel engine. Control must be taken locally to perform these functions, although only for a brief period of time. While the control switch is in local, the EDG will not automatically respond to initiating signals and, if needed, align itself in the safety mode as it would with the control room switch in test. However, the time required to warm up and bar-over the engine is short, and during most of the surveillance testing the control switch will be in test. Also, personnel performing the test will be in communication with the control room, and could take action in the unlikely event the EDG is required while warming or barring-over the engine. The notes referenced in Unit 1 TS 3.9. A.2 and Unit 2 TS 3.8.1.1.b allow control to be taken locally without the EDG being considered inoper tc.le for the purposes of required actions.

PROPOSED Cli&MGLS:

Proposed Change 8 would delete current Unit 2 SR 4.8.1.1.2.e which requires the EDG to be started 5 times in a row and quickly accelerated to verify the capacity of the air start receivers.

BASIS:

Deleting this TS requirement will reduce the number of unnecessary tests on the EDGs. The primary reason for this test is to verify adequate equipment sizing of the air start system, which is not expected to change unless modifications are performed to the air start system or EDG. This requirement is part of pre-operational testing, but does not appear in the STS provided in GL 84-15.

0344V HL-790 El-12 m .. .. .. ..

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ENCLOSURE PLANT HATCH - UNITS 1, 2 -

NRC DOCKETS 50-321, 50-366 OPERATING LICENSES DPR-57, NPF-5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY-DIESEL GENERATOR 2

10 CFR 50.92 EVALUATION

' PROPOSED CHANGE 1:

Proposed Change 1 would add steady-state voltage and frequency acceptance criteria- to several EDG surveillance requirements. Specifically. Unit 2 SR 4.8.1.1.2.a.4 and Unit 1 SR 4.9. A.2.a.1 (monthly or weekly test depending on EDG' failure rate) will require the EDG to maintain voltage within i 101 -(i 420 volts) and frequency within i 2% (i 1.2 Hz) after reaching steady state. These same steady-state voltage - and frequency acceptance criteria are proposed for the six-month test in Unit 2 SR 4.8.1.1.2.b and Unit 1 SR 4.9.A.2.a.2. Additionally, Unit- 2 SR 4.8.1.1.2.d.5.b and Unit 1 SR 4.9. A.T.b.1 (simulated loss of offsite power [LOSP) and/or degraded voltage) and Unit 2 SR 4.8.1.1.2.d.8.b . and Unit 1 SR 4.9. A.7.c.) (simulated LOSP plus ECCS signal) will have the same steady-state voltage and- frequency acceptance criteria. Also, _a requirement to energize the emergency buses within 12 seconds has been added to Unit . 2 SRs 4.8.1.1.2.d.5.b and 4.8.1.1.2.d.8.b. Unit 1 SRs 4.9.A 7.b.1 and 4.9.A.T.c.1 have been reworded to be consistent with the corresponding Unit 2 requirements. In addition a requirement for the periodic test to verify the pressure in both air start receivers is at-least 225 psig has been added to Unit 1 SR 4.9. A.2.a.1.. This change is consistent with the existing Unit 2 requirement (4.8.1.1.2.a.6);

BASIS:

Georgia Power Company has evaluated this proposed change and determined it involves no significant hazards considerations.

-This proposed change does' not involve a significant increase in the probability or consequences of an accident previously evaluated. The change adds acceptance criteria to ' periodic (monthly), six-month', and several 18-month. EDG tests, makes the Unit 1 SRs consistent with .the corresponding Unit '2 requirements and added a new > SR or Unit 1. The proposed change will result in more complete testing - The EDG's' will not be functionally altered and will continue to. function as designed. Adding these additional test requirements and- acceptance criteria will not reduce the reliability of the Unit 1 and Unit 2 EDGs.

0344V HL-790 E2-1

ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE RE0 VEST The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated, because the EDGs and on-site electric power system will not be altered. The EDGs will continue to respond and function in the same manner.

The proposed change does not involve a significant decrease in the margin of safety because the EDGs will continue to respond as before to mitigate analyzed transients and accidents. Adding testing requirements and acceptance criteria will result in a more meaningful test, reduce inconsistencies between the Unit 1 and Unit 2 TS, and not reduce the EDG reliability.

PROPOSED CHANGE 2:

This proposed change modifies criteria for the 24-hour load test required each 18-months by Unit 2 SR 4.8.1.1.2.d.9. It also adds a similar requirement to Unit 1 (proposed SR 4.9.A.2.a.6) which would also be performed each 18-months. The proposed TS would require the first two hours of the 24-hour test be performed at loads equal to or greater than 2950 kH, which is above the EDG continuous rating of 2850 kH. For the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of the test, the EDGs would be loaded between 2775-2825 kH.

BASIS:

Georgia Power Company has evaluated this proposed change and determined it involves no significant hazards considerations.

This proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. The chango modifies test criteria for the Unit 2 EDGs and adds the test requirement and criteria to Unit 1. The proposed change will not modify the EDGs on either unit and they will continue to function as before to mitigate the consequences of an accident. Our EDG vendor has concurred that the specified load ranges on the EDGs are acceptable for an 18-month test, and will not degrade their reliability.

This proposed change does not create the possibility of a new or different kind of accident from any previously evaluated because the on-site electric power system will not be altered. The EDGs will respond and function in the same manner as they do currently.

0344V HL-790 E2-2

D E

l ENCLOSURE 2 (Continued) 5 REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE RE00EST

=

This proposed change does not involve a significant decrease in the margin of safety because the EDGs will continue to respond to mitigate analyzed  ;

transients and accidents as before. Our EDG vendor concurs that the load ranges specified will not degrade EDG reliability and adding the 24-hour load test requirement will make Unit I and Unit 2 testing requirements more consistent.

=

PROPOSED CHANGE 3:

This proposed change modifies the criteria for the partial and fuli load rejection tests currently performed every 18-months per Unit 2 SR 4.8.1.1.2.d. 3 and SR 4. 8.1.1.2.d.4, respectively. It also adds similar requirements to the Unit 1 TS in proposed SR 4.9. A.2.a.4 and 4.9. A.2.a.5. =

The surveillance frequency for the Unit 1 tests would also be every =

18-months. -

BASIS: ,

Georgia Power Company has evaluated this proposed change and determined it involves no significant hazards considerations. _

This proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. The revised loading criteria for both the full and partial load rejection -

tests are more restrictive than those presently in the Unit 2 TS, and represent new requirements for Unit 1. Voltage and frequency criteria are less stringent than those currently in the Unit 2 TS, but compatible with the STS, RG 1.9, and our EDG vendor recommendations. The EDGs will continue to function as before to mitigate the consequences of an accident.

This proposed change does not create the possibility of a new or different -

kind of accident from any previously evaluated because the on-site electric power system will not be altered. The EDGs will respond and function in the same manner as they do currently.

This proposed change does not involve a significant decrease in the margin of safety because the EDGs will continue to mitigate analyzed transients and accidents as before. Testing requirements will be similar on all 5 EDGs and consistent with industry standards and recommendations, and not degrade EDG reliability.

0344V HL-790 E2-3

i ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIDNS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE RE00EST PROPOSED CHANGE 4:

Unit 2 TS 4.8.1.1.2.d.9 currently requires that within 5 minutes following the 24-hour load test, the EDG be restarted via a simulated LOSP, and that automatically connected emergency loads be energized and loaded on the EDG (i.e., re-perform SR 4.8.1.1.2.d.5). Proposed Change 4 would add a similar requirement to immediately retest the EDG to the Unit 1 TS (proposed SR 4.9.A.7.b.2). However, both requirements would allow the EDG restart test to be performed following either the 24-hour load test or immediately following any running of the EDG which raises it to normal operating temperature (e.g., one hour at 1 60% of rated load).

BASIS:

Georgia Power Company has evaluated this proposed change and determined it involves no significant hazards considerations.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. The EDGs will function as before to mitigate analyzed transients and accidents.

The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated because the revised Unit 2 TS will still verify that the EDG can start and load properly when warm.

The current testing requirement could result in unnecessary testing of the EDG because if the EDG failed its restart, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load test would have to be rerun. This constitutes a new testing requirement for Unit 1 and therefore a conservative change.

This proposed change does not involve a significant decrease in the margin of safety because the EDGs will continue to respond as before to mitigate transients and accidents. Requirements for all 5 EDGs will be similar and will not result in abusive testing of the EDGs. Since the increased testing will not be abusive, EDG reliability will continue to be acceptable.

0344V HL-790 E2-4

l ENCLOSURE 2 (Continued)

RE7)EST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE REOUEST PROPOSED CHANGE 5:

Unit 2 TS 3.8.1.1.b.2 and 3.8.1.2.b.2 will be modified to require each of the 3 EDG's oil tanks contain 33,000 gallons of fuel. Unit 1 TS 3.9.A.2.d will require 99,000 gallons for the three EDGs. Unit 2 Bases Section 3/4.8, and Unit 1 Bases 3.9. A.2.d have been modified accordingly. Unit 1 Limiting Condition for Operation (LCO) 3.9. A.2.d and SR 4.9. A.2.d will be modified to require a 900 gallon minimum supply in each EDG day tank to be verified monthly, consistent with current Unit 2 LCO 3. 8.1.1. b .1 and 3.8.1.2.b.1. A note has been added to Unit 2 TS 3.8.1.1.b.1 and 3.8.1.2.b.1 and Unit 1 modified TS 3.9. A.2.d. allowing the EDG to be considered operable (up to four hours) with less than 900 gallon in the day tank during verification of fuel transfer pump flow.

MSIS:

Georgia Power Company has evaluated this proposed change and determined it involves no significant hazards consideration.

This proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Requiring all five EDG oil tanks to contain 33,000 gallons of oil and adding a SR to Unit 1 on fuel transfer pump operability and day tank volume are conservative changes. Allowing the associated EDG to be considered operable during pump flow testing will not increase the probability of consequences of an accident significantly since the alloted time is short (4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br />), the EDG would still function upon receipt of a start signal, and the testing improves the confidence that the fuel transfer pump is functioning properly.

This proposed change does not create the possibility of a new or different kind of accident from any previously evaluated because the EDGs will respond and function as before.

This proposed change does not involve a significant decrease in the margin of safety. The EDGs will continue to mitigate analyzed transients and accidents. Testing requirements will be similar for all five EDGs, and will not decrease the reliability of the EDGs.

0344V HL-790 E2-5

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ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE REOUEST PROPOSED CHANGE 6:

This proposed change would add many other SRs to the Unit 1 TS, in addition to those discussed in Proposed Changes 1-5. Most of these additional requirements are 18-month tests currently in the Unit 2 TS.

The additional requiroments are discussed in Enclosure 1, under " Proposed Change 6". The current Unit 1 TS requirement (Specifications 3.9. A.7.d and 4.9. A.7.d) to verify load shedding on specific non-essential 600-V loads would be deleted.

MS15:

Georgia Power Company has evaluated this proposed change and determined it involves no significant hazards considerations.

The proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated. Except for deleting one specific Unit 1 TS, the change adds testing requirements to The Unit 1 TS, but does not modify the EDGs in either unit. The change adds consistency to the testing requirements for all five EDGs. Deletion of existing Unit 1 TS 3.9. A.7.d and 4.9. A 7.d is justified because the requirement does not exist in the Unit 2 TS, or in the STS, and proper load shedding of the 600-V loads will be verified during the testing required by modified Unit 1 SR 4.9. A.7.b.1 and 4.9. A.7.c.1.

The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated because the EDGs will still function and respond in the same manner.

The proposed change does not involve a significant decrease in the margin of safety because the EDGs will respond and mitigate analyzed transients and accidents as they do currently. The new SRs will not degrade EDG reliability and will make the testing of all five EDGs consistent.

PROPOSED CHAN,GLl:

Plant Hatch has five EDGs, Emergency diesel generator 1B is a swing diesel, and may supply power to emergency buses in either unit. Since it is shared, operability, testing, and failure tracking have historically been performed for each unit separately. Adding all the new requirements to Unit 1, aggravates the situation of " double testing" the IB even more.

Proposed Change 7 allows for periodic testing (including the six-month 0344V HL-790 E2-6

ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE RE00EST test) of the 1B EDG to be reduced to the same frequency as the other four 1 EDGs. Eighteen-month SRs which demonstrate the EDG's capability to carry and reject loads would be performed on the IB EDG only once per 18 months. Also, notes have been added allowing control to be taken locally while warming up and barring over the diesel engine.

BASIS:

Georgia Power Company has evaluated this proposed change and determined it -

involves no significant hazards considerations.

This proposed change does not involve a significant increase in the probability or consequences of an accident previously evaluated.

Unnecessary testing of the IB EDG will be avoided, provided the purpose of <

the test is primarily to demonstrate the EDG capability to start and carry and reject loads. Many of the 18-month tests added to the voit 1 TS (see Proposed Changes 1-6) will have to be performed every 18 months for mb unit, effectively meaning the IB will be tested twice every 18 months.

The IB EDG will still be tested at least as frequently as the other four EDGs, and will continue to respond and function as designed. Allowing control to be taken locally for while warming up and barring over the diesel engine is justified because the time period is brief, the practice enhances the reliability of the EDG, and also allows GPC to follow NRC and vendor guidance.

The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated becaust the IB EDG will still function and respond in the same manner.

The proposed change does not involve a significant decrease in the margin of safety because the IB EDG will respond to mitigate transients and "

accidents as it does currently. The IB EDG will be tested throughly to ensure high reliability. Taking control locally for brief periods of time allows GPC to test the EDG in a manner prescribed by the NRC and the EDG vendor.

PROPOSED CHANGE 8:

Proposed Change 8 would delete current Unit 2 SR 4.8.1.1.2.e which requires the EDG to be started five times in a row and quickly accelerated to verify the capacity of the air start receivers.

0344V HL-790 E2-7

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1 4

ENCLOSURE 2 (Continued)

REQUEST TO REVISE TECHNICAL SPECIFICATIONS:

EMERGENCY DIESEL GENERATORS BASIS FOR CHANGE REOUEST BASIS:

Georgia Power Company has evaluated the proposed change and determined it involves no significant hazards considerations.

The proposed change does not i nvolve a significant increase in the probability of consequences of an accident previously evaluated. Deleting the requirement will reduce the number of unnecessary EDG tests. The primary reason for the test is to verify adequate sizing of the air start system. This is not expected to change.

The proposed change does not create the possibility of a new or different kind of accident from any previously evaluated because the EDGs will function and respond in the same manner.

The proposed change does not involve a significant decrease in the margin of safety because the EDGs will respond to mitigate transients and accidents as they do currently. The capacity of the air start system is not expected to change unless modifications are performed, so the test is not normally necessary.

0344V HL-790 E2-8

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