RBG-32248, Application for Amend to License NPF-47,revising Tech Spec 4.8.1.1 Re Pretest Requirements for Div I & II Diesel Generator Surveillance Testing
| ML20006D926 | |
| Person / Time | |
|---|---|
| Site: | River Bend  |
| Issue date: | 02/02/1990 |
| From: | Deddens J GULF STATES UTILITIES CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20006D927 | List: |
| References | |
| RBG-32248, NUDOCS 9002150270 | |
| Download: ML20006D926 (8) | |
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February 2,1990 RBG-32248 File No. G9.5, G9.42
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U.S. Nuclear Regulatory Commission.
Document Control Desk
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Gentlemen:~
River Bend Station - Unit 1 Docket No. 50-458' Gulf. States Utilities (GSU) Company hereby files an application to amend the River Bend Station Unit 1. Technical Specifications, Appendix A to Facility Operating License NPF-47, pursuant to 10CFR50.90. This application is filed to revise the pre-test.> requirements for Division 11 and II Diesel Geherator surveillance testing contained in Specification 4.8.1.1.
This proposed change is requested prior to the third refueling outage at River Bend Station.
The Attachment to this letter and i
Enclosure provide the justifications and proposed revisions to the Technical ~ Specifications.
Your prompt attention.to this application is appreciated.
Sincere 1,
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J. C. Deddens Senior Vice President
. River Bend Nuclear Group JCD/TFP/WA0/
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9002150270 900202 A
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UNITED STATES OF AMERICA NUCLEAR REGULATORY COMMISSION STATE OF LOUISIANA
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PARISH OF WEST FELICIANA
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l Docket No. 50-458 l
In the Matter of
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L-GULF STATES UTILITIES COMPANY
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(River Bend Station - Unit 1)
AFFIDAVIT J.
C.
- Deddens, being duly
- sworn, states that he is a Senior Vice President of Gulf States Utilities Company; that he is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the documents attached hereto; and that all such documents are true and correct to the best of his knowledge, information and belief.
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Deddens Subscribed and sworn to before me, a Notary Public in and for the State and Parish above named, this 2 od-day of f>fftud/Lu 19C7()
My Commission expires with Life.
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Claudia F.
Hurst Notary Public in and for L
West Feliciana Parish, Louisiana 1
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'7 611 Ryan Plaza Drive, Suite 1000 9
Arlington, TX 76011 te -
Mr. Walt Paulson.' Project Manager j
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U.S.: Nuclear Regulatory Commission-
-Washington, D.C. 20555 l
1 NRC Resident Inspecto-Post Office' Box 1051-St. Francisv111e LA 70775
'l Mr. William H. Spell, Administrator i
Nuclear Energy Division Louisiana Department of Environmental Quality j
Post Office Box 14690:
Baton Rouge,-LA 70898-i j
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ATTACHMENT GULF STATES UTILITIES COMPANY RIVER BEND STATION DOCKET 50-458/ LICENSE NO. NPF-47 AC SOURCES - Operating (89-05)
LICENSING DOCUMENT INVOLVED:
TECHNICAL SPECIFICATIONS ITEMS:
4.8.1.1.2.f.4 PAGE: 3/4 8-7 4.8.1.1.2.f.8 3/4 8-8 Footnote ##
3/4 8-8 Footnote ###
3/4 8-6, 7, 8, and 9 REASON FOR REQUEST:
In accordance with 10CFR50.90, a change is being requested to modify the requirement to perform a simulated loss of offsite power test of the diesel generators (DGs) within five minutes of performing a required 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run.
River Bend Station (RBS) Technical Specification Surveillance Requirement 4.8.1.1.2.f.8 currently requires that a simulated loss of offsite power (LOP)-
test per Surveillance Requirements 4.8.1.1.2 f.4.a)2) and b)2) be performed within 5 minutes of completing the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run. Regulatory Guide 1.108 Position C.2.a(5), which is the basis for the requirement to perform the LOP test immediately following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run, states that the purpose of this requirement is to " demonstrate functional capability at full load temperature conditions."
Surveillance. Requirement 4.8.1.1.2.f.8 currently allows an acceptable alternative to:reperforming the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run if the LOP test is not satisfactorily completed.
Under these conditions, footnote ##_ allows the DG to be operated at full load for one hour or until operating temperatures have stabilized prior to performing the LOP test.
During refueling outages, the requirement that the LOP test to be scheduled within 5 minutes of completing the 24-hour run reduces scheduling flexibility, unnecessarily constrains outage activities, and creates the potential for critical path schedule complications and delays.
Therefore, GSU proposes separating the requirements for the LOP test from the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run. A requirement for stabilization of~ full load operating temperature;
. prior to initiating the LOP test will be added as Surveillance Requirement 4.8.1.1.2.f 4.c), and will replace the current requirements of Surveillance 4.8.1.1.2.f.8 to perform the LOP test within five minutes of completing the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run.
Due to the increased scheduling flexibility allowed by this proposed change and to allow adequate time for refueling outage scheduling, this proposed change is requested to be approved by July 31, 1990.
Page 1 of 4
A further editorial change is being proposed to delete footnote H # which was approved,by the NRC in Amendment 9 to the RBS Technical Specifications to allow specific surveillances to be delayed to coincide with completion of the first refueling outage.
This refueling outage has been completed and this footnote serves no current or future purpose.
Therefore, GSU proposed l
deletion of footnote #H.
DESCRIPTION:
The 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run required by Surveillance Requirement 4.8.1.1.2.f.8 demonstrates that the DG is capable of carrying the required loads for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, that voltage and frequency requirements are maintained during this test, and that the cooling system functions within design limits.
Regulatory Guide 1.108 Position C.2.a(5), which is the basis for the requirement to perform the LOP test immediately following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run, states that the purpose of this requirement is to " demonstrate functional capability at full load temperature conditions." Separating the two tests does not invalidate or reduce the effectiveness of either test, provided full load temperature conditions are achieved prior to performing the LOP test.
To ensure that the intent of Regulatory Guide 1.108 Position C.2.a(5) is met, a requirement for DG operation for a sufficient period of time to allow stabilization of full load operating temperatures prior to performing the LOP test has been added.
This alternative method of establishing full load temperature conditions is already offered as an optional prerequisite in the RBS Technical Specifications if the DG fails to successfully complete the initial LOP test following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run (reference footnote ## of page 3/4 8-8).
This proposal has been reviewed by the manufacturer (Cooper Industries) who concurred the diesel operating parameters will be stable within one hour of a start from standby and the additional 23 hours2.662037e-4 days <br />0.00639 hours <br />3.80291e-5 weeks <br />8.7515e-6 months <br /> will serve no purpose.
Additionally, the NRC has previously reviewed and approved similar. testing changes at other plants (i.e.,
McGuire Nuclear Station - Units 1 and 2, Amendments Nos. 71 and 52 to License Nos.
NPF-9 and NPF-17, respectively, dated May 6,1987; and Grand Gulf Nuclear Station - Unit 1. Amendment No. 52 to License No. NPF-29, dated December 12,1987). The NRC reviews conducted for these amendment requests are applicable to this proposed change.
In summary, the NRC staff found that conducting the simulated loss of offsite power test (i.e.,
the LOP test) after DG operating temperatures have stabilized at full load conditions fulfills the intent of conducting this test following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run.
NO SIGNIFICANT HAZARDS CONSIDERATIONS:
As required by 10CFR50.92, the following is provided to the NRC staff in support of a "no significant hazards considerations" determination.
1.
No significant increase in the probability or consequences of an accident previously evaluated results from this proposed change because:
Page 2 of 4
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As stated in Regulatory Guide 1.108, the LOP test required by Technical Specification 4.8.1.1.2.f.P demonstrates that the DG can start and accept-t the required loads in the pr= scribed time when the DG is at its full load operating temperature.
This provides assurance that the DG is capable of responding to a loss of offsite power as assumed in the accident analysis.
Because the purpose of performing the LOP test innediately following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run is to demonstrate the functional capability of the DG at full load temperature conditions, establishing full load temperature conditions with other than a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run provides the necessary initial conditions for the LOP test in order to satisfy the intent of Regulatory Guide 1.108 Position C.2.a(5).
The proposed method of establishing full load temperature conditions has been previously reviewed by the NRC and found to be an acceptable alternative to the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run. Additionally, DG design and function remain as previously analyzed.
Therefore, the DG's proposed response during accident conditions is not affected due to this change.
The proposed change to delete footnote ### is editorial only.
This footnote: was applicable to a refueling outage which has been completed.
Hence, this footnote serves no current or future purpose.
Therefore, no significant increase in the consequences of an accident previously evaluated results from these proposed changes.
2.
This proposed change would not create the possibility of a new or different kind of accident from any previously evaluated because:
This request does not involve a physical change in any system's configuration and no new modes of operation are introduced. This change will not result in reduced testing and will not affect DG re11 ability.
Additionally, the LOP test initial conditions contained in the proposed change are consistent with those currently allowed. The proposed change to delete footnote ### is editorial only.
This footnote was appliable to a refueling outage which has been completed. Hence, this footnote serves no current or future purpose.
~Therefore, these proposed changes do not create the possibility of a new or different kind of accident from any previously evaluated.
3.
This proposed change would not involve a significant reduction in the margin of safety because:
Allowing the DG to reach full load temperature conditions by means other than the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run required by Surveillance Requirement 4.8.1.1.2.f. 8 has previously been found acceptable by the NRC staff for satisfying the intent of this surveillance requirement.
This proposed change will not result in reduced testing and will not affect DG reliability.
The proposed change will adequately demonstrate the DG's functional capability at full load temperature conditions, thus ensuring the designed margin of safety in the DG's ability to start and accept the required loads within the required time limits.
The proposed change to delete footnote ### is editorial only. This footnote was appliable to a Page 3 of 4 i
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refueling outage which has been completed.
Hence, this footnote serves 1
no current or future purpose.
Therefore, these proposed changes will not involve reduction in the margin of safety.
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The proposed change as discussed above, has not changed the system design-function or operation as discussed in the USAR and therefore, will not increase the probability or the consequences of a previously evaluated I
accident and will not create a new or different accident. Adequate assurance i-of DG availability is maintained by establishing the required initial conditions of the LOP test by means other than the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run.
- Also, the results of the change are within acceptable criteria with respect to system components and design requirements. As a. result, the ability to perform as i
described in the USAR is maintained and therefore, the proposed change does not result in a significant reduction in the margin of safety.
Therefore, GSU concludes that no significant hazards are involved.
REVISED TECHNICAL SPECIFICATION:
The requested revision is provided in the Enclosure.
SCHEDULE FOR ATTAINING COMPLIANCE:
'As indicated above, River Bend Station is currently in compliance with the applicable Technical Specification requirements.
Due to the increased scheduling flexibility allowed by this proposed change and to allow adequate time for refueling outage scheduling, this proposed change is requested to be approved by July 31, 1990.
NOTIFICATION OF STATE PERSONNEL:
l A copy of this amendment request has been provided to the State of Louisiana, Department of Environmental Quality - Nuclear Energy Division.
1 ENVIRONMENTAL IMPACT APPRAISAL:
l Gulf States _ Utilities Company (GSU) has reviewed the proposed license l
amendment against the criteria of 10CFR51.22 for environmental considerations. The proposed changes do not involve a significant hazards consideration, nor increase the types and amounts of effluents that may be released offsite, nor significantly increase individual or cumulative occupational radiation exposures. Based on the foregoing, GSU concludes that the proposed change meets the criteria given in 10CfM51.22(c){9) for a categorical exclusion from the requirement for an Environmental Impact Statement.
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EllCLOSURE Revised Technical Specification Pages I
~ INSERT 1 for page 3/4 8-7 c) 0perating** with the diesel generator loaded to 3000 3100 kW***
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-diesel generators.1A and 18 and 2500 - 2600 kW *** for diesel-generator b
IC' for at least 60 minutes or until operating temperatures-- have-
-stabilized.
Within 5 minutes after completin this test, perform
- Surveillance Requirement 4.8.1.1.2.f.4.a)2) and b)g).
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- Momentary transients due to changing bus loads shall not invalidate the test..
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