ML20043G102

Requests Temporary Waiver of Compliance from Requirements of Action Statement 27 of Tech Spec 3.3.2 for Period of 6 H When Two Operating Control Room Emergency Filtration Sys Trains Shut Down for Required Testing

ML20043G102
Person / Time
Site:	Vogtle
Issue date:	06/06/1990
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
ELV-01738, ELV-1738, NUDOCS 9006190059
Download: ML20043G102 (3)

Text

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q Georg.a Power Company 333 Piedmont Awnue Atianta, Georg a 30308 lelephone 404 s26 3195 Mair,g Address 40 lnverness Center Parkway Post Once Dox 1295 Birmingharn. Alabama 35201 Tetophone 005 868 5581 June 6, 1990 ,, , ,,

w. o. Heir $ ton, iii NMM sen.or vec Pms dent 0417 Nuclear Operat.ons Docket Nos. 50-424 50-425 l

U. S. Nuclear Regulatory Commission  ;

Region II - Suite 2900 101 Marietta Street, N. W.

Atlanta, Georgia 30321 Gentlemen:

V0GTLE ELECTRIC GENERATING PLANT RE00EST FOR TEMPORARY WAIVER OF COMPLIANCE l Technical Specification (TS) Surveillance Requirement 4.3.2.2 requires that each

Engineered Safety Features Actuation System (ESFAS) function response time be demonstrated to be within its limit at least once per 18 months. In reviewing i the data from the ESFAS 18 month surveillance completed during the recent Unit 1 outage, Georgia Power Company (GPC) discovered that the response time for the Control Room Emergency Filtration System (CREFS) Actuation had not been  ;

adequately verified due to procedural content inadequacies. A further review  !

l revealed that the response time for the Unit 2 CREFS had likewise not been  !

l~ adequately verified. As a consequence, all four instrumentation channels were l l declared inoperable and two CREFS trains were placed in operation in the  ;

emergency mode in accordance with Action Statement 27, Table 3.3-2, TS 3.3.2. j i

In order to obtain a complete response time for the CREFS, the diesel generator

!- sequencer loading delays and fan response times will have.to be measured. The i measurement of the diesel generator sequencer loading delays can be accomplished within the provisions of the Technical Specifications. However, in order to i measure-the response time of the CREFS fans, the two operating CREFS trains will have to be shut down.- When they are shut down, we will no longer be able to "

meet the requirements of the Limiting Condition for Operation as provided in the ,

- associated. Action requirements, which would necessitate a deliberate entry into i LTS. 3.0.3. In order to avoid a deliberate entry into TS 3.0.3 and to accomplish  ;

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this required portion of the response time testing, GPC requests a temporary waiver of compliance from the requirements of Action Statement 27 of TS 3.3.2 4 for a periodLof six hours. Six hours is requested in order to allow I approximately two hours to perform the testing and an additional four hours to perform any troubleshooting or evaluation which may be required. GPC will minimize the amount time that the fans are shut down.

1 Our justification for this temporary waiver of compliance is as follows:

1. The portion of the test which requires the fans to be shut down can be accomplished in a relatively short period of time. We believe the testing can be performed in less than two hours, barring any unforeseen 90061900'39 900606 PDR ADOCK 05000424 P PDC 7

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i 5 l V. S. Nuclear Regulatory Commission ELV-01738 Paae Two difficulties. Therefore, the plant would be in this condition (i.e.. all four CREFS channels inoperable with no CREFS trains operating) for a very-short period of time.

2. A temporary waiver of compliance would eliminate the distraction of having to prepare for a plant shutdown (as required in the first hour of operation under TS 3.0.3) while performing the required surveillance.

This is consistent with the conclusions of the NRC staff as discussed in Generic Letter 87-09.

3 The CREFS meets all TS Surveillance Requirements with the exception of ESFAS response time testing, and, based on the response time testing which has been performed, we fully expect the response time to be within limits. Therefore, we believe the CREFS to be capable of performing its intended safety function.

4. The CREFS can be manually or automatically actuated during the testing should the need arise.

5. A procedure for obtaining fan response times will be reviewed and approved by the Plant Review Board. A separate procedure will be written for obtaining the sequencer loading delays. However, testing of the sequencer loading delays is not a part of this temporary waiver of compliance.

6. The proposed temporary waiver of compliance does not involve a significant hazards consideration. The probability or consequences of any accident previously evaluated are not affected. The proposed waiver does not create the possibility of a new or different kind of accident than any previously evaluated, and there is no reduction in margin of safety. Furthermore, there are no irreversible environmental consequences.

7. Finally, the Plant Review Board has reviewed and approved this request for a temporary waiver of compliance.

On the basis of the above discussion, GPC requests this temporary waiver of compliance from the requirements of Action Statement 27 of TS 3.3.2 for a period of six hours to begin when the two operating CREFS trains are shut down for the

. - , s U. S. Nuclear Regulatory Commission ELV-01738 Paae Three required testing. We expect to perform response time testing of the fans upon review and approval of the required procedure and NRC' approval of this request -

for a temporary waiver of compliance.

Please contact this office if you have any questions -

s N

W. G. Hairston, 111 /

WGH,Ill/NJS/gm xc: Georaia power Comoany  !

Mr. C. K. McCoy Mr. G. Bockhold, Jr.

Mr. P. D. Rushton Mr. R. M. Odom NORMS U. S. Nuclear Reculatory Commission Mr. S. D. Ebneter, Regional Administrator 1 l Mr. T. A. Reed, Licensing Project Manager, NRR I Mr. B. R. Bonser, Senior Resident Inspector, Vogtle

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