ML20073G411

Safety Evaluation Supporting Amends 75 & 54 to Licenses NPF-68 & NPF-81,respectively

ML20073G411
Person / Time
Site:	Vogtle
Issue date:	09/21/1994
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML20073G401	List: ML20073G399 ML20073G411
References
NUDOCS 9410040168
Download: ML20073G411 (7)

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UNITED STATES j

j NUCLEAR REGULATORY COMMISSION t

WASHINGTON, D.C. 20086 4 001 SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION RELATED TO AMENDMENT NO. 75 TO FACILITY OPERATING LICENSE NPF-68 1

AND AMENDMENT NO. 54 TO FACILITY OPERATING LICENSE NPF-81 GEORGIA POWER COMPANY. ET AL.

V0GTLE ELECTRIC GENERATING PLANT. UNITS 1 AND 2 DOCKET NOS. 50-424 AND 50-425

1.0 INTRODUCTION

By letter dated April 28, 1994, supplemented by letter dated July 29, i

1994, Georgia Power Company, et al. (the licensee) proposed license j

amendments to change the Technical Specifications (TS) for Vogtle Electric Generating Plant (Vogtle), Units 1 and 2.

The proposed changes would eliminate certain Surveillance requirements for the emergency j

diesel generators (EDGs). These changes are in accordance with the

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NRC Technical Specification Improvement Program as documented in l

Generic Letter (GL) 93-05, "Line-Item Technical Specifications Improvements For Testing During Power Operation," dated i

September 27, 1993, NUREG-1366, " Improvements To Technical Specifications Surveillance Requirements," dated December 1992, and Regulatory Guide 1.9, Revision 3, " Selection, Design, Qualification, And Testing Of Emergency Diesel Generator Units Used As Class IE Onsite Electrical Power Systems At Nuclear Power Plants," dated July 1993.

By letter dated July 29, 1994, the licensee submitted a revision to their original request by withdrawing a T/S change to Table 4.8-1, Diesel Generator Test Schedule, and S/R 4.8.1.1.3, reporting requirements and its referene-in S/R 4.8.1.2 of T/S 3/4.8.1.2. This is because the staff had requesf 4 the licensee to commit to GL 94-01 in order to eliminate acceleratet urting requirements and the reporting requirements for EDGs.

The licensee stated that they cannot, at this time, commit to the conditions of GL 94-01. Also, there were teleconferences between representatives of the licensee and the NRC staff on July 19 and 20, 1994, to discuss the above changes.

The July 29, 1994, letter provided a revision to tlie proposed amendment and did not change the initial proposed no significant hazards 4

consideration detemination.

2.0 EVALUATION The staff has reviewed the proposed changes submitted by the licensee as i

follows:

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1. DTE:

Strikeouts denote deletions and shaded portions denote additions.

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9410040168 940921 PDR ADOCK 05000424 P

PDR.

. 2.1 Revision to Existino T/S Section 3.8.1.1 Action Statements a.b.c.e and f Revised Action a: With one offsite circuit of the above-required A.C.

electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.1.1.1.a within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter.

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Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Revised Action b: With either diesel generator inoperable, demonstrate the OPERABILITY of the above required A.C. offsite sources by performing Surveillance Requirement 4.8.1.1.1.a within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter._$iijp_pgab}Mhfpp%!iy~RE7ffMiBopendgg@i_$$39R55If th cause other than sh

~si prepfahned1Feventive maintehsce ir 'tisting, ^demonitrate ti6kiiBHHt"siUTY of the remaining OPERABLE diesel generator by performin thi'0PERAB Surveillance Requirements 4.8.1.1.2.*r4 53 and 4.8.1.1.2.a.5 within 44 I hou rs 9EET6sittlisliirsaiF6EaiutJpot~e~nt1 Sjlgs]BqEEEE

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e BiisiT generiG^hganeratorli r ti~0PERABL itus witM 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD Shutdown within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

Revised Action c: With one offsite circuit and one diesel generator of the above required A.C. electrical power sources inoperable, demonstrate the OPERABILITY of the remaining A.C. offsite source by performing Surveillance Requirement 4.8.1.1.1.a within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter, and, "if the diese_h_po@i i generator became ino erable due to anycauseotherthansjjn~op~gTaiMg3p jM ljl demonstrate: poggnEt st pri~piihhsd pFiveita lie mitn enance or t'ng, M MiNethe OPERABILITY of the remaining OPERABLE diesel generator by performing Surveillance Requirements 4.8.1.1.2.*r4 M and 4.8.1.1.2.a.5 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> *,'eliiisiiiusfGiggibfistill* generator _digiQ~M unless the OPERABLE diesel is already operatin, ~ 76siEth Miissiso

_t FeIE1 WiiMemongtatsd Restdre~at leisE on o the PERABLEstitu(swithn12hoursorbeinatleast Th5' ira ~ e sources p

HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore the other A.C. power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the provisions of 3.8.1.1, ACTION Statement a or b, as appropriate, with the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable A.C. power source. A successful test of diesel generator OPERABILITY per Surveillance Requirements 4.8.1.1.2.ev4 % and 4.8.1.1.2.a.5 performed under the ACTION Statement for an OPERABLE d<esel generator or a restored to OPERABLE diesel generator satisfies the diesel generator test requirement of ACTION Statement e-ee b.

l 3-Revised Action e: With two of the above required offsite A.C. circuits inoperable, f:- ::tr:t: th: 0."E"*"!LITY cf t:0 di:::1 ;; :r;t:r;

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lr::dy :;:r:tta;, restore at least one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />.

Following restoration of one offsite source, follow ACTION Statement a with the time requirement of that ACTION Statement based on the time of the initial loss of the remaining inoperable offsite a.c. c.,ircuit.,", :::::::ful t::t(:) :f di:::1 0."E"*"!LITY ;r e.._..

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Revised Action f: With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by

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performing the requirements of Specification 4.8.1.1.1.a. within I hour and at least once per 8 holes thereafter; restore at least one of the i

inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within t

the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Following restoration of one diesel generator unit, follow ACTION Statement b with the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable diesel generator. A successful test of diesel OPERABILITY per SurveillanceRequirements4.8.1.1.2.or4k3.and4.8.1.1.2.a.5 performed under this ACTION Statement for a restored to OPERABLE diesel satisfies i

the diesel generator test requirements of ACTION Statement b.

t These proposed changes are based on the recommendations of NUREG-1366 which state that when one EDG is inoperable due to causes other than j

preplanned preventive maintenance, an inoperable support system, or an independently testable component; testing of the remaining EDGs should be limited to those cases where the cause for inoperability has not been j

conclusively demonstrated to preclude the potential for a common mode failure. Therefore, testing of the remaining EDGs occurs only when the cause for inoperability could affect the remaining EDGs. This change also eliminates the need to test the EDGs in the event of an inoperable offsite circuit (s). NRC Information Notice 84-69 warns that disturbances on the offsite source can adversely affect EDG reliability when an EDG is operated in parallel with the offsite sources. Therefore, EDG availability is potentially lessened by requiring a demonstration of operability which connects the EDG to the same grid being supplied by offsite AC power. The deletion of the TS requirement to start and load operable EDGs when an offsite AC source becomes inoperable does not increase the probability that the operable EDGs will be unable to perform their safety function. Therefore, in accordance with GL 93-05, Item 10.1, which is based on the recommendations of NUREG 1366, the licensee is requesting that Vogtle Units 1&2 TS be amended to delete the r

requirement to conduct operability testing of the EDGs when one or both offsite AC sources become inoperable. The staff finds the above changes to be consistent with GL 93-05 and acceptable.

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. 2.2 Revision to Existina S/R Section 4.8.1.1.2.a.4 Revised S/R 4.8.1.

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,:t:rt zi;;:1. The diesel generator shall be started for this test by using one of the following Signals:

a)

Manual, or b)

Simulated loss-of-offsite power by itself, or c)

Simulated loss-of-offsite power in conjunction with an ESF Actuation test signal, or d)

An ESF Actuation test signal by itself.

The proposed change allows for routine monthly testing by gradually accelerating the EDG to operating speed as opposed to requiring the EDG to attain rated voltage and frequency within 11.4 seconds. The licensee is replacing the governors on the EDGs with a model that will give the EDG units slow start capability. However, when the EDGs are in standby for emergency operation, or when one EDG is inoperable and the remaining operable EDG must be tested pursuant to the action statement, they will i

continue to fast start in accordance with their emergency function.

NUREG-1366 states, in part, that fast starting has the potential to accelerate the degradation of EDGs. Also, R.G. 1.9, Revision 3, i

Section 2.2.1, states, in part, that for these start tests the emergency t

diesel generator can be slow started and reach rated speed on a prescribed schedule that is selected to minimize stress and wear. This i

change is consistent with the recommendations of NUREG-1366 and R.G.1.9, Revision 3.

The staff finds this change to be acceptable.

2.3 Revision to Existina S/R Section 4.8.1.1.2.a.2 Revised S/R 4.8.1.1.2.a.2:

Verifying the generator is synchronized, loaded to an indicated value f 5100 7000 X'd"' in 1::: th:2 Or : ::1 t:

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(({EN"MMIEGE for at least 60 minutes.with : 10:d of 6800-7000 KWi***t 50 :::::d:

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perfirmec so it coiscides with the testing required by Surveillance Requirement 4.8.1.1.2.a.5, may also serve to concurrently meet those requirements as well.

The proposed change allows the EDG to be loaded gradually to 6800-7000 kW rather than requiring the EDG to be loaded to 6100-7000 kW in less than or equal to 60 seconds.

R.G. 1.9, Revision 3, Section 2.2.2, states, in part, that the loading and unloading of an emergency diesel generator during this test should be gradual and based on a prescribed schedule that is selected to minimize stress and wear. Also, NUREG-1366 states, in part, that fast loading during surveillance testing is the most significant cause of accelerated degradation of EDGs.

In accordance with GL 93-05, the licensee is requesting that the Vogtle Units 1 & 2 TS be

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. amended to delete the fast loading requirements and allow gradual loading for all surveillance requirements, with the exception of the loss of offsite power tests that are performed with and without an ESF sigial once each refueling, be performed by gradual loading in accordance with the manufacturer's recommendations. This change is consistent with R.G. 1.9, Revision 3, and GL 93-05 which is based on the recommendations of NUREG-1366. The staff finds this change to be acceptable.

2.4 Revision to Existina S/R Section 4.8.1.1.2.h Revised S/R 4.8.1.1.2.h.7:

Verifying the diesel generator operates for i

at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded to an indicated 7600 to 7700 KW,** and during i

the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded to an indicated 6800-7000 KW.**

The generator voltage and frequency shall be 4160 + 170, -135 volts and 60 i 1.2 Hz within 11.4 seconds after the start signal; the steady-state generator voltage and frequency shall be 4160 + 170, -410 volts and 60 1 1.2 Hz during this test.# W4%4*-4 Add New S/R 4.8.1.1.2.h.8:

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The proposed change to S/R 4.8.1.1.2.h.7 separates the 24-hour endurance run from the hot restart test. As a result, new S/R 4.8.1.1.2.h.8 would be created to require the hot restart test. The purpose of the hot restart test is to ensure that the EDG does not in any way have impaired performance following operation at full load or equilibrium temperature.

In order to ensure that the EDG is at full load equilibrium temperature for the hot restart test, the new SR would require that the EDG be l

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 a load of 6800-7000 Kw. Within 5 minutes of shutdown, the EDG would be restarted and required to attain rated voltage and frequency within 11.4 seconds. Separating these two required tests gives plant operations added flexibility in scheduling these tests and prevents them from becoming the source of critical path complications during outages. Also, NUREG-1366 states that "There is no safety reason for performing a startup of a diesel within 5 minutes of the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test run as is required by Technical Specifications." The proposed new SR would continue to ensure the hot restart capability of the EDGs. This change is consistent with the recommendations of NUREG-1366 and is acceptable.

Revisions to Existing S/R Sections 4.8.1.1.2.h.8, 9, 10, 11, and 12:

These S/Rs would be renumbered to accommodate the addition of new S/R 4.8.1.1.2.h.8.

Footnote ## would be deleted since it would be no longer required. These proposed changes are administrative in nature and acceptable.

. 2.5 Revision to Existino Bases 3/4.8.1. 3/4.8.2. and 3/4.8.3 Revised Bases 3/4.8.1. 3/4.8.2. and 3/4.8.3: The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are based on the recommendations of Regulatory Guides 1.9, Revision 4 l'

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esiffpdbas Bj@s65(ejlL&6sg18tqgLvi!stpfor3Tistiss The proposed changes are administrative in nature and are consistent with the above T/S changes. The staff finds these changes to be acceptable.

2.6

SUMMARY

The licensee's proposed changes are based on the recommendations of R.G. 1.9, Revision 3, NUREG-1366 and GL 93-05. These changes are expected to result in improvements in diesel generator testing and reduced degradation due to excessive testing. As such, the proposed changes should result in improved diesel generator reliability, thereby providing additional assurance that the diesel generators will be capable of performing their safety function. Therefore, the proposed changes will not significantly increase the probability or consequences of any accident previously evaluated. The staff finds these proposed changes to be acceptable.

3.0 STATE CONSULTATION

In accordance with the Commission's regulations, the Georgia State official was notified of the proposed issuance of the amendments. The State official had no comments.

4.0 ENVIRONMENTAL CONSIDERATION

The amendments change requirements with respect to installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20. The NRC staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite, and that there is no significant increase in individual or cumulative occupational radiation exposure. The Commission has previously issued a proposed finding that the

. amendments involve no significant hazards consideration, and there has been no public consent on such finding (59 FR 39590 dated August 3,1994).

Accordingly, the amendments meet the eligibility criteria for categorical exclusion set forth in 10 CFR 51.22(c)(9). Pursuant to 10 CFR 51.22(b) no environmental impact statement or environmental assessment need be prepared in connection with the issuance of the amendments.

5.0 CONCLUSION

The Commission has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such I

activities will be conducted in compliance with the Comission's regulations, l

and (3) the issuance of the amendments will not be inimical to the common I

defense and security or to the health and safety of the public.

Principal Contributor:

C. Thomas EEL 8/DE

0. Chopra EELB/DE Date: September 21, 1994 l

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