ML20100M723

Requests That Listed SR Not Be Required Immediately Upon Implementation of Improved TS

ML20100M723
Person / Time
Site:	Vogtle
Issue date:	02/29/1996
From:	Mccoy C GEORGIA POWER CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
LCV-0603-J, LCV-603-J, TAC-M92131, TAC-M92132, NUDOCS 9603050494
Download: ML20100M723 (3)

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• Georgia Power Company ~

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40 invemess Center Pathway.

Post Off ce Box 1295 -

Bir&ngham, Alabarna 35201 Telephone 205 877 7122 C. K. McCoy - .. GeorgiaPower Vce President, Nuclear the southern e&tre system l

Vogtte Progect February'29, 1996 r

i LCV-0603-J B

Docket Nos. 50-424 50-425 Tac Nos. M92131 M92132 I +

U. S. Nuclear Regulatory Commission -

i ' ATrN: Document Control Desk  ;

l. Washington, D. C. 20555 l

l Gentlemen:  ;

VOGTLE ELECTRIC GENERATING PLANT 4' PROPOSED CONVERSION OF TIIE UNIT 1 AND UNIT 2  ;

i TECIINICAL SPECIFICATIONS BASED ON NUREG-1431

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In preparation for implementation of the improved Technical Specifications (ITS), which is planned to occur between the Spring Unit I refueling outage and the Fall Unit 2 refueling .

outage, Georgia Power Company (GPC) has reviewed the surveillance requirements that will .

be contained in the ITS. As a result of that review, GPC has identified a limited number of surveillances that will not be current at the time ofimplementation due to changes in these surveillances resulting from the conversion.

Therefore, GPC requests that the following surveillance requirements (SRs) listed below not be required immediately upon implementation of the improved TS; they will instead be required in accordance with the piovisions stated below:

l Unit 1:

SR 3.8.4.7 - This SR states that a modified performance discharge test may be performed in li_cu of a service test whereas the current Technical Specification (CTS) 4.8.2.1.e, Table 4.8- ,

. 3, note 2, states that a performance test may be substituted for the service test once per 60- I month interval.' This SR may not be performed in . Modes 1,2,3, or 4. For the Unit I batteries, until operation under the improved TS begins, the CTS surveillance requirement for

.. battery service tests will be met because the performance test will be performed in lieu of the I service test, in accordance with CTS 4.8.2.1.e, Table 4.8-3, note 2. Since the modified  !

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. U. S. Nuclear Regulatory Commission LCV-0603-J Page 2 performance test is a more restrictive test, upon implementation of the ITS, SR 3.8.4.7 would not be met.

Therefore, GPC requests that SR 3.8.4.7 not be required prior to entering Mode 4 until the first startup after the 7th Unit I refueling. Thus, the current TS provision that the battery performance test may be performed in lieu of the service test (CTS 4.8.2.1.e, Table 4.8-3, note 2) would be extended to the first entry into Mode 4 following the 7th Unit I refueling.

Unit 2:

SR 3.8.1.8 - This SR involves verifying that the DGs are capable of withstanding rejection of the single largest post accident load once per 18 months. The CTS version of this SR, 4.8.1.1.2.h.2, does not contain requirements on frequency. Therefore, GPC requests that SR 3.8.1.8 not be required prior to entering Mode 4 until the first startup after the 5th Unit 2 refueling. This reliefis requested because of the more restrictive requirements that (1) following load rejection, the frequency is 5 64.5 hz; and (2) within 3 seconds following load ,

I rejection, the frequency is > 58.8 hz and 5 61.2 hz.

SR 3.8.1.9 - This SR verities that each DG is capable of withstanding a load rejection of 2 6800 kW and 5; 7000 kW once per 18 months. The CTS version of this SR,4.8.1.1.2.h.3, does not contain a requirement that the DG be operating at a kVAR load as close as practicable to 3390 kVAR. Therefore, GPC requests that SR 3.8.1.9 not be required prior to entering Mode 4 until the first startup after the 5th Unit 2 refueling. This reliefis requested because of the more restrictive requirement in the SR that each DG be operating as close as practicable to 3390 kVAR.

SR 3.8.1.11 - This SR requires verification that the DGs automatically start on a simulated or actual Engineered Safety Feature (ESP) actuation signal. The CTS version of this SR, 4.8.1.1.2.h.5. does not include the acceptance criteria that permanently connected loads remain energized from the offsite power system, and that emergency loads are energized or auto-connected through the automatic load sequencer from the ofTsite power system.

Therefore. GPC requests that SR 3.8.1.11 not be required prior to entering Mode 4 until the first startup aller the 5th Unit 2 refueling. This reliefis requested because of the more restrictive requirements in the SR that (1) permanently connected loads remain energized from the offsite power sysu.m (2) emergency loads are energized or auto-connected through the automatic load sequencer from the offsite power system.

SR 3.8.1.13 - This SR is the 24-hour run of the DGs. The CTS version of this SR, 4.8.1.1.2.h.7, does not contain any criteria related to kVAR loading at the required power levels. Therefore, GPC requests that SR 3.8.1.9 not be required prior to entering Mode 4 until the first startup after the 5th Unit 2 refueling. This reliefis requested because of the

. more restrictive requirements in the SR that each DG be operating (1) as close as practicable l

. UsS. Nuclear Regulatory Commission LCV-0603-1 Page 3 3390 kVAR during operation at 2 6800 and s 7000 kW and operating (2) as close as practicable to 3730 kVAR during operation 2 7000 and 5 7700 kW.

SR 3.8.1.20 - This SR requires both DGs to be started simultaneously and verified to operate within specified voltage and frequency limits. The CTS version of this SR,4.8.1.1.2.i, does not contain soecified voltage and frequency limits. Therefore, GPC requests that SR 3.8.1.20 not be required until the next required performance of this SR. This reliefis requested because of the more restrictive requirements that both DGs achieve (1) voltage 2 4025 V and s 4330 V: and (2) frequency 2 58.8 hz and s 61.2 hz.

Based on the above discussion, GPC requests relief from the aforementioned surveillance requirements.

Sincerely, C. K. McCoy CKM/NJS xc: Georgia Power Comnany Mr. J. B. Beasley, Jr.

Mr. M. Sheibani NORMS U. S. Nuclear Regulatory Commission Mr. S. D. Ebneter, Regional Administrator Mr. L. L. Wheeler. Licensing Project Manager, NRR Mr. C. R. Ogle, Senior Resident Inspector, Vogtle 1

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