3F0188-15, Application for Amend to License DPR-72,consisting of Change Request 160,revising Tech Specs to Provide Specific Actions When One Battery Supplying Dc Control Power to 120 Kv Switchyard Breakers Inoperable.Fee Paid
| ML20148E490 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 01/20/1988 |
| From: | Wilgus W FLORIDA POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| Shared Package | |
| ML20148E493 | List: |
| References | |
| 3F0188-15, 3F188-15, NUDOCS 8801260046 | |
| Download: ML20148E490 (8) | |
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e.e Florida Power CORPORATION January 20, 1988 3F0188-15 Document Control Desk U.
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Nuclear Regulatory Commission Washington, DC 20555 FUBJECT:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification Change Request No. 160
Dear Sir:
Flcrida Power Corporation (FPC) hereby submits Technical Specification Change Request No.
160 requesting amendment to Appendix A
of Operating License No.
As part of this request, the proposed replacement pages for Appendix A sre provided.
This submittal proposes to revise tha Technical Specifications to provide specific actions to be taica when one of the batteries supplying E0 cont.ol power to the 230 kv switchyard breakers is inoperable.
The change also proposes to revise the time Crystal River 3 (CR-3) is allowed to operate with one of these batteries inoperable.
This change is needed to allow testing of the Crystal River Unit 2 battery during an outage on that unit scheduled to begin on April 25, 1988.
An amendment application
- fee, check number 19328 of one hundred fifty dollars ($150), as required oy
- 10CFh170, has been included with this Change Request.
Since ely, hR AOK h2 P
Vice P sident k
(d g i Nuclear Operations I I AEF:dhd
- gf cc:
See Next Page
/
Post O'fice Box 219
- Crystal River, Florida 32621
- Telephone (904) 795 3802 A Florida Progress Comcany
January
'0, 1988 4
.3F0188-15 Page 2
'Attechments-cc:
Dr.
J.
Nelson Grace Regional Administrator, Region II Mr.
T.
F.
Stetka Senior Resident Inspector
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UNITED STATES OF AMERICA NUCLEAR-REGULATORY COMMISSION IN THE MATTER
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DOCKET No.
50-302 FLORIDA POWER CORPORATION
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CERTIFICATE OF SERVICE W.S.
Wilgus deposes and says that the following has been served on the Designated State Representative and Chief Executive of Citrus County, Florida, by deposit in the United States mail, addressed as follows:
- Chairman, Administrator Board of County Commissioners Radiological Health Services of Citrus County Department of Health and Citrus County Courthouse Rehabilitative Services Inverness, FL 32650 1323 Winewood Blvd.
Tallahassee, FL 32301 A copy cf Technical Specification Change Request No. 160, Revision 0 requesting Amendment to Appendix A of Operating Licensing No.'DPR-72.
FLORIDA POWER CORPORATION W.ST Wil Vice President Nuclear arations SWORN TO AND SUBSCRIBED BEFORE ME TilIS 20TH DAY OF JANUARY 1988.
0 SY N tary Public Notary Public, State of Florida at Large My Commission Expires:
June 21, 1991
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STATE OF FLORIDA
' COUNTY-OF CITRUS-
-W.S.;Wilgus_ states that he is.the Vice President,_ Nuclear Operations for Florida Power Corporation; that he is. authorized-on the.part of
- said company te sign and file ~with the Nuclear Regulatory Commission the information.au ached hereco; and that all such statements made
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and matters set forth therein are true and correct to the best'of his knowledge, infor mation, and belief.
L V.S.
Miigu, Vice President Nuclear Operations Subscribed and sworn to before me, a Notary Public in and for the
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State and County above named, this 20th day of January 1988 W.
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1 Notary Public, State of Florida at Large, My Commission Expires:
June 21, 1991
FLORIr3 POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302/ LICENSE NO. DPR-72 REQUEST NO. 160, REVISION 0 ELECTRICAL POWER SYSTEMS LICENSE DOCUMENT INVOLVED: Technical Specifications PORTION: 3/4.8.1.1 AC Sources - Operating 3/4.8.1.2 AC Sources - Shutdown DESCRIPTION OF REQUEST:
This change will add an action statement to the Limiticc condition
.for Operation to provide for specific actions to be taken when one of the batteries or chargers supplying DC control power to the 230 kv' switchyard breakers is inoperable.
This change will also more explicitly state the surveillances to be performed in Modes 5 and 6.
REASON FOR REQUEST:
The change to Technical Specification 3.8.1.1 is being requested to provide more appropriate corrective actions for an inoperable battery or charger.
The change is also being requested to increase the-allowed outage time to allow surveillance testing of the batteries within the Action Statement time interval.
This increase l
in allowed outage time will significantly decrease the risk to the equipment at Units 1 and 2 whose battery is being tested, and to the safety of the personnel operating and maintaining that equipment.
This is true because this change will allow surveillance tests to be performed while Units 1 & 2 are shut down rather than operating as has been the case in the past.
Thus, DC systems, critically l
important' to these units, will not have to be removed from service while the units are on line.
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The change to Technical Specification 4.8.1.2 is being requested to l
clarify the surveillances and equipment required to be operable in j
Modes 5 and 6.
This clarification is consistent with the written l
NRC interpretation of this Specification.
No changes from the current Surveillance Requirements will result from this Technical Specification change.
EVALUATION OF REQUEST:
The plant lines to the Unit 3 start-up transformer and the Units 1&
2 start-up transformer respectively are the preferred and primary alternate off-site power sources for Crystal River Unit 3.
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Technical Specification
?.8.1.1 requires two physically independent circuits between the off-site transmission network and the on-site Class lE distribution system to be operable in Modes 1, 2,
3, and 4.
I With one of these off-site sources inoperable, shut-down is required after 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />; and with both of the off-site sources inoperable, I
y 3
shut-down is required efter 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.
Both Action Statements also reqlire augmented testing of the emergency diesel generators.
The protection schemes for these lines, the other plant lines, the 230 kv substation and the transmission lines connected to it are designed so that no single failure will result in the loss of both sources of off-site power to Unit 3 should a fault occur.
Separate battery / charger combinations provide tripping power to redundant tripping coils in the 230 kv breakers.
These design features assure the independence required by the Limitiag Condition for Operation (LCO).
The curren+
Specification requires both off-site power r.ources be declared noperable when either of the batteries or chargers supplying cripping power to the 230 kv breakers is inoperatle, because the physical independence required by the LCO is not maintained.
This is because with a battery inoperable, a single failure in the redundant relay scheme could result in a loss of both off-site power sources if a fault occurred.
The specification also requires that both emergency diesel generators be started within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The addition of action statements (f) and (g) to Specification 3.8.1.1 will provide a more appropriate action to be taken when one of these batteries or chargers is inoperable.
The current action is inappropriate and causes unnecessary diesel generator starts since the off-site power supplies remain available and the possibility of needing the diesel generators is not significantly increased even though the physical independence of the off-site power supplies has been compromised to some extent.
The allowed action statement time of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> is also inappropriate and could cause an unnecessary plant shutdown since the loss of one battery or charger does not represent a significant decrease in the level of safety if it is compensated for by the substitution of the other battery / charger combination.
The proposed action statements (f) and (g) recognize that the off-site power sources have not been impanted when a battery or charger is inoperable and requires the remaining battery / charger combination be substituted for the inoperable equipment within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The remaining battery is also required to be demonstrated operable within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
This is an appropriate action since the DC System for the switchyard is the system that has been degraded, not the off-site power supplies.
The increase in the allowed outage time to seven days will provide time to do required surveillances during power operation without significantly increasing the risk to the health and safety of the public.
This increase in risk has been calculated using a simplifiad probabilistic risk assessment (pRA) model.
With separate battery / charger combinations providing power to the redundant relaying and tripping systems the probability of not isolating a 230 kv fault (and thus causing a simultaneous loss of both off-site power sources) is estimated to be 4.62X10-6 per fault.
When one battery or charger is out of service, this probability is not significantly impacted if all components are fed from a common battery / charger combination.
Under these conditions the probability of not isolating a 230 kv fault is estimated to be 7.03X10-5 per fault.
In either case, the probability of having a loss of off-site power because of the inability to isolate a 230 kv fault is very low.
Even in the event this situation did occur, the loss of off-site power to Crystal River 3 would only be momentary providea-the fault was not maintained.
All incoming lines and operating units would trip, de-energizing the 236 kv substation.
Within 10 seconde automatic dead-line reclosers at the remote. substations will re-energize the lines and restore off-site power to the plant.
This op e ra t i ot, of the transmission ~ system was demonstrated during an event which occurred on February 28, 1984 (See LER 84-003).
The change in the Action Statement requirements for an inoperable battery or charger will provide a more appropriate action than does the current Specification.
The increase in the allowed outage time does increase the probability of a Joss of off-site power, however, as has been shown,.this increase is minute and the benefits of being able to more appropriately schedulc battery surveillance testing outweigh this increase in risk.
There is no possibility of an accident different than those evaluated in the Final Safety Analysis Report (FSAR) created by this change since loss of off-site power is an analyzed accident.
The consequences of the analyzed uccidents are unchanged, since all acciden, analyses assume a loss of off-site power at the beginning of the accident.
This change also requests the Surveillance Requirements for Specification 4.8.1.2 be explicitly stated, rather than included by reference to Specification 4.8.1.1.
This is necessary because of ambiguities caused by the references in Specification 4.8.1.1 to 1
both off-site power
- sources, both diesel generators, and both batterfes supplying tripping power to the 230 kv switchyard.
The proposed change does not change the Surveillance Requirements but
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acknowledges the fact that only one off-site and one o n - s t 'c e power source is required to be operable in Modes 5 and 6.
The change in the Surveillance Hequiremen' 4.8.1.2 will not result 4
in any change in risk and will provide more easily understandable requirements.
SHOLLY EVALUATION:
Florida Power Corporation (FPC) proposes this amendment does not involve a significant hazards consideration.
The revision to the allowed outage time for the substation batteries will provide more flexibility in scheduling of required battery testing without significantly increasing the probability of a
loss of off-site power.
1.
Operation of the facility in accordance with the proposed amendmont would not involve a
significant increase in the probability of occurrence of consequences of an accident previously evaluated.
While the probability of a loss of off-site power is increased slightly, the contribution to the total loss of off-site power probability is still small.
Tha consequences of a loss of off-site power are unchanged by this i
proposed amendment.
2.
Operation of the facility in accordance with'.the proposed amendment would not create the possibility of a new or different kind of accident from any' accident previously evaluated..The proposed amendment has no affect.on the possibility of creating a new or different-kind of accident from'any accident previously evaluated.
The proposed amendment changes the action-statement requirements to more appropriate actions for. an inoperable battery.
A change in' allowed outage time cannot create a new or different accident.from those previously evaluated.
3.
Operation of the facility in accordance with the proposed-
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amendment would not involve a significant reduction in. a margin of -safeiy.
The initial condition assumptions of the safety analyses is based upon maintaining at least one of each of the-on-site AC and DC-power sources and associated distribution systems operable during accident conditions coincident with an assumed loss of off-site power and a single failure of the other on-site AC source.
.Thus, no credit is taken in the safety analysis for any margin of safety provided by the off-site power sources.
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