ML20206C476

Application for Amend to License NPF-68,revising Tech Spec 3.8.1.1 Re Action Requirement for Inoperable Diesel Generator to Reduce Possibility of Abusive Testing of Remaining Operable Diesel Generator.Fee Paid

ML20206C476
Person / Time
Site:	Vogtle
Issue date:	11/07/1988
From:	Hairston W GEORGIA POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20206C479	List: ML20206C476 ML20206C519
References
VL-110, NUDOCS 8811160295
Download: ML20206C476 (7)

Text

o ca,; sr w ac o ,

3n r ..p e A.en*

A; : L ( ,, < ; :: : 4

% c; P.'v a j 2 4 * [ " t ' ,6 vo nw ft31i"(e D aJ"A6 AP M $Nd)n' 4 S.

w a s.e m . , .,

~ ~ , ,, .

If :', f t' a. g 4 'g* *'

YL-110 ,

0079e  :

X7GJ17-V600 November 7,1988 '

U. S. Nuclear Regulatory Commission ATTN: Document Control Desk Washington, D. C. 20555 PLANT YOGTLE - UNIT 1 '

NRC DOCKET 50-424 OPERATING LICENSE NPF-68 -

REQLEST TO REVISE TECHNICN. SPEt.!FICATION 3.8.1.1  !

Gentlemen:

In accordance with 10 CFR 50.90 as required by 10 CFR 50.59(c)(1), Georgia Power Company (GPC) hereby proposes to amend the Vogtle Electric Generating  ;

Plant Unit 1 Technical Specifications Appendix A to Operating License CPF-68.

The proposed amendment revises the action requirement for an inoperable diesel generator to reduce the possibility of abusive testing of the remaining operable diesel generator.

l Enclosure 1 provides a detailed description of the proposed change and the basis for the change request.

Enclosure 2 details the basis for our determination that the proposed change does not involve significant hazards considerations. l Enclosure 3 provides page change instructions for incorporating the proposed .hange. The proposed revised Technical Specification pages follow i inclosure 3. I 1

l l In accordance with 10 CFR 170.12, a check for $150.00 is enc' d in l i payment of the required application fee, r l

A copy of this letter and all appitcable enclosures will be sent to the l designated state official in accordance with 10 CFR 50.91. I l i The Vogtle Plant Review Board and the GPC Safety Review Board have j reviewed and concur with this proposed amendment. n n \ t hh 6911160295 881107 t h, k$

FDR AD4XK 05000424 P PDC L .if gl

i

. .* L

'( eorgia Power

", S. Nu:lcar Regulatory Commission -

c November 7,1988 Page Two {

r 4

Mr. W. G. Hairston, !!! states that he is a Senior Vice President of Gecrgia Power Company and is authorize / to execute this oath on behalf of .

Georgia Power Company. and that to the best of his knowledge and belief, the  !

facts set forth in this letter and enclosures are true. L GEORGIA POWER COMPANY l

I By: h. . b ~ W W. G. Mafrston, III i

Sworn to and subscribed Micre me this 7th day of November 1988.

k.. a LA gnotary PublicM my commiss% t,$ge s %-M- % .

JH/11h l 0 i

Enclosures:

l. Basis for Proposed Change  !

1

2. 10 CFR 50.92 Evaluation l l 3. Instructions for Incorporation 1 4

j 4 Check for Application Fee

c

Georgia Power Company ,

Mr. P. D. Rfce '

Mr. G. Bocknold, Jr.  !

GO-NORMS  !

U. S. Nuclear Regulatory Commission i Region ,i cioseinistratsr l Mr. J 8. Hopkins, Licensing Project Manager, NRR (2 co [

! Mr. J. F. Regge Senior Resident Inspector-Operations, pies)

Yogtle I e

q State of Georgia i Mr. J. L. Le@etter, Commissioner - Depart'Aent of Natural Resources  :

I i

f i

i i r

Georgia Ponel ENCLOSURE 1 PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NPF-6P REQUEST TO REVISE TECHN! CAL SPECIFICATION 3.8.1.1 BAS!$ FOR PROPOSED CHANGE PROPOSED CHANGE Specification 3.8.1.1 requires that, with one diesel generator inoperable for any cause other than preplanned preventative maintenance or testing, the other diesel generator must be demonstrated operable by perfoming Surveillance Requi rements 4. 8.1.1. 2. a . 4 and 4.8.1.1.2.a.5, subject to Footnotes

• and f. The footnotes read as follows:

This test is required to be completed regardless of when the inoperable diesel generator is restored to OPERABILITY.

f The diesel shall not be rendered inope'able by activities perfomed to support i;esting pursuant to the At tion States,ent (e.g., an air roll).

The proposed change revises Footnote f as f allows:

1. 7he diesel shall not be rendered inoperable by activities perfomed {

to support testing pursuant to the Action Statement (e.g., an air roll), unless the inoperable diesel is returned to OPEPABLE status prior to the testing.

BAS!$

During tl.e perfomance of an air roll, a diesel generator is unavailable f or an automatic start. Footnote f ensures that, if one diesel generator is inoperable, the second diesel generator will not be rendered simultaneously inoperable by testing activities. If, however, the first diesel generator is demonstrated operable prior to the testing of the second diesel generator, it would not be necessary to apply Footnote f. In these circumstances, perfoming an air roll of the second diesel would not result in two diesels being inoperable. GPC is therefore proposing to add an exception to Footnote f which would allow an air roll test to be perfomed on the second diesel if the first diesel has been demonstrated operable.

0079e El-1 11/07/88 YL-110

Ges..jla l'on er ENCLOSURE 2 FLANT V0GTLE - UNIT 1 hRC 00CKET 50-424 ,

OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.8.1.1 10 CFR 50,92 EVALUATION BACKGROUND The Transamerica Delaval , Inc. (TDI) Owners Group developed and implemented a program plan to resolve operational and regulatory issues >

relative to TDI diesel generators. The F'tC staff's evaluation of the Owners Group's findings and recommendations was provided in NUREG-1216 "Safety i Evaluation Report Related to the Operability and Reliability of Emergency Diesel Generators Manufactured by Transamerica Delaval, Inc." The staff's i position on air roll testing was stated in Section 2.1.3.13 of NUREG-1216 as r follows: l

... cylinder heads are one of the components that PNL has concluded I warrant special emphasis in the area of maintenance and surveillance. The l key item in this area is PNL's reconmendation in Section 4.10.4.3 of -

PNL-5600 for periodic Cr-roiling of the engine with the cylinder cocks  ;

open to check for the pretence of water in the cylinders. Except as noted '

for Group !!! heads below, this ites will be incorporated as a Itcense j condition for all TDI engines (see Appendix 8 to this SER)."

The staff also stated that: I

"... the PNL reconnended air-roll tests should be performed except when the plant is already in the Action stattment of Technical Specification i 3/4.8.1. In oth6r words, it is not the staff's intent that an engine should intentionally be put into a co9dition where it cannot receive e ,

start signal if the other diesel engine (s) or other ac sources are already  :

inoperable."

License Condition 2.C(6) of the Yogtle Unit 1 Operating License sets forth '

requirments for air roll testing in accordance with the staff's position. ,

1 Specification 3.8.1.1 prohibits the perfomance of an air roll test if a diesel is being tested due to the inoperability of the other diesel, even if (

the inoperable diesel is restored to operable status prior to tha testing. ,

The proposed change allows an air roll tast to be perfomed if the inoperable dieul is restored to operable status prior to the testing. This, ensures that  !

both diesels will not be rendered simultaneously inoperable, consistent with the staff's position in NUREG-1216.

i 0079e E2-1 11/07/88 l YL-110 i i

-.l-

( cor la Powel ENCLOSURE 2 (CONT'D)

PLANT V0GTLE - UNIT 1 NRC DOCKET 50-424 OPERATING L!rENSE NPF-63 REQUEST TO REVISE TECHNICAL SPICIFICATION 3.8.1.1 10 CFR 50.92 EVALUATION ANALYSIS GPC has reviewed the proposed change with respect to the requirements of 10 CFR 50.92 and has determined that the change does not involve significant hazards considerations. In support of this conclusion, the following analysis is provided:

1. The proposed chtnge will not significantly increase the probability or con'equences of an accident previously evaluated. The change allow; the perforwance of an air roll test if a diesel generator is beilg tested due to the inoperability of the other diesel generator, prov. *)d the inoperable Jtesel is restored to operable status prior to the testing. The change ensures that one diesel generator will be available for an automatic start signal, consistent with the NRC staff's guidanct in WUREG-1216. The change involves no physical alteration of the Diant or changes to setpoints or operating parameters. The probabi'iity or consequences of previously evaluated accidents are therefore not significantly increased by the proposed change.

l

2. Tre proposed change does not create the possibility of a new or l different kind of accident than any accident previously evaluated.

The change does not introduce any new equipwnt into the plant or require any existing equipment to operate in a dif ferent manner frors which it was designed to operate. Thus, the change does no; introduce a new failure pode and a new or different kind of .ccident is not made psssible.

3. The proposed change does not significantly reduce a margin of safety. The change has no effect on safety limits or limiting safety systeci settings. The change is expected to have a positive ef f=-t on diesel generator reliability. Perfomance of an air roll prior k testing facilitates the early detection of cylinder head flaws indicated by moisture in the cylinders. An air roll reduces the possibility of engine da: sage during testing. Margins of safety will therefore not be significantly reduced, g E2-2 11/07/88

n _ _ _

0 t

(leorgia l\mer i

ENCLOSlfRE 2 (CONT'0)

PLANT YOGTLE - UNIT 1 NRC DOCKET 50-424 OPERATING LICENSE NP/-68 REQLEST TO REVISE TECHNICAL SPECIFICATION 3.8,1.1 10 CFR 50.92 EVALUAT!0W CONCLUSION Based on the preceding analysis, GPC had detemined that the proposed change to the Technical Specifications will not significantly increase the i probability or 'onsequences of an accident previc1 sly evaluated, create the possibilits of a new or dif ferent kind of accident from a,1y accident previously evaluated, or involve a significant reduction in a margin of safety. GPC therefore concludes that the proposed change meets the requirements of 10 CFR 50.92(c) and does not involve significant Lazards considerations.

i 4

i f

l f

i 0079e E2-3 11/07/88 '

1 YL-110

1. p b Georgia Powerkn .

4 ENCLOSURE 3 t

PLANT YOGTLE - UNIT 1 WRC DOCKET 50-424 OPERATING LICENSE NPF-68 REQUEST TO REVISE TECHNICAL SPECIFICATION 3.8.1.1

- INSTRUCTIONS F0P. INCORPORATION-  :

}

The proposed amendment to the Technical Specifications ( Appendix A to 1 Operating License NPF-68) would be incorporated as follows. ,

, Remove Page Insert Page i

3/48-1 3/4 8-1 3/4 8-2 3/4 8-2 I

t c

j 5

b i.

.l-

! i e

a i

0079e E3-1 11/07/88 l VL-110 .

e

, , - - . , - , , --,--m,--.---._--.-,n-----.., ----,,---,-~-w ,----,r . - - - + - - ~ , , - -