U-603043, Application for Amend to License NPF-62,revising Acceptance Criteria of SRs 3.8.1.7,3.8.1.12,3.8.1.15 & 3.8.1.20
| ML20236W986 | |
| Person / Time | |
|---|---|
| Site: | Clinton  |
| Issue date: | 07/31/1998 |
| From: | Walter MacFarland ILLINOIS POWER CO. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML20236W988 | List: |
| References | |
| RTR-NUREG-1434 LS-98-005, LS-98-5, U-603043, NUDOCS 9808070038 | |
| Download: ML20236W986 (8) | |
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~ Chnton Power Station P.O Box 678 Chnton. IL 61727
.e Tel 217 935-5623 Fax 217 935-4632 Walter G. MacFarland IV Senior Vice President e and chief Nuclear Officer POWER Z;6fs,4' An Illinova Company July 31,1998 Docket No. 50-461 10CFR50.90 Document Control Desk Nuclear Regulatory Commission- .
Washington, D.C. 20555
Subject:
Clinton Power Station Proposed Amendment of Facility Operating License No. NPF-62 (LS-98-005)
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Dear Madam or Sir:
Pursuant to 10CFR50.90, Illinois Power (IP) hereby applies for amendment of Facility Operating License No. NPF-62, Appendix A - Technical Specifications (TS) for
- Clinton Power Station (CPS). This request consists of proposed changes to revise the acceptance criteria of Surveillance Requirement (SR) 3.8.1.7, SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20. Currently, these SRs require that each Diesel Generator (DG), upon a receipt of a start signal, achieve a voltage: 2 3870 V and s 4580 V and a frequency 2 58.8 Hz and s 61.2 Hz within 12 seconds. These SRs are being revised to require each DG to (a) achieve a voltage 2 3870 V and a frequency 2 58.8 Hz within 12 seconds and {
(b) subsequently achieve a steady state voltage 2 3870 V and s 4580 V and frequency 2 J 58.8 Hz and s 61.2 Hz. These changes proposed for the CPS TS are consistent with generic changes recently approved by the NRC for incorporation into the Standard Technical Specifications, including NUREG-1434, " Standard Technical Specifications -
General Electric Plants, BWR-6."
A description of the proposed changes and associated justification (including a Basis for No Significant Hazards Consideration) are provided in Attachment 2. A L, marked-up copy of the affected pages from the current TS is provided in Attachment 3.
L A marked-up copy of the affected pages from the current TS Bases is provided in Attachment 4. Further, an affidavit supporting the facts set forth in this letter and its go' i-attachments is provided in Attachment 1. Following NRC approval of this request, IP l' will revise the CPS TS Bases, in accordance with the TS Bases Control Program of TS 5.5.11, "TS Bases Control Program," to incorporate the changes identified in Attachment 4.
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' 9808070038 900731 I
PDR ADOCK 05000461-,
P PDR.
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U-603043 Page 2
( IP has reviewed the proposed changes against the criteria of 10CFR51.22 for categorical exclusion from environmentalimpact considerations. The proposed changes do not involve a significant hazards consideration, or significantly increase the amounts or change the types of effluents that may be released offsite, nor do they significantly increase l individual or cumulative occupational radiation exposures. Based on the foregoing, IP concludes that the proposed changes meet the criteria given in 10CFR51.2(c)(9) for a categorical exclusion from the requirement for an Environmental Impact Statement.
l Please note that the changes to the TS proposed herein resolve an issue identified during the current outage at CPS concerning compliance with, and the intent of, the TS requirements as currently worded in the applicable SRs. To ensure that this issue is fully l resolved prior to plant startup, which is scheduled to occur during the fourth quarter of this year, IP respectfully requests receipt of the license amendment reflecting the proposed changes (if approved) by October 15,1998.
Sincerely yours, NG'1" Q Walter G. MacFarland, IV Senior Vice President and ChiefNuclear Officer TBE/mlh Attachments cc: NRC Clinton Licensing Project Manager NRC Resident Office, V-690 Regional Administrator, Region III, USNRC Illinois Department of Nuclear Safety
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Attachment 1 to U-603043 Page1of1 Wayne D. Romberg, being first duly sworn, deposes and says: That he is Manager-Nuclear Station Engineering Department; that this application for amendment of Facility Operating License NPF-62 has been prepared under his supervision and direction; that he knows the contents thereof; and that to the best of his knowledge and belief said letter and ,
the facts contained therein are tme and correct.
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i Date: This N day of July 1998.
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Wayne D. Romberg STATE OF ILLINOIS ( SS.
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l Attachment 2 to U-603043 LS-98-005 Page1of5
Background
Within the Technical Specification require nents for testing of the emergency standby .
diesel generators, Surveillance Requirement (SR) 3.8.1.7 requires that each diesel generator (DG) starts from standby conditions and achieves required voltage and frequency within the required time. Specifically, SR 3.8.1.7 of the Clinton Power Station (CPS) Technical Specifications (TS) states, " Verify each DG starts from standby condition and achieves, in s 12 seconds, voltage 2 3870 V and s 4580 V and frequency 2 58.8 Hz and s 61,2 Hz." SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20 contain similar requirements.'
As they are currently worded and structured, these SRs imply that steady state conditions must be established within 12 seconds, since minimum and maximum limits for voltage and frequency are specified. This is not the intent of the 12-second start tests. The intent of the 12-second start tests is to confirm the capability of each DG to start and achieve the minimum conditions required to accept load. Thus, requirements for steady state I operation are appropriate subsequent to the 12-second start. I The industry and the NRC have reviewed and resolved this issue on a generic basis. A j Technical Specification Task Force (TSTF) Traveler (TSTF-163, Revision 2) was !
submitted to the Nuclear Regulatory Commission which proposed to modify SR 3.8.1.7, {
SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20 by (1) eliminating the maximum voltage and frequency limits from the 12-second start test, (2) rewording the SRs to clarify that each DG is required to achieve steady state operation following the 12-second start, and (3) ,
adding a requirement to the Bases for SR 3.8.1.7 to ensure that the time to achieve steady l state operation is periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance. The proposed changes were to be applied to I each of the Standard Technical Specifications (NUREG-1430, NUREG-1431, NUREG- i 1432, NUREG-1433, and NUREG-1434). TSTF-163, Revision 2 was approved by the NRC on April 21,1998. 1 l
t Description of Proposed Changes In accordance with 10CFR50.90, IP proposes to change TS 3.8.1 by revising the i acceptance criteria of SR 3.8.1.7, SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20 consistent with the changes proposed generically by TSTF-163, Revision 2. Currently, these Surveillance Requirements verify that each DG achieves a voltage 2 3870 V and s 4580 V and frequency 2 58.8 Hz and s 61.2 Hz within 12 seconds. SR 3.8.1.7, SR 3.8.1.12, SR i
8 A " fast start" (i.e., a 12-second start) may also be performed pursuant to SR 3.8.1.2. This SR is pe formed much more frequently than SR 3.8.1.7 (or the other noted SRs) and does not normally require a fast start. Specifically, Note 3 of SR 3.8.1.2 pennits a " modified start" invohing gradual acceleration of the DG to synchronous speed to be used for performance of the SR in order to reduce stress and wear on the d6el machines. Thus, testing per SR 3.8.1.2 is normally performed using such modified starts.
However, when such modified starts are not used, Note 3 requires the time, voltage, and frequency tolerances of SR 3.8.1.7 to be met.
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Attachment 2 to U-603043 LS-98 005 Page 2 of 5 3d1.15, and SR 3.8.1.20 are being revised to require that each DG (a) achieve a voltage 2 3870 V and a frequency 2 58.8 Hz within 12 seconds and (b) subsequently achieve a steady state voltage 2 3870 V and s 4580 V and frequency 2 58.8 Hz and s 61.2 Hz.
Additionally, consistent with TSTF-163 (Rev. 2), a commitment is being added to the Bases of SR 3.8.1.7 to require that the time for each DG to reach steady state operation be periodically monitored and the trend evaluated to identify degradation of governor and voltage regulator performance.2 The proposed TS changes are reflected on a marked-up copy of the affected pages from the CPS TS contained in Attachment 3. The associated Bases changes are reflected on a ,
marked-up copy of the affected pages from the TS Bases, as provided in Attachment 4.
The Base, changes are not a formal part of the Technical Specification change request, and are therefore provided for information only. Changes to the Bases are processed per J the Technical Specification Bases Control Program, as described in Technical Specification 5.5.11 Justification for Proposed Channes SR 3.8.1.7, SR 3.8.1.12, SR 3.8.1.15, and SR 3.8.1.20 are being revised to require each DG to (a) achieve a voltage 2 3870 V and frequency 2 58.8 Hz within 12 seconds and (b) subsequently achieve a steady state voltage 2 3870 V and s 4580 V end frequency 2 58.8 Hz and s 61.2 Hz. With regard to each diesel generator's capability to achieve a fast start and be ready to accept load, verifying that each DG achieves the minimum voltage and frequency within 12-seconds is sufficient to verify such capability, including satisfying the conditions needed for the DG output breaker to close. Further, when called upon, each DG must start and tie to the applicable bus within the assumed time. Verification that permanently connected loads are energized in less than or equal to 12 seconds is performed pursuant to SR 3.8.1.11 and SR 3.8.1.19.
, When a test is performed that does not result in tying the DG to the bus, a momentary
, voltage or frequency overshoot (and/or subsequent undershoot) can occur because no loads are being tied to the DG. (Loading tends to minimize the overshoot.) This overshoot (or undershoot) could be such that the voltage or frequency is momentarily outside the specified limit (s) at the 12-second time limit. This condition, which is not uncommon due to the nature of the DG governor as it seeks to control DG speed during l the fast start when the DG is unloaded, does not affect the permissive for closure of the DG output breaker since the permissive is primarily dependent on minimum conditions being achieved regardless of any overshoot or subsequent momentary undershoot. Thus, i
2 This commitment is not applicable to the modified start method that may be employed per SR 3.8.1.2.
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Attachment 2 to U-603043
( LS-98-005 Page 3 of 5
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, 1 this condition is not indicative of an inoperable DG, provided that steady state voltage and I frequency are subsequently achieved.
It should be noted that the steady state voltage and frequency limits themselves are not being changed. Additionally, as noted previously, the time for each DG to reach steady q state operation will be periodically monitored and the trend evaluated to identify
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degradation ofgovernor and voltage regulator performance.
Therefore, based on the above, eliminating the requirement for each DG to achieve a I voltage and frequency within both minimum and maximum limits within 12 seconds has no impact on safety. q I i l
Basis for No Significant Hazards Consideration J According to 10CFR50.92, a proposed change to the operating license involves no significant hazards consideration if operation of the facility in accordance with the proposed change would not: (1) involve a significant increase in the probability or consequences of any accident previously evaluated, (2) create the possibility of a new or different kind of accident from any accident previously evaluated, or (3) involve a j l significant reduction in a margin of safety. The request is evaluated against each of these criteria below:
(1) Analyzed events are initiated by the failure of certain plant structures, systems or l components. The proposed changes to the Clinton Power Station (CPS) Technical Specifications revise the acceptance criteria for Surveillance Requirements (SRs) pertaining to the diesel generators (DGs). The DGs are not considered as initiators of any analyzed event. Thus, these changes do not increase the probability of any accident previously evaluated.
The consequences of analyzed events involving the diesel generators are dependent on the successful functioning of the diesel generator (s) to mitigate such events when a concurrent loss of offsite power is postulated. The proposed change in the acceptance criteria for testing of the DGs per the affected SRs accounts for DG governor performance in response to a fast start. Notwithstanding, the revised l
SRs will continue to ensure that minimum frequency and voltage are attained within the required time, thus satisfying permissive conditions required for closure of the DG output breaker The SRs will also continue to ensure that proper steady-state voltage and frequency are attained consistent with proper DG governor and voltage regulator performance. Additionally, verification that permanently connected loads are energized within the required time (in response to a loss of offsite power or in response to a loss of coolant accident (LOCA) concurrent with a loss of offsite power) will continue to be performed pursuant to l
Attachment 2 to U-603043 LS-98 005 Page 4 of 5 SRs not affected by the proposed changes. Thus, there is no impact on the capability of the DGs to perform their required safety function.
Based on the above, IP has concluded that the proposed changes will not result in a significant increase in the probability or consequences of any accident previously evaluated.
(2) The proposed changes do not involve a physical alteration of the plant. No new or different equipment is being installed, and no installed equipment is being operated in a new or different manner. There is no alteration to the parameters within which the plant is normally operated or in the set points that initiate protective or mitigative actions.. As a result, no new failure modes are being introduced.
Additionally, there are no changes in the methods governing normal plant operation, nor are the methods utilized to respond to plant transients altered.
Based on the above, IP has concluded that the proposed changes will not create the possibility of a new or different kind of accident not previously evaluated.
(3) As noted previously, the proposed changes to the acceptance criteria for testing of the DGs per the affected SRs accounts for the characteristics of the DG governor during a fast start, but they do not impact the effectiveness of such testing to provide assurance of DG operability. Thus, the proposed changes do not impact expected DG performance, including the capability for each DG to attain and maintain required voltage and frequency for accepting and supporting plant safety loads within the required time, as assumed in the plant safety analyses. ,
Margins of safety are established through the design of the plant structures, systems and components, the parameters within which the plant is operated, and the establishment of set points for the actuation of equipment relied upon to respond to an event. With respect to any margins of safety associated with the diesel generators, and as noted previously, the proposed changes do not impact
- - diesel generator performance. That is, the SRs as revised will continue to ensure that proper voltage and frequency are attained for closure of the DG output breaker, and for steady-state conditions consistent with proper DG governor and L voltage regulator performance. In addition, the proposed changes involve no changes to any setpoints or settings associated with the diesel generators. On this basis, the proposed changes do not involve any changes to any assumptions of the plant safety analyses with regard to the function of the diesel generators. Thus, no margins of safety are impacted by the proposed changes.
Based on the above, IP has concluded that the proposed change will not result in a reduction in a margin of safety.
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Attachment 2
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to U-603043 LS-98-005 Page 5 of 5 Based on all of the above, IP concludes that the proposed changes do not involve significant hazards consideration.
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