ML20236R904

Application for Amend to License DPR-61,revising Tech Spec 3.12 Re Addition of Operability Requirements on Offsite & Onsite Power Sources W/Limiting Conditions for Operation & Time Requirements for Corrective Actions.Fee Paid

ML20236R904
Person / Time
Site:	Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png
Issue date:	11/17/1987
From:	Mroczka E, Romberg W CONNECTICUT YANKEE ATOMIC POWER CO.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
Shared Package
ML20236R907	List: B12727, Proposed Tech Spec 3.12 Adding Operability Requirements on Offsite & Onsite Power Sources W/Limiting Conditions for Operation & Time Requirements for Corrective Actions ML20236R904
References
B12727, NUDOCS 8711240098
Download: ML20236R904 (5)

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. CON N ECTICUT . YAN KEE ATO MIC POWER COMPANY l

B E R L I N, CONNECTICUT I

.. y P.o. Box 270

• HARTFORD, CONNECTICUT 06141-0270 TELEPHONE November 17,1987 ro>eas-sooo Docket No. 50-213 B12727 ,

. Re: 10CFR50.90 l

U. S. Nuclear Regulatory Commission

~Atto , Document Control Desk Washington, D. C. 20535 l

' Gentlemen:

l Haddam Neck Plant Proposed Revision to Technical Specifications j Degraded Grid Voltage Protection System i Pursuant ~ to 10CFR50.90, Connecticut Yankee Atomic Power Company (CYAPCO) hereby ' proposes - to amend its Operating License, DPR-61, by

.-incorporating the attached proposed changes into the Technical Specifications of the Haddam Neck Plant.

'The proposed changes' to Technical Specification 3.12 involve the addition of operability requirements on off-site and on-site power sources with limiting

- conditions for operation (LCO) and time requirements for corrective actions. In addition, Technical Specification 4.2 has been modified to include requirements ,

for testing and channel calibration of the undervoltage setpoints, j Background i By letter dated October 20, 1981,(1) CYAPCO proposed technical specification  ;

changes to reflect additional LCOs associated with the proposed degraded grid l voltage protection system. The NRC Staff provided its safety evaluation on  !

degraded letter dated grid protection

. July of (Class 9, 1982. 21 IE power systems at the Haddam Neck Plant by As requested in the safety evaluation report,

CYAP O submitted the operating procedures for NRC review on February 3, 1983.(

' (1) W. G. Counsil letter to D. M. Crutchfield, " Proposed Revisions to Technical Specifications," dated October 20,1981.  ;

(2) D. M. Crutchfield letter to W. G. Counsit, " Degraded Grid Protection for h- Class IE Power Systems," dated July 9,1982.

W. G; Counsil letter to D. M. Crutchfield, " Degraded Grid Protection for 0 (3). . Class IE Power Systems," dated February 3,1983.

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- B12727/Page 2

November.17, .1987  !

k By, letterTdated 3uly 2,1985,(4)'the NRC Staff concluded that the procedures

, were acceptable; however, they stated _that the technical specifications P

Jsubmitted .on October 20, 1981 were not consistent' with these procedures.

Therefore, the NRC requested that CYAPCO revise and resubmit the technical

! ' specifications . to reflect the ' numerical values presented in the approved

procedures.

Discussion LThe proposed changes involve revisions to portions of Sections 3.12 and 4.2 of the

- Haddam Neck Technical Specifications. The changes to Section 3.12 involve the l'

addition of operability requirements on off-site and on-site power sources with LCO and time . requirements for corrective actions. . The changes apply to Modes 1,2,3, and 4 and include:

o . Increasing from one to two the number of off-site circuits required to be operable, j o'  : Increasing from one to. two' the number of emergency diesel generators (EDGs) required to be operable, o Increasing from three to all four 480V buses required to be operable, o The addition of new requirements for the operability of the four 120V vital buses, .

o Increasing from'one to two the number of battery chargers required

-to be operable and addition of new requirements for the two 125V

< DC batteries and associated buses to be available,

o. The addition of LCO time limits given the loss of any 4160V,480V,

120V AC bus, DC power supply or EDGs, e

o Deletion of the EDG loading limit (2850 kW), and o The addition of a new requirement on undervoltage setpoints with LCO time limits for Modes 1 or 2.

. . . . i Section 4.2 is revised to add requirements for calibrating the level-one, level-two, and level-three undervoltage setpoints and performing channel functional tests. Please note that these setpoints are different than those previously submitted to the NRC in AOP 3.2-25, Revision 3. Since new transformers were installed during the present refueling outage, CYAPCO had to recalculate the I setpoints. These new setpoints will be incorporated in Revision 6 of AOP 3.2-25 prior to start-up.

i (4)' 3. A. Zwolinski letter to 3. F. Opeka, " Safety Evaluation for Degraded Grid Voltage Procedures," dated July 2,1985.

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. November 17,1987

.Significant Hazards Consideration In accordance with 10CFR50.92, CYAPCO' has reviewed the attached proposed changes .and .has concluded that they do not involve a significant hazards f

- consideration. The basis for this conclusion is that the three criteria of

.. .10CFR50.92(c)'are not compromised; a conclusion which is supported by our determinations ' discussed below. The proposed changes do not involve a

'significant hazards consideration because the changes do not:

1 1.. Involve a significant increase in the probability or consequences of an accident previously analyzed. The' impact of the change on design

' basis accidents (DBAs) which assume loss of off-site power has been

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reviewed and has been determined to be unaffected by the change.

The proposed changes in general provide for more conservatism in

'that the operability requirements for the on-site 4160V emergency buses, 480V buses,120V vital buses, and the 125V DC systems are more' restrictive than the existing-requirements. These changes do not : impact the failure probability of the associated electrical systems, rather L they. increase the probability that a train of emergency electrical; power is available following an accident. The probability. of occurrence or the consequences of the DBAs are 7 unchanged.-

In addition, the deletion of the loading limit on the EDGs does not affect the probability or consequences of an EDG failure. The

-loading limit was required when there was no circuit for load shedding prior to automatic sequencing of emergency safeguards loads onto each diesel generator. These circuits have since been installed and calculations have-shown these loads do not overload the EDGs. The potential for overloading the EDGs by the operator is. addressed by having caution statements in the Emergency Response Procedures.~. in addition, removing this requirement from

'.the Haddam Neck Technical Specifications is consistent with the NRC approved Westinghouse Standard Technical Specifications.

The proposed changes to Section 4.2 improve system availability by providing for ' periodic testing since no periodic testing was previously required. .These changes do not increase the failure '

probability of the undervoltage logic.

2.- Create the possibility of a new or different kind of accident from  ;

any previously evaluated. There are no new failure modes associated  !

with Technical Specification 3.12 since these changes involve more l restrictive requirements on the operability of the electrical power systems and do not involve design changes. No new accident is created because the same equipment is assumed to perform in the same' manner as before. The deletion of the EDG loading limit does not provide any new failure modes since this limit was required when there was no circuit for load shedding prior to automatic sequencing of loads onto each diesr! generator. These circuits have 2-___.

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U. S. Nuclear Regulatory Commission L B12727/Page 4 '

. November 17,1987

.since been installed and calculations have shown these loads do not

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overload the EDGs. The potential for overloading the EDGs by the operator is ' addressed by caution statements in the Emergency Response Procedures. Thus, the deletion of the loading limit from

.Section 3.12 does not impact the failure probability of the EDGs nor does it increase the probability of an accident.

v Changes to Technical Specification 4.2 provide for periodic testing and calibration of the undervoltage setpoints. - The changes improve

' system availability by providing periodic testing since no periodic testing is specified in current technical specifications. The failure mode associated with' this change is mis-calibration; however, this l failure mode.is not new because the undervoltage setpoints are I presently tested and ' calibrated. Thus, because the potential for  ;

mis-calibration. already _ exists, no new failure modes are created. j No'new potential accident is created because the proposed changes l

and associated failure modes -do not modify plant response.

Therefore, the proposed technical specification changes do not create the probability of an accident or malfunction of a different type than any evaluated previously in the safety analysis report.

3. Involve a significant reduction in a margin of safety. The protective boundaries are'not impacted because the consequences of the DBA are not affected.- Since the protective boundaries are not affected, the- safety limits are also - not affected. The proposed change

, ' maintains the basis'. of the technical specifications in assuring r electrical power operability.

1Moreover, the Commission has provided guidance concerning the applications of standards set forth in.10CFR50.92 by providing certain examples (March 6,1986, S . F,Rf 7751) of ' amendments that are considered not likely to involve a significant hazards consideration. The changes proposed herein are most closely enveloped by example (ii) which constitutes an additional limitation or control not presently included in Jhe technical specifications. Since the proposed changes provide for more restrictive operability requirements. and provide new requirements for testin.g and calibrating the undervoltage setpoints, the proposed changes result in added assurance that the electrical power system will be available. Therefore,

' the proposed changes would not involve a significant hazards consideration.

The.Haddam Neck Plant Nuclear Review Board has reviewed and approved the ,

. attached proposed revision and concurs with the above determinations. (

l In' ;accordance with 10CFR50.91(b), CYAPCO will provide the State of  ;

Connecticut with a copy of this proposed amendment. {

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U. S. Nuclear Regulatory Commission B12727/Page 5 November 17,1987 Pursuant to the requirements of 10CFR170.12(c), enclosed with this amendment

- request is the application fee of $i50.00.

Very truly yours, CONNECTICUT YANKEE ATOMIC POWER COMPANY Y H l'o r 2 Y A.

E. J. Mroczka ,

Senior Vice President hhf By: W. D. Romberg Vice President cc: Mr. Kevin McCarthy Director, Radiation Control Unit Department of Environmental Protection Hartford, Connecticut 06116 W. T. Russell, Region I Administrator A. Wang, NRC Project Manager, Haddam Neck Plant

3. T. Shed!osky, Resident inspector,~ Haddam Neck Plant

. STATE OF CONNECTICUT - )

) ss. Berlin

- COUNTY OF HARTFORD )

l Then personally appeared before me W. D. Romberg, who being duly sworn, did state that he is Vice President of Connecticut Yankee Atomic Power Company, a Licensee . herein, that he is authorized to execute and file the foregoing information in the name and on behalf of the Licensee herein and that the statements contained in said information are true and correct to the best of his knowledge and belief.

AAvA f&h flotary Fplic My Commission Expires March 31, 1988 s

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