ML20077L531

Suppl to 830201 & 0503 Requests for Amend to Licenses NPF-2 & NPF-8 Re Dc Distribution Sys.Nshc Involved.Portion of 830503 Request Re 24-month Surveillance Interval Withdrawn Since Issue Addressed in Generic Ltr 83-27

ML20077L531
Person / Time
Site:	Farley
Issue date:	07/29/1983
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
References
GL-83-27, NUDOCS 8308090463
Download: ML20077L531 (5)

Text

I Malling Address

.' AlaDams Power Company 600 North 18th Street Post Office Box 2641 Birmingham. Alabama 35291 Telephone 205 783-6081 F. L. Clayton, Jr.

Senior Vice President Flintridge Building AlabamaPower the southern elecirc system July 29, 1983 Docket Nos. 50-348 50-364 Director of Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 D.C. Distribution System Technical Specification 3/4.8.2 Gentlemen:

Alabama Power Company submitted proposed technical specification changes in letters dated February 1,1983 and May 3,1983 involving the D.C. distribution systems. The proposed changes updated the Auxiliary and Service Water Building D.C. Distribution System Technical Specifications to conform with the format of the most recent Westinghouse Standard Technical Specifications, current industry practice and Farley Nuclear Plant specific design parameters. During subsequent discussions with the NRC Staff, additional information was requested regarding the portion of the proposed changes involving discharge testing of the Service Water Building Batteries. -The requested information is contained herein.

The Service Water P@ ding Batteries are currently required to be subjected to performann 4 scharge tests every 18 and 60 months while the plant is shutdoy:e. r. citionally, the Technical Specification Action statement requiro 6.t . mh one train of the D.C. distribution system inoperable, the ; Dit v .1 te shutdown after 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. Since the Service I~ . Water Building Baltery bydem is shared between Units 1 and 2, the discharge test requirement necessitates a shutdown of both units. The proposed change includes a footnote to the ACTION statement to allow one D.C. distribution train to be inoperable during the battery discharge tests and to delete the requirement that the test be performed during shutdown.

During the discharge testing, one D.C. of stribution train must be declared inoperable based on the technical specification definition of OPERABLE, 'i.e., the bus, battery bank and charger must meet the

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July 29, 1983 U. S.> Nuclear Regulatory Commission Page 2 surveillance requirements in order to be OPERABLE. The discharge

-' testing involves disconnecting the Service Water Building Batteries from the D.C. distribution system, and following testing, recharging the -

- battery voltage to the surveillance requirement values. Although one train of the D.C. distribution system would be declared inoperable-during the discharge testing, the train would be functional throughout the test since the battery charger would supply the D.C. loads while the batteries were disconnected.- The battery charger would be supplied by off-site power during normal plant operation.

In case of a loss of off-site power event concurrent with the period of time that the batteries are disconnected for discharge testing, one train of the Service Water Building D.C. Distribution System would be operable with a battery, battery charger, and diese1~

generator back-up power. source while the other train is not operable.

The maximum period of time that such a condition would exist is 20 hours2.314815e-4 days <br />0.00556 hours <br />3.306878e-5 weeks <br />7.61e-6 months <br /> for each 18-month surveillance test and 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> for each 60-month surveillance test. The probability of a loss of off-site power event occurring during a 20-hour period that exists only once every 18 months or 30-hour period that exists only once every 60 months is extremely remote. The-existing technical specification allows a period of up to 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> inoperable and 6 additional hours to shutdown) for one train of the D.C. Distribution System to be inoperable (each occurrence). The proposed change is consistent with the philsophy of the existing technical specifications and would not significantly-increase the probability of one train being inoperable concurrent with a loss of off-site power event but would delete the current requirement to

. simultaneously shutdown _both units for the sole purpose of surveillance testing. This proposed change would not impact the continued safe operation of the Farley Nuclear Plant.

L At the conclusion of the discharge test, the batteries would be i

! reconnected to the D.C. distribution system and recharging would begin.

' A maximum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> would be required to restore the battery voltage

to the minimum technical specification value; however, during the recharging portion of the test, the battery would be capable

' Lof automatically supplying D.C. power _to both trains of essential loads j- during an accident situation.

-The proposed change to allow Service Water Building Battery '

-discharge testing without- requiring both units to shutdown does not F

- affect the continued safe operation of the Farley_ Nuclear Plant. The l

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Service Water Building D.C. Distribution System would be functional and

!> capable of supplying at least one train of essential loads during the period of. time discharge testing was being performed and the batteries

. were being' recharged.

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Mr. S. A. Varga July 29, 1983 U. S. Nuclear Regulatory Commission Page 3 The May 3,1983 submittal did not include a significant hazards consideration since the NRC requirements for such a review was not in effect at that time. Subsequently, Alabama Power Company has evaluated the proposed changes and determined that a significant hazards consideration is not involved in accordance with 10 CFR 50.92. This determination is consistent with example (vi) of the " Examples of Amendments that are Considered Not Likely to Involve Significant Hazards Considerations" listed on page 14870 of the April 6,1983 issue of the Federal Register. The

-proposed changes conform to the NRC approved Standard Review Plan and Westinghouse Standard Technical Specifications (NUREG-0452, Revision 4) which utilizes IEEE Standard 450-1980 as the basis for battery surveillance except for the following six minor plant-specific design differences.

1. The full charge specific gravity limits were adjusted to reflect the Farley Nuclear Plant specific battery design.

2. The voltage limits reflect the original Farley Nuclear Plant licensing basis.

3. A 24-hour period is allowed to correct temperature or connection resistance deviations without declaring the battery inoperable in accordance with IEEE Standard 450-1980.

4. Specific connection 4sistance values are defined for the connection resistance checks to reflect Farley Nuclear Plant specific design.

5. All battery charger test amperages and times are provided for completeness as the Standard Technical Specications did not define these values.

6. Depressurization of the Reactor Coolant System through a vent is not applicable to the Farley Nuclear Plant design.

The May 3,1983 submittal provides the detailed justification for the above six exemptions to the Standard Technical Specifications.

These justifications show that the results of the proposed changes are within acceptable criteria with respect to the Standard Technical Specifications and/or IEEE 450-1980 and thus do not constitute a significant hazards consideration.

In accordance with Generic Letter 83-27 dated July 6,1983, Alabama Power Company withdraws the portion of the May 3,1983 proposed change involving increasing the 18-month surveillance intervals to 24 months.

This issue has been addressed in the Generic Letter and the conclusion was that extending the 18-month surveillance intervals based on an 18-month fuel cycle is not acceptable to the NRC.

Mr. S. A. Varga July 29, 1983 U. S. Nuclear Regulatory Commission Page 4 This letter is a supplement to the Alabama Power Company letter dated May 3, 1983. The class of this proposed change was designated as Class III for Unit 1 and Class I for Unit 2 in accordance with 10 CFR 170.22 requirements. A check for $4,400.00 to cover the total amount of fees required was enclosed with the May 3,1983 letter. As noted by the distribution, a copy of this supplemental letter is being sent to the Alabama State Designee in accordance with 10 CFR 50.91(b)(1).

If you have any questions, please advise.

Yours very truly,

. L. Clayton, r.

FLCJr/GGY:ddr-D35 cc: Mr. R. A. Thomas Mr. G. F. Trowbridge Mr. J. P. 0'Reilly Mr. E. A. Reeves Mr. W. 'H. Bradford Dr. I. L. Myers

r bc: Mr. W. 0..Whitt

. Mr. R. P. Mcdonald Mr. H. O. Thrash

-Mr. O. D. Ki ngsicy, Jr.

Mr. W. G. Hairston III Mr. J. W. McGowan Mr. C. D. Nesbitt Mr. R. G. Berryhill Mr. D. E. Mansfield Mr. J. A. Ripple ..~j" Mr. W. G. Ware Mr. L. B. Long Mr. J. R. Crane Mr. K. C. Gandhi Reference Listing N

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