3F0986-02, Application for Amend to License DPR-72,consisting of Tech Spec Change Request 146,relaxing Action Statements for Tech Spec 3.8.1.1 in Order to Increase Diesel Generator Reliability by Reducing Excessive Test Starts.Fee Paid

Application for Amend to License DPR-72,consisting of Tech Spec Change Request 146,relaxing Action Statements for Tech Spec 3.8.1.1 in Order to Increase Diesel Generator Reliability by Reducing Excessive Test Starts.Fee Paid

ML20203M921
Person / Time
Site:	Crystal River
Issue date:	09/02/1986
From:	Widell R FLORIDA POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20203M922	List: 3F0986-02, Application for Amend to License DPR-72,consisting of Tech Spec Change Request 146,relaxing Action Statements for Tech Spec 3.8.1.1 in Order to Increase Diesel Generator Reliability by Reducing Excessive Test Starts.Fee Paid ML20203M926
References
3F0986-02, 3F986-2, NUDOCS 8609050177
Download: ML20203M921 (5)

Text

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lr [O ' Og Y*$ o, l Florida Power C O R POR ATION September 2,1986 3F0986-02 Mr. H. R. Denton, Director Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Technical Specification Change Request No.146 Diesel Generator Special Test

Dear Sir:

Florida Power Corporation (FPC) hereby submits the enclosed three (3) originals and forty (40) copies of Technical Specification (TS) Change Request No. 146.

This revision requests a relaxation in the action statements for Technical Specification 3.8.1.1 in order to increase diesel generator reliability by reducing excessive test 3 tarts and by reducing the situations where the diesels are running parallel with the grid.

An amendment application fee of one hundred fifty dollars ($150), check number 856084, as required by 10 CFR 170, has t.een included wi t.h this change request.

Sincerely, zu-Rolfh.Widell Manager, Nuclear Operations Licensing and Fuel Management 1 PGH/feb 8609050177 860902 2 PDR ADOOK 0500 U)/

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Enclosures P Q

xc: Dr. J. Nelson Grace Regional Administrator, Region II I" g i

h U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323 GENERAL OFFICE: 3201 Thirty fourth Strect South

• P.O. Box 14042 + St. Petersburg, Florida 33733 + (813) 866-5151 A Florida Progress Company

1 STATE OF FLORIDA COUNTY OF PINELLAS Rolf C. Widell states that he is the Manager, Nuclear Operations Licensing and Fuel Management for Florida Power Corporation; that he is authorized on the part of said company to sign and -file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information, and belief.

Rolf C.

Manager,pidel1 Nuclear Operations Licensing and Fuel Management Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 2nd day of September,1986.

YA Notaryfublic

$3fARY PUBLIC SIAIE OF FLORIDA PV COMISSICE ( AP JULY 22,1999 SCROED IPRU GE4ERAL IRS. Uno, Notary Public, State of Florida at Large, My Commission Expires: July 22, 1989

UNITED STATES OF AMERICA NUCLEAR RE6ULATORY COMMISSION IN THE MATTER OF )

) DOCKET No. 50-302 FLORIDA POWER CORPORATION )

CERTIFICATE OF SERVICE Rolf C. Widell deposes and says that the following has been served on tne Designated State Representative and the 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 of the request for amendment to Operating License No. DPR-72 (Change Request No. 146).

FLORIDA POWER CORPORATION

-I Rolf C.)Widell Manager, Nuclear Operations Licensing and Fuel Management SWORN TO AND SUBSCRIBED BEFORE ME THIS 2nd DAY OF SEPTEMBER 1986.

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l Notaryfublic l Notary Public, State of Florida at Large My Comission Expires: hcTaar ruetic start er nonroa NY cokMISSION EXP JutY 22,1989 (NOTARIAL SEAL) soeto ranu cintant Ins. uso.

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET NO. 50-302/ LICENSE NO. DPR-72 REQUEST NO. 146, REVISION O DIESEL GENERATOR SPECIAL TESTS LICENSE DOCUMENT INVOLVED: TECHNICAL SPECIFICATIONS PORTICH: 3.8.1.1. AC SOURCES, OPERATIl8G DESCRIPTION OF REQUEST:

This submittal requests a relaxation in the action statements for the referenced specification. Specifically, the time frame for demonstration of Diesel Generator operability has been changed from "within one hour" to "within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" if one AC power supply is inoperable, and to "within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />" if two AC power supplies are inoperable. The requirement to test the diesel generators every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter has been deleted.

REASON FOR REQUEST The purpose of this . change is to increase diesel generator reliability by reducing excessive test starts and by reducing the situations where the diesels are running parallel with the grid. The current specification requires demonctration of diesel generator operability within one hour if one or two AC power supplies are inoperable. Additionally, the diesel (s) must be tested every eight hours thereafter. This could mean up to nine tests in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> period. The diesel manufacturer and NRC Staff (see Generic Letter 84-15) have identified excessive diesel testing as causes of diesel degradation. Due to these concerns with excessive diesel starts, Crystal River Unit 3 satisfies the current action statement by continuously running the diesel loaded parallel to the grid rather than starting it every 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. While this does improve diesel reliability, it decreases the degree of independence between the offsite and onsite power systems.

SAFETY EVALUATION OF REQUEST:

The proposed relaxation of the action statement requirements will improve overall plant safety by improving diesel reliability and availability.

One purpose of the one hour action statement is to determine if the cause of the initial EDG failure may also cause the redundant EDG to fail. Historically, we have found that the cause of the initial EDG failure does not cause the redundant EDG to fail. As we have gained more experience in accident mitigation, more emphasis has been placed on core cooling than equipment reliability. While equipment reliability is important, attempting to perform the EDG reliability test within one hour of a power system degradation will take operators away from more critical activities.

A second reason to perform the initial and the subsequent follow-up EDG tests is to provide assurance that the diesels remain operable if further power system degradation occurs. The NRC staff re-evaluated the need for follow-up EDG testing in light of the excessive number of tests this action statement causes. (See SER #84 North Anna Unit 2, April 25, 1985). They concluded that the appropriate interval for diesel followup tests should be every 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. Because this interval exceeds :he total allowable outage time such that a shutdown has been initiated or operability has been restored, a requirement for follow-up tests would be unnecessary.

~ One concern with the action statement follow-up testing is the effect this has on power system independence. Due to our concern with increased EDG wear and reduced overall EDG reliability, we continuously run the EDG parallel to the grid rather than starting the diesel every eight hours (except during inclement weather). When the diesel is operated this way it is not independent of certain transients from the nonvital and offsite power systems. Thus the followup testing may cause a decrease in emergency power system availability (see IEN 84-69, Supplement 1, February 24, 1986). By deleting the eight-hour follow-up tests, we will reduce the potential for EDG unavailability.

This change request is based primarily on the North Anna Unit 2 amendment referenced above; specifically, Section 3.3 Special EDG Tests (action statements). The considerations applied in this SER also apply to Crystal River Unit 3, with the exception that the diesel is run continuously instead of every eight hours as described above.

SHOLLY EVALUATION OF REQUEST Florida power Corporation proposes that this amendment does not involve a significant hazards consideration. Diesel generator operability will still be demonstrated monthly. Additionally, the NRC staff has determined that excessive diesel generator testing contributes to premature engine degradation and that an overall improvement in reliability and availability can be gained by reducing diesel generator starts.

Therefore, the relaxation of the Action Statement initial and follow-up test periods for the diesel generators is compensated for by increased diesel generator reliability and availability. The Commission has provided standards for determining whether a significant hazards consideration exists (10 CFR 50. 92) . Based on those standards, this change will not:

(1) Involve a significant increase in the probability or consequences of an accident previously analyzed because the diesel generator does not cause accidents and because the reduction of diesel generator testing should improve diesel availability to mitigate accident consequences.

(2) Create the possibility of a new or different kind of accident because this change introduces no new mode of plant operation nor does it modify equipment or setpoints.

(3) Any reduction in the margin of safety will be insignificant since the purpose of this change is to conform to NRC guidance provided in Generic Letter 84-15. This change should increase diesel generator reliability and thus cause an increase in the overall margin of safety in the plant.