3F1085-11, Application for Amend to License DPR-72,consisting of Tech Spec Change Request 139,reducing Frequency of Diesel Generator Cold Fast Start Tests from Monthly to Semiannually.Certificate of Svc Encl.Fee Paid

Application for Amend to License DPR-72,consisting of Tech Spec Change Request 139,reducing Frequency of Diesel Generator Cold Fast Start Tests from Monthly to Semiannually.Certificate of Svc Encl.Fee Paid

ML20138N548
Person / Time
Site:	Crystal River
Issue date:	10/28/1985
From:	Westafer G FLORIDA POWER CORP.
To:	Harold Denton Office of Nuclear Reactor Regulation
Shared Package
ML20138N551	List: 3F1085-11, Application for Amend to License DPR-72,consisting of Tech Spec Change Request 139,reducing Frequency of Diesel Generator Cold Fast Start Tests from Monthly to Semiannually.Certificate of Svc Encl.Fee Paid ML20138N561
References
3F1085-11, NUDOCS 8511050223
Download: ML20138N548 (5)

Text

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Power C O RPO R ATIO N October 28,1985 3F1085-ll 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.139

Dear Sir:

Florida Power Corporation (FPC) hereby submits the enclosed three (3) originals and forty (40) copies of Technical Specification Change Request No.139 requesting amendment to Appendix A of Operating License No. DPR 72. As part of this request, the proposed replacement page for Appendix A is enclosed.

This submittal proposes to reduce the frequency of diesel generator cold fast start tests currently required to be performed monthly such that these tests are performed semi-annually. This submittal includes additional administrative changes to the snubber table (inclusion of additional safety-related snubbers) and to the diesel generator bases (clarification of the term " ambient condition"). Please note that FPC intends to remove the snubber list, per Generic Letter 84-13, upon resolution of our GDC-4 exemption request.

An amendment application fee, check number 775895 of one hundred fif ty dollars ($150), as required by 10 CFR 170, has been included with this Change Request.

Sincerely, g e

G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management

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cc: Dr. 3. Nelson Grace (gh, k

g Regional Administrator, Regien 11 Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323 GEN ERAL OFFICE 3201 Thirty-fourth Street South 4 P.O. Box 14042, St. Petersburg, Florida 33733 e 813-866-5151

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

) DOCKET No. 50-302 FLORIDA POWER CORPORATION )

CERTIFICATE OF SERVICE G. R. Westafer deposes and says that the following has been served on the 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 Serv! es cf Citrus County Department of Health and Citrus County Courthouse Rehabilitative Services Inverness, FL 32650 1323 Winewood Blvd.

Tallahassee, FL 32301 A copy of Technical Specification Change Request No. 139 requesting amendment to Appendix A of Ope.ating Licensing No. DPR-72.

FLORIDA POWER CORPORATION

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G. R.'Westafer ~

Manager, Nuclear /

Operations Licensing and Fuel Management SWORN TO AND SUBSCRIBED BEFORE ME THIS 28th DAY OF OCTOBER 1985.

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Notary Pg61ic L Notary Public, State of Florida at Large My Commission Expires: July 22,1989 (NOTARIAL SEAL) l l

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a STATE OF FLORIDA COUNTY OF PINELLAS G. R. Westafer 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 bellei.

/ /

G. R. Westafer/

Manager, Nuclear Operations Licensing and Fuel Management Subscribed and sworn to before me, a Notary Public in ar.d for the State aad County above named, this 28th day of October,1985.

i AM, Notary Pgblic Notary Public, State of Florida at Large, My Commission Expires: July 22,1989

FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 DOCKET No. 50-302/ LICENSE NO. DPR 72 REQUEST NO. 139, REVISION O DIESEL GENERATOR COLD FAST STARTS LICENSE DOCUMENT INVOLVED: Technical Specifications PORTIONS: 3.7.9.1 Hydraulic Snubbers 3.8.1.1 Electric Power Systems Bases Electric Power Systems DESCRIPTION OF REQUEST:

On July 2, 1984, the NRC Staff issued Generic Letter 84-15 which identified cold fast starts of diesel generators as contributing to premature diesel engine degradation due to unnecessary wear. The NRC concluded that the frequency of diesel generator fast start tests from ambient conditions should be reduced. This submittal proposes tu reduce the number of diesel generator cold fast start tests currently required to be performed monthly such that cold fast start tests are performed semi-annually.

This submittal includes additional administrative changes to the snubber table to include additional safety related snubbers and to the diesel generator bases clarifying the term " Ambient Condition".

REASON FOR REQUEST:

Florida Power is requesting this change in order to improve diesel generator reliability. Reducing the frequency of cold fast starts will improve overall reliability and availability of the diesel generators by reducing mechanical stress and wear.

Generic Letter 83-41 implied that the " ambient condition" requirement in the diesel cold fast start test may not include any warmup of the diesel generators. To clarify the extent that diesel generator warmup is permissable, we have clarified the definition of " ambient condition" in the bases.

SAFETY EVALUATION OF REQUEST:

The reduction of cold fast diesel generator testing has been endorsed by the staff in Generic Letter 84-15, July 2, 1984. Additionally, Colt Industries, manufacturer of the CR-3 diesels, has endorsed this NRC action in a letter to the owner's dated February 27, 1985. Based on these actions, Florida Power concludes that this change will improve diesel generator reliability and availability.

The clarification of " ambient condition" is an administrative change and is consistent with our response to Generic Letter 83-41, dated January 13, 1984, with the exception that prelubing has been excluded.

The addition of the emergency feedwater snubbers is an administrative change. Please note that six snubbers were also recommended to be added to Table 3.7-3 in Change Request No. 103, Revision 2, dated July 25, 1984.

SHOLLY EVALUATION OF REQUEST Florida power proposes that this amendment does not involve a significant hazards consideration. Diesel generator cold fast start capability will be demonstrated semi-annually to ensure plant capability to mitigate the consequences of a large loss of coolant accident coincident with a loss of offsite power. Diesel generator operability will still be demonstrated monthly and will include any necessary i

prelubing and a gradual acceleration to 900 rpm. 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 fast cold starts. Therefore, we conclude that this amendment should result in enhanced engine reliability.

Based on the above, we find that the amendment will not:

1. Involve a significant increase in the probability or consequence of an accident previously evaluated because the reduced number of fast starts should increase the probability of diesel generator availability in the event of an accident.

2. Create the possibility of a new or different kind of accident f rem any accident previously evaluated because the proposed change introduces no new mode of plant operation and no physical modifications are required to be performed to the plant.

3. Involve a significant reduction in the margin of safety. Any reduction in the margin of safety will be insignificant since the purpose of this change is to conform to NRC Guidelines 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.

The administrative changes to the snubber listing and the bases are similar to example (i) of the examples which involve no significant hazard consideration per i commission guidance in the Federal Register (48 FR 14870). These changes are:

i) A purely administrative change to the technical specifications: For example to achieve consistency throughout the technical specifications, correction of an error or a change in nomenclature.

Specification 3.7.9.1 clearly allows the addition of more safety related snubbers provided the Technical Specifications are updated with the next I amendment request. The bases change is intended to clarify the nomenclature in Specification 3.8.1.1 and does not by itself change how the tests are performed. The proposed changes are similar to an example for which no significant hazards cor.siceration exists. Thus, we propose that these' administrative changes in':olve no significant hazards considerations.

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