AECM-84-0410, Discusses Util Conclusion Re Conformance of Tdi Diesel Generators to Reliability Requirements of GDC 17.Diesel Generators Inspected at Least Once W/Satisfactory Results

Discusses Util Conclusion Re Conformance of Tdi Diesel Generators to Reliability Requirements of GDC 17.Diesel Generators Inspected at Least Once W/Satisfactory Results

ML20093K878
Person / Time
Site:	Grand Gulf
Issue date:	07/28/1984
From:	Dale L MISSISSIPPI POWER & LIGHT CO.
To:	Harold Denton Office of Nuclear Reactor Regulation
References
AECM-84-0410, AECM-84-410, NUDOCS 8407310222
Download: ML20093K878 (3)

Text

1 E MISSISSIPPI POWER & LIGHT COMPANY

( Helping Build Mississippi P. O. B OX 1840, J AC K S O N. MIS SIS SIP PI 3 9 2 05 NUCLE AR LICEN51NG & SAFETY DEPARTMENT July 28,1984 Office of Nuclear Reactor Regulation U.S. Nuclear Regulatory Commission Washington, D.C. 20555 Attention: Mr. Harold R. Denton, Director

SUBJECT:

Grand Gulf Nuclear Station Units I and 2 Docket Nos. 50-416 & 50-417 License No. NPF-l 3 File: 0260/L-860.0 Division I and 2 TDI Diesel Generators AECM-84/0410 The NRC staff has recently completed its review of the information submitted by MP&L regarding the reliability of the Division I and 11 TDI DGs installed at GGNS Unit 1. This information includes MP&L submittals AECM-84/103, AECM-84/0240, AECM-84/0241, AECM-84/0373, and AECM-84/0386. MP&L submitted AECM-84/0345 on July 5, 1984, providing the results of the inspections, tests, and "as-manufactured" qualificotton review specified in the NRC staff's Order dated May 22,1984. Based upon the results of MP&L's activities related to that Order, MP&L informed the NRC staff on July 18,1984 (AECM-84/0350), of its conclusion that the GCNS Unit i TDI DGs meet the on-site emergency power supply reliability requirements of GDC-17 and that with the exception of the torslograph testing, all requirements of the Order had been met. As a result, MP&L further requested that the May 22,1984 Order be rescinded. The successful completion of the torslograph testing was reported in the MP&L letter dated July 26,1984 (AECM-84/0386).

In reaching its conclusion regarding the conformance of the GGNS Unit i TDI DGs to the reliability requirements of GDC-17, MP&L relles upon the following facts:

o Each of the GGNS Unit i TDI DGs have been inspected at least once, with satisfactory results.

o The Division 1 TDI DG has recently been inspected and tested in accordance with the requirements of the NRC staff and its consultants (i.e., in accordance with the requirements of the May 22,1984 Order) with excellent results.

O h

PDR

\

Member Middle South Utilities System O

f:

AECM-84/0410 MississlPPI POWER O LIZHT COMPANY U9' o The operational performance of the GGNS Unit i TDI DGs, both in terms of successful starting and demonstrated load carrying capability, has been excellent.

o Due to the fact that the load carrying capability of the GGNS Unit i TDI DCs is significantly greater than that required by the regulations, these DGs con and will be operated under conditions which result in loads. and stresses on critical engine components which are much less than those for which the engine components have been designed.

o MP&L has instituted a surveillance and maintenance program for the GGNS Unit i TDI DGs which for exceeds regulatory requirements for diesel generators at nuclear power plants and which assun that there will be early detection of any potential probiem.

In sum, evidence related to the specific TDI DGs installed at GGNS Unit I indicates that they, in fact, are highly reliable and that such reliability assures conformance with CDC-17.

As indicated in previous correspondence to the NRC staff (e.g., AECM-84/0271),

MP&L has committed to, prior to restart from the first refueling outage, implement (as appropriate) the findings from the NRC review of the TDI DG Owners Group resolution. MP&L believes that this commitment is confirmatory in nature and that it should not be construed as indicating any lack of confidence in the reliability of the GGNS Unit i TDI DGs. It is MP&L's understanding that the NRC staff will recommend that this commitment be reflected as a condition of the FPOL for GGNS Unit 1. MP&L has no objection to such a recommendation.

4 Neither the NRC staff nor MP&L con conclude today whether some future technical requirement, which is unknown but might arise from the TDI DG Owners Group findings. There is presently no requirement from which an exemption is needed. The basis for such an exemption cannot be shown since the basis for non-compliance with a possible future requirement cannot be shown.

MP&L further understands that the NRC staff is also currently considering whether an exemption to GDC .17 (with respect to the reliability of the GGNS

. Unit i TDI diesel generators) is required for authorization of full power operations. Based on the Information previously provided to the NPC staff, as 1

9 i

_ - , r, ..._e--- - ~ % , mm -_y-y ,--.-_s._ , , , - - , , --.-w-

.-- AECM-84/0410 Mississippi POWER Q LI2HT COMPANY i-summarized above, MP&L does not believe that on exemption to GDC-17 related i to the reliabillity of the GGNS Unit i TDI DGs is necessary or oppropriate.

Nonetheless, if the NRC staff cannot reach a similar conclusion, MP&L believes that sufficient information has been presented in previous submittals and herein to demonstrate that the standards of 10 CFR 50.12(a) have been met.

Sincerely, k

Larry F. Dale Director, Nuclear Licensing & Safety LFD/ sad cc: Mr. J. B. Richard Mr. R. B. McGehee Mr. N. S. Reynolds Mr. G. B. Taylor Mr. Richard C. DeYoung Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission Washington, D.C. 20SSS Mr. J. P. O'Reilly Regional Administrator U.S. Nuclear Regulatory Commission Region 11 101 Marietta Street, N.W., Suite 2900 Atlanto, GA 30323 1 _