L-78-289, Proposed Amendment to Appendix a of Facility Operating License DPR-67 Regarding Surveillance Requirements for the Diesel Generator Units Used as the Onsite A.C. Power Source

Proposed Amendment to Appendix a of Facility Operating License DPR-67 Regarding Surveillance Requirements for the Diesel Generator Units Used as the Onsite A.C. Power Source

ML18088A126
Person / Time
Site:	Saint Lucie
Issue date:	09/05/1978
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-78-289
Download: ML18088A126 (15)

Text

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REGULATORY INFORMATION DISTRIBUTION SYSTEM (RID

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DISTRIOUTION FOR INCOMING MATERIAL 50-335 REC:

STELLO V NRC ORG:

UHRIG R E FL PMR 5 LIGHT DOCDATE: 09/05/78 DATE RCVD: 09/ii/78 DOCTYPE:

LETTER NOTARIZED:

YES

SUBJECT:

FORWARDING LIC NO DPR-67 APPL FOR AMEND: APPENDIX A TECH CONCERNING REVISION TO THE SURVEILLANCE REQUIREMENTS FOR UNITS AS Tl-IE ONSITE A. C.

PMR OURCEAT SUBJECT FACILITY.

l COPIES RECEIVED LTR 3 ENCL 40 SPEC PROPOSED CHANGE THE DIESEL GENERATOR NOTARIZED 09/05/78.

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FLORIOA POWER & LIGHT COMPANY September 5, 1978 L-78-289 Director of Nuclear Reactor Regulatiogff5]J( gg(p gf(p Attention:

Mr. Victor Stello, DirectdV--~

J Division of Operating Reactors U.

S.

Nuclear Regulatory Commission llashington, D.

C.

20555

Dear Mr. Stello:

Re:

St. Lucie Unit 1 Docket No. 50-335 Proposed Amendm'ent to Facilit 0 eratin License DPR-67 Pl( QP) g c/at "/

trt nAl c/a a

a In accordance with 10 CFR 50.30, Florida Power 5 Light Company submits herewith three (3) signed originals and forty (40) copies of a request to amend Appendix A of Facility Operating License DPR-67.

This proposed amendment relates to the surveillance requirements for the diesel generator units used as the onsite A.C. power source at St. Lucie Unit No.

1. It is being submitted at the request of members of the NRC staff.

The staff request specified that our proposed technical specifications we'e to incorporate the requirements of Regulatory Guide 1.108 "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants."

Based upon the information available to us at that time, at a meeting with members of the NRC staff on June 5, 1978, FPL agreed to comply with the testing requirements contained in Regulatory Guide 1.108, provided that these requirements would not necessitate any design, changes.

FPL has since reviewed in detail the Regulatory Positions contained in the guide; the results of that review and the manner in which we comply or will comply are contained in Attachment A.

Based upon our subsequent review and discussions with the diesel engine manufac-

turer, FPL believes that the requirements for testing frequency contained in Regulatory position C. 2.

d should be modified for St Lucie Unit No.l.

Regulatory Guide 1.108 was originally issued in August 1976 and subsequently revised in August 1977.

Its inception therefore came several years after the diesel gener-ator units at St. Lucie No.

1 had been procured and installed and a number of months after the Operating License for the unit was issued.

Recent correspondence with our di.'esel engine manufacturer indicates that the testing requirements set forth in the guide are excessive and, if implemented, may lead to premature fail-ures.

Since it is in the best interest of all concerned parties that diesel engine sureveillance enhance rather than degrade engine reliability, representatives from FPL and the diesel engine manufacturer would be willing to meet with the NRC for further discussion of this issue.

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Mr. Victor Stello, Director The proposed technical specification changes are shown on the accompanying technical specification pages contained in Attachment 8 bearing the date of this letter in the lower right hand corner.

These proposed changes have been reviewed by the St. Lucie Facility Review Group and the Florida Power 8 Light Company Nuclear Review Board, They have concluded that this amendment does not involve an unreviewed safety question.

They have further concluded that any additional testing requirements beyond those contained in attach'ment, B

may constitute an unreviewed safety question due to the potential for degraded reliability of the diesel generator units.

FPL believes that the proposed amendment is fee exempt since it has been requested by the Commission

and, as presented by FPL, has only minor safety significance.

Therefore no amendment fee is required.

Very

l. yours, Robert E. Uhrig Vice President REU:LLL:HAS:pit Attachments cc:

Mr. James P. O'Reilly, Region II Harold F. Reis, Esquire

I 4

ATTACHMENT A Re:

St. Lucie Unit 1

Docket No. 50-335 Evaluation of Proposed Technical Specifications Diesel Generator Units C.2-.a(1)

C.2.a(2)

C.2.a(3)

C.2.a(4)

C.2.a(5)

C.2.a(6)

Presently required by TS 4.8.1.1.2. c.3 Presently required by TS 4.8.1.1.2.c.3 FPL proposes to include this as an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test.

The diesel reaches equilibrium in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or less.

Eight hours provide a factor of 4 over the time required to reach equilibrium temperature.

Since we must perform both diesel generator and electrical switchgear preventative maintenance each outage, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run would delay these'items and therefore add unnecessary forced outage time.

Verification of generator capability to withstand the loss of the largest single load (600 HP) without tripping is presently required by TS 4.8.1.1.2.c.2.

Our D/G sets were designed to accomodate this degree of load rejection.

The loss of all,load is an unnecessary test and poses a risk of significant damage to the D/G.'owever, it has been demonstrated once by preoperational test.

To ensure that any control of governor system degradation is detected, we will add the voltage and frequency requirements suggested by the NRC, i.e., 4160 V+ 624 volts

(+ 15%);

60 HZ + 1.2 HZ'(+ 2X), to the loss of largest single load test required by TS 4.8.1.1;2.c.2.

Although the vendor has stated that they have never experienced hot restart (vapor lock) failures, we agree to do a hot start within 15

'* minutes and load the D/G to full load rating.

Maintaining safety-related components in line-ups capable of producing the design accident loading sequence would preclude RCS/ECCS main-tenance and delay each refueling.

Therefore, we maintain that loading the D/G to full load meets the intent of C.2.a.(5) without unnecessarily extending plant outages.

Also, the sequencing controls are" not affected in any manner by the temperature conditions of the D/G and this portion of the suggested testing merely duplicates C.2.a(2).

In order to do the monthly load test required by. TS 4.8.1.1.2.a.5 it is necessary to synchronize the D/G and pick up load (which is greater than emergency load).

This demonstrates synchronization.

At

. the end of the monthly test the load is transferred to off-site power;

~

and the D/G is shutdown (after opening the output breaker) and returned to a standby!line:up.

J Thus, the 18 month test is redundant to the already existing monthly periodic test.

e lt

ATTACHMENT A PAGE 2 C.2.a(7)

Presently required by TS 4.8.1.1.2.d.

C.2.a(8}

We maintain. that this item should not be required for the following reasons:

C.2. b C.2. c(l )

C.2.c(2}

C.2.d I)

By design, the D/G will not unload if loss of off-site power occurs during testing (this circumstance also affects our position on Section C.2.d described below).

2}

By design, the D/G is operated in parallel with (synchronized to) off-site power during testing.

In the event of SIAS (or. other safeguards signal) without loss of power the status of'he D/G-has no safety significance.

,:We concur with most of this section.

However, we do not agree that the "every 10 years" portion is necessary.

This is in reference to a

.design feature which is tested during the preoperational test program.

!le already have an administrative design control system, including retest requirements, as required by various NRC regulations to ensure that system design is not degraded.

We concur with this item and include a requirement in TS 4.8.1.1.2.a.4 for verifying time for starting the D/G.

Also, we would like to point out that this paragr'aph implies testing of 'the sequencing timers.

'The St. Lucie Unit 1 design utilized individual timing relays for each safeguard load.

The relays cannot be tested without disabling each component.

Therefore, the sequence timers testing will remain an 18 month (Refueling) surveillance (TS 4.8.1.1.2. c.6).

We concur with this item.

This requires assumi'ng load at the "maximum practical rate".

Since our system requires manual loading, we interpret this to be the maximum safe loading rate to ensure that the D/G is not overloaded.

It should be noted that our standard practice has been to load. the D/G expeditiously, and in any case it is impossible to even approach the design accident loading rate of about 3200 Kw in 30 seconds (FSAR Table 8.3-2).

From FSAR Table 8.3-2, we note that the maximum safeguards load is 3163 Kw (conservatively calculated).

, Therefore, we will use 3163 Kw as the "design full load rating" of the PSL diesel generators.

We feel. that the proposed increased testing frequencies are very undesirable and may lead to eventual degradation of the on-site emergency power, system since our diesel engines were not designed to

'ccommodate the degree'o'f testing to which they conceivably could be exposed under this position.

Our diesel engine manufacturer shares our position. that more frequent emergency starting creates a strong li.kelihood 'that the engine reliability will be degraded.:

'ATTACHMENT A PAGE 3 C.2.d C.3.b (Continued)

Emergency startup is known to be one of the most stressful and wear producing evolutions possible and this section potentially increases the number of fast cold starts and rapid loadings by a factor of 10 over existing requirements.

We sould like to suggest that the NRC use an existing program which specifically addresses diesel generator reliability.

The NRC Division of Inspection and Enforcement reviews all Licensee Event Reports and ensures.that corrective action is prompt, appropriate

'nd addresses generic or repeated failures. If the NRC feels D/G reliability is not being properly addressed, then an appropriate action might be to more fully implement the existing program, not to impose additional tests on equipment.

Regulatory Guide 1.108 reporting requirements are not the same as our present reporting requirements which are based on Regulatory Guide 1.16.

We plan to continue reporting in accordance with Regulatory Guide 1.16 as implemented by Technical Specifications 6.9.1.8 and

'6.9.1.9.

.)

Re:

St. Lucie Unit l Docket No. 50-335 Proposed Techni cal Speci fications Diesel Generator Units

ATl'ACE1ENT B ELECTRICAL PCAER SYSTEM SURVEILLANCE PE iJIREiiEHTS Continued 4.8.1.1.2 Each diesel generator set. shall be demonstrated OP"RABI E:

a

~

At least once per 31 days on a

STAGGERED TEST BASIS by:

1..Verifying the fuel level in the engine-mount d fuel tank.

2.

Yerifying the fuel level in the,fue'I stor>ge tanks 3.

Yerifying the fuel transfer pump can be started and transfers fuel from the storage system to the engine-mounted tank.

b.

c ~

4.

Verifying the diesel starts from ambient condition and accelerates to provide a nominal 60 Hz frequency in <

10 seconds 5.

Yerifying the generator is synchronized, then loaded, to > 3200 kw within 3 minutes and. operates for > 60 minutes.

6.. lerifying the diesel gen rator se~ is aligned to provide standby power to the. associated emergency busses.

At least once per 92 days by verifying that a-sample o, diesel fu 1 fr"m the fuel storage

=tank is within the acceptable limits specified in Table 1 of ASP1 0975-68 when checked fo, viscosity, water and sediment.

A"=least once-per 18 months during shutdown.'by:

1.

Subjecting the diesels to an inspection in accordance with procedures prepared in accordance

,vith its manufacturer's recommendations for this class of standby-servic

.2-3.

Verifying the generator capability to reject a load of >

600 hp without exceeding 4160 V + 624 V (+ 15:) arid 60 Hz +.

1.2 Hz (+ 2p).

Simulating a loss of offsite power in conjunction with a'af ety injecti on actuation signal, and:

a)

Verifying de-energi za tion of the emergency busses and load shedding from the emergency busses.

Yerifying the diesels start from ambient condition on the auto-start signal, energize the emergency busses with permanently connected

loads, energize ST.

LUCIE Ui'/IT 1

3/4 8-3 9/5/78

ELECTRICAL POWER SYSTEYiS SURVE ILLANCE REQUI REi"lEHTS (Continued c)

+he auto-connected emergency loads through the load sequencing system and operate for > 5 minutes while the gen rator is loaded with the emergency loads.

Verifying that, on the safety injection actuation signal, all diesel generator trips, except engine overspeed and generator differential, are automa-tically bypassed.

4, Verifying the D/G operates for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.,

During the first two hours of this test the load shall be >3520 Kw (110; of design) and during the remaining 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the load shall be >3200 Kw.

Nithin15minutes after completing this 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test, repeat Specification 4.8.1.1.2.a.5.

5.

Verifying that the auto-connected loads to each diesel generator set do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 3730 kw.

6.

Verifying that the automatic sequence timers're OPERABLF with th interval between each load block w"th>n +

1 second of its design interval.

At least once per-18 months by verifying that each fuel transfer pump transfers fuel from each fuel storage tank to the engine mounted fuel tanks on each diesel via the installed cross con-nec ion lines.

4.8.1.1.3 The Class lE underground cable system shall be demonstrated OPERABL'E:

Oe Within 30 days after the movement of any loads in excess of 80~ of i.he'round surface design basis load over the cable ducts by pulling a mandrel with a diameter of at least 805 of the duct's inside diameter through.a duct exposed to the maximum-loading (duct nearest the ground's surface) and ver-;fying that the duct has not been damaged.

At least once per 18 months, during shutdown, by:

l.

Selec+ing on a uotating basis at least 3 (one each in the ducts between the diesel generators and the switchgear, between the switchgear and the component cooling water pump

motors, and between the switchgear and the intake cooling water pump motors) Class lE 5000 volt underground cables and megger testing the selected cables at a minimum test ST.

LUCIE - UNITT'/4 8-4 9/5/70

STATE OF FLORIDA

)

)

COUNTY OF DADE

)

ss Robert E. Uhrig, being first duly sworn, deposes and says:

That he is a Vice President of Florida Power 6 Light Company, the Licensee herein; That he has executed the foregoing document; that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

Robert E.

U rig Subscribed and sworn to before me this say oZ 3, 19?E NOTARY PUBLIC, 'n and for the County of.Dade, State of Florida NOTAl U6UC OTAL OF FLORIDA ct tARQg MY COMY'VglO~) 'MLR,;S MARCH 27, V~

My commission expires.-Ro.io~o'TRwvAnuRo GCRcRG AamcY t"~

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