L-78-292, Letter Submits Request to Amend Appendix a of Facility Operating Licenses DPR-31 & 41, Relates to Surveillance Requirements for Diesel Generator Units Used as Onsite A.C. Power Source at Turkey Point Units 3 & 4

Letter Submits Request to Amend Appendix a of Facility Operating Licenses DPR-31 & 41, Relates to Surveillance Requirements for Diesel Generator Units Used as Onsite A.C. Power Source at Turkey Point Units 3 & 4

ML18227D797
Person / Time
Site:	Turkey Point
Issue date:	09/08/1978
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-78-292
Download: ML18227D797 (14)

Text

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

DISTRIBUTION FOR INCOMING MATERIAL 50-2 251 REC: STELLO V ORG: UHRIG R E DOCDATE: 09/08/78 Nr;C FL PWR 5 LIGHT DATE RCVD: 09/1'/78 DOCTYPE: LETTER NOTARIZED: YES COPIES RECEIVED

SUBJECT:

LTP. =-: ENCL 40 FORWARDING LIC NOS DPR-31 8 41 APPL FOR AMEND: APPENDIX A TECH SPEC PROPO"ED CHANGE CONCERNINO REVISION TO SURVEILLANCE REQUIREMENT ~ FOR Tl<E DIESEL GENERATOR UNITS UESED AS TIIE ONSITE A. C. PWR SOURCE AT SUBJECT FACILITY"S... NOTARIZED ov/08/78.

PLANT NAME: 1URKEY PT 53 REVIEWER iNITIAL: X JM TURKEY PT 84 DISTRIBUTER INITIAL:

DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ONSITE EMERGENCY POWER SYSTEMS.

(DISTRIBUTION CODE A015)

FOR ACTION: IEF ORBN1 BC~"4W/7 ENCL INTERNAL: REG FIL . ~W/ENCL NRC PDR+<W/ENCL ENCL GELD>+W/ENCL MIPC44W/ENCL HANAUER~~W/ENCL AUXILIARY SYS BR>4W/ENCL I 8. C SYSTEMS BR++W/ENCL AD FOR SYS 8c PROJ4->W/ENCL ENGINEERING BR++W/ENCL

'REACTOR SAFETY BR++W/ENCL PLANT SYSTEMS BR++W/ENCL EEB+4W/ENCL POWER SYS BR++W/ENCL T. WAMBACIS++W/ENCL D. TOND I+4 W/ENCL

.D. MCDONALD44W/ENCL J. 'I.IANNON+4W/ENCL J MCGOUGH>%W/ENCL

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EXTERNAL: LPDR S MIAMI FL+~~W/ENCL ACRS CAT B++W/16 ENCL DISTRIBUTION: LTR 44 ENCL 44 CONTROL NBR: 782130349 SIZE: 2P+7P

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'OJBOX 013100, MIAMI, FL 33101 FLORIOA POWER & LIGHT COMPANY September 8, 1978 L-78-292 Director of Nuclear Reactor Regulation Attention: Mr. Victor Stello, Director Division of Operating Reactors U. S. Nuclear Regulatory Commission Washington, D.C. 20555

Dear Mr Stello:

Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed Amendment to Facilit C eratin Licenses DPR-31 and DPR-41 Zn accordance with 10 CFR 50 30, Florida Power 6 Light Company submits herewith three (3) signed. originals and forty (40) copies of request to amend Appendix A of Facility Operating Licenses DPR-31 and 4-1..

This proposed amendment relates to the surveillance requirements for the diesel generator units used as the onsite A.C power source at Turkey Point Units 3 and. 4.

staff.

It is being submitted at the request of members of the NRC The staff request specified that our proposed technical specifica-tions were to incorporate the requirements of Regulatory Guide 1.108 Electric "Periodic Testing of Diesel Generator Units Used as Onsite Power Systems at Nuclear Power Plants." Based upon the information available to us at that time, at a meeting with members o the NRC staff on June 5, 1978, FPL agreed to comply with the testing require-ments contained in Regulatory Guide 1.108 provided that these require-ments 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 manufacturer, FPL believes that the requirements for testing frequency contained in Regulatory Position C.2.d should be modified for Turkey Point Units 3 and 4. Regulatory Guide 1.108 was originally issuI-.d in August. 1977. Its inception therefore came several years after the diesel generator units at Turkey Point had been procured and installed and the Operating Licenses issued. Recent. correspondence with our diesel engine manufacturer indicates that the testing requirements set forth in the guide are excessive and, it is in if implemented, may lead to interest of all concerned pre-mature failures. Since the best parties that diesel engine surveillance enhance rather than degrade engine reliability, representatives from PPL and the diesel engine man-facturer would be willing to meet with the NRC for further discussion p(5

Nr. Victor Stello, Director of this issue.

The proposed technical specification changes are shown on the accom-panying technical specification pages contained in Attachment B bearing the date of this letter in the lower right hand corner.

These proposed changes have been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power 6 Light Company Nuclear Review Board, They have concluded that this amendment does not in-volve 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 poten-ial for degraded reliability of the diesel generator units.

FPL believes that the proposed amendment is fee exempt since it has been reauested by the Commission and,, as presented by FPL, has only minor safety significance. Therefore no amendment fee is required.

Very uly yours, Robert E.. Uhrig Vice President REU:LLL:HAS:pit Attachments cc: Nr . James P 0 'eilly, Harold F. Reis, Esquire Region ZX

4 .i 4

II

ATTACHMENT A Re: Turkey Point Units 3 5 4 Docket Nos. 50-250 and 50-251 Evaluation of Proposed Technical Specifications Diesel Generator Units C.2.a(1) Presently required by TS 4.8.l.b.

C.2.a(2) We concur with this, section.

C.2.a(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 provides 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.

C.2.a(4) Me concur with the verification of generator capability to withstand the loss. of the largest single load, without tripping. Our D/G sets were designed to accommodate. this degree of load rejection.

The loss of all load is an unnecessary test and poses a risk damage to the D/G However, it has been demonstrated of'ignificant.

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

(+ 155); 60 HZ 1.2 HZ (+ 25),. to the loss

+ of the largest single load, test.

C.2.a(5) 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 maintenance and delay each refueling. Therefore, we maintain that loading the D/G to full 1qad meets the intent of C.Z.a.(5) without unnecessari ly delaying 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).

C.2.a(6) In order to do the monthly load test, it is necessary to synchronize the D/G and pick up load (which is greater than emergency load).

This demonstrated 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.

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

C.2.a(7) Not applicable. By design, the Turkey Point engines have one fuel supply system.

ATTACHMENT A PAGE 2 C.2. a(8) We maintain that this item should not be required because the necessary demonstration would- include a rejection of full load by the diesel generator. As discussed under C.2.a(4) above, full load rejection poses a risk of significant damage to the diesel generator.

C.2.b 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.

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

C.2'.c(1) We concur with this item and include a requirement for verifying time for starting, the D/G..

C.2.c(2) We concur with- this item This requires assuming 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 over loaded It should'e 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 2000 Kw in 33 seconds (FSAR Table 8.2-3).

C.2- d We feeT that the proposed increased testing frequencies are very undesirable and may lead to eventual degradation of the on-site emergency power system. Our diesel engine manufacturer shares our position that more frequent emergency starting. creates a strong likelihood that the engine rel.iability will be degraded.

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

C.3. b 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 Specification 6.9.2.

ATTACHMENT B Re: Turkey Point Units 3 and 4 Docket Nos. 50-250 and 50-251 Proposed Technical Specifications Diesel Generator Units

~ ~

ao TABLE 4.1-2 (Sheet of 3)

MINIMUM FREQUENCIES FOR EQUIPMENT AND SAMPLING TESTS ll. Reactor Coolant Sys- Evaluate Daily tern Leakage

12. Spent Fuel Pit Boron Concentration Prior to refueling

13. Secondary Coolant I-131 Concentration Weekly*g I

14. Vent Gas, & I-131 & Particulate Weekly*

P'articulates Activity I

1.S. I Fire Protection Pump Operable Monthly

& Power Supply

16. Turbine Stop and Con- Closuie. Monthly ** 45

~

) trol Valves Reheater I Stop and: Intercept Valves:

17- LP'urbine Rotor VMT~ PT Every 5 Years 6 Years Inspection (w/o rotor disassembly)

18. Spent Fuel*~ Functioning Within 7 days of using 7 days Cask Crane Inter1ocks crane to fuel cask lift spent when.cran~

is being used to maneuver spent fue3 cask h

N.A. during cold'r. refueling. shutdowns The speCified tests"- however, shall be performed prior .to heatup above 200 F..

A V r ~ ~

~When activity exceeds 10% of specification,.frequency shall be-..changed t'o daily.

• • In the interim period until-the spent fuel cask crane

~

interlocks are installed (instal-lation is to be, completed no later than June,1977) the followin'g controls sha1.1 be used to prevent movement of the cask over spent fuel:

l. Indexing of the crane and trolley will be implemented.

2. Once properly posi,tioned, the respective crane bridge and trolley drives will be de-energized as appropriate.

3. In addition, a mechanical bumper will be installed to limit trolley travel in the westward direction, such that movement of the spent fuel shipping cask over spent fuel. is .prevented.

9/8/78

4.8 EMERGENCY POllER SYSTEM PERIODIC TESTS A Vtttit  : IIPPII P I d' the mergency power system.

tl g d 11 q t

~0b ective: To verify that the emergency power system will respond promptly and. properly.

e ifi li: Igtated:fll s

I g d 111 tilt p f d 1 Diesel Generator Each diesel generator shall be demonstrated OPERABLE:

a. At least once per 31 days by:

1 Verifying the fuel level in the day, and engine-mounted fuel tank.

2 Verifying- the fuel level in the fueT storage tank.

3. Verifying a fuel transfer. pump can be started and transfers fuel from the Diesel, Oil Storage Tank to the Day Tank 4; 'erifying the diesel starts from ambient condition and accelerates to provide a nominal 60 Hz frequency in < 15 seconds.

5 Verifying: the generator is synchronized, loaded to

> 2500 kw within 10 minutes and operates- for > 60 minutes.

'.. At 1'east once per 92 days by verifying that a sample of diesel fuel from the fuel storage tank is within accept-able limits when checked for viscosity, water and sediment.

c. At least once per 18 months by:

1. Subjecting the diesel to an inspection in conjunction with its manufacturer's recommendations for this class of standby service.

2. Verifying the generator capability to reject a load of > 200 kw without exceeding 4160 V + 624 V and 60 Hz + 1.2 Hz.

3. Simulating a loss of offsite power and a safety injection signal, and a) Verifying de-energization and load shedding from 4160 Volt busses.

4.8-1 9/8/78

b) Yerifying the dies% start from ambient condition on the auto-start signal, energize the 4160 volt busses, energize appropriate emergency loads through the load sequencing system, and operate for > 5 minutes.

4.. Verifying the diesel generator operates for a 1'east 8 hours. Ouring the first two hours of this test, the diesel generator shall be loaded to > 2750 kw 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

> 2500 kw. Within 15 minutes after completing the 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.a.5.

5. Verifying that the auto-connected loads to each diesel generator do not exceed 2750 kw.

2. Station Batteries

a. The pilot. cell specific gravity shall be read and recorded. daily. The pilot cell shall. be rotated on a monthly basis b Monthly the battery shall be given an equalizing charge,.

and afterwards specific gravity and voltage readings shall be taken. and recorded for each cell. Water shall be added to restore normal level and total water use shall be recorded. Complete visual inspection of batteries shall be made monthly..

c. quarterly detailed visual inspection shall be made of char gers

d. Annually connections. shall be checked, for tightness and anti-corrosion coating shall be applied to interconnections.

e Perform: load test annually.

4.8-2 g/8/78

STATE OF FLORIDA )

) ss COUNTY OF DADE )

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

That he is a Vice President of Florida Power & 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 Uhrig Subscribed and sworn to before me this day of NOTARY PUBLEC, in and for the county of Dade, State of Florida

'NOTA' ASUC STAT" OF FLORlOA at tARCE MY COMMiS8;CN ~ EXi"jitg >ItARON 27 My COmmiSSiOn eXPireS: QCNoEo ThRU N',.'NAPD coNoiNO AoENoy

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