L-95-163, Provides Rev to 950330 Request for Amends to Licenses DPR-31 & DPR-41 Re TS SR 4.8.1.1.2.g.7

Provides Rev to 950330 Request for Amends to Licenses DPR-31 & DPR-41 Re TS SR 4.8.1.1.2.g.7

ML17353A238
Person / Time
Site:	Turkey Point
Issue date:	06/19/1995
From:	Goldberg J FLORIDA POWER & LIGHT CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML17353A239	List: L-95-163, Provides Rev to 950330 Request for Amends to Licenses DPR-31 & DPR-41 Re TS SR 4.8.1.1.2.g.7 ML17353A240
References
L-95-163, TAC-M91911, TAC-M91912, NUDOCS 9506290252
Download: ML17353A238 (12)

Text

PRIORITY 1 (ACCELERATED RZDS PROCESSING)

REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS)

ACCESSION NBR:9506290252 DOC.DATE: 95/06/19 NOTARIZED: YES DOCKET FACIL:50-250 Turkey. Point Plant, Unit 3, Florida Power and Light C 05000250 p

50-251 Turkey Point Plant, Unit 4, Florida Power and Light C 05000251 AUTH.NAME AUTHOR AFFILIATION GOLDBERG,J.H.

Florida Power

& Light Co.

RECIP.NAME RECIPIENT AFFILIATION Document Control Branch (Document Control Desk)

I

SUBJECT:

Provides rev to 950330 request for amends to licenses DPR-31

& DPR-41 re TS SR 4.8.1.1.2.g.7.

DISTRIBUTION CODE:

ADOID COPIES RECEIVED:LTR J ENCL

)

SIZE:

TITLE: OR Submittal:

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RECIPIENT ID CODE/NAME PD2-1 LA CROTEAU,R INTERNA FILE CE

-'l NHR DRCH/HICB NRR/DSSA/SRXB OGC/HDS3 EXTERNAL NOAC COPIES LTTR ENCL 1

1 1

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1 1

1 1

1 0

1 1

RECIPIENT ID CODE/NAME PD2-1 PD NRR/DE/EMCB NRR/DSSA/SPLB NUDOCS-ABSTRACT, NRC PDR COPIES LTTR ENCL 1

1 1

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1 1

1 D

N NOTE TO ALL,"RZDS" RECZPZENTS:

PLEASE HELP US TO REDUCE WASTE!

CONTACT THE DOCUMENT CONTROL

DESK, ROOM OWFN 5D8 (415-2083)

TO ELZMZNATE YOUR NAME FROM DISTRIBUTION LISTS FOR DOCUMENTS YOU DON'T NEED!

TOTAL NUMBER OF COPIES REQUIRED LTTR 12 ENCL 11

ly

PPK.

JUN19 t995 L-95-163 10 CFR 550.36 10 CFR 550.90 U.

S. Nuclear Regulatory Commission Attn:

Document Control Desk Washington D.C.

20555 Gentlemen:

Re:

Turkey Point Units 3 and 4

Docket Nos.

50-250 and 50-251 Proposed License Amendments Revision Periodic Testing of Emergency Diesel Generators TAC Nos.

M91911 M91912 By letters L-95-81, dated March 30,

1995, as revised by letter L 141, dated May 5, 1995, Florida Power and Light Company (FPL) requested that Appendix A of Facility Operating Licenses DPR 31 and DPR 41 be amended to revi'se Turkey Point Units 3 and 4 Technical Specification (TS) Surveillance Requirement 4.8.1.1.2.g.7),

Emergency Diesel Generator (EDG) loss of offsite power (LOOP) load acceptance hot start test within 5 minutes of the 24-hour EDG test zun.

Subsequent to our May 5, 1995 letter, and as a result of proposed license amendments review comments by the NRC staff, FPL has revised Attachment 1, "Description of Amendments" and Attachment.

3, "Proposed Technical Specifications".

FPL has concluded that the proposed license amendments'evisions do not alter the original conclusion, rendered in Attachment 2 to letter L-95-81, that no significant hazards considerations exist pursuant to 10 CFR 550.92.

In accordance with 10 CFR 550.91(b)(1),

a copy of these proposed license amendments'evisions aze being forwarded to the State Designee for the State of Florida.

The proposed revisions have been reviewed by the Turkey Point Plant Nuclear Safety Committee and the FPL Company Nuclear Review Board.

Should there be any questions, please contact us.

ery truly yours,,

J.

H. Goldberg President Nuclear Division Attachments cc:

S.

D. Ebneter, Regional Administrator, Region II, USNRC AT.

PE

Johnson, Senior Resident Inspector, USNRC, Turkey Point Plant W. A. PagqpgtA.+ florida Department of Health and Rehabilitative 950b290252 000250 PDR ADOCK 0 PDR an FPL Group company P

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STATE OF FLORIDA COUNTY OF PALM BEACH

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H. Goldberg being first duly sworn, deposes and says:

That he is President, Nuclear Division, of Florida Power and Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this 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.

J.

H.

Go ber Subscribed and sworn to before me this 6

day of JLlrt/d 1995.

Fo Name of Notary Public (Typ or Print)

NOTARY PUBLIC, 'in and for the County of Palm Beach, State of Florida My Commission expires 4 / Q7 Commission No.

J.

H. Goldberg is personally known to me.

R08ERTA S. EC0N0gy

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L-95-163 Attachment 1

Page 1

ATTACHMENT 1 DESCRIPTION OF AMENDMENTS RE VEST INTRODUCTION Florida Power and Light Company (FPL) proposes to revise Turkey Point Units 3 and 4 Technical Specification (TS) Surveillance Requirement (SR) 4.8.1.1.2.g.7),

Emergency Diesel Generator (EDG) loss of offsite power (LOOP) load acceptance hot start test within 5 minutes of the 24-hour EDG run,its associated

footnote, and BASES.

Currently, this SR contains a requirement to operate the EDG for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />; during the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />, the EDG is to operate with its 2-hour-rated load and for the last 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> it is to operate at its continuous-rated load.

Surveillance Requirement 4.8.1 '.2.g.7) currently requires that, within 5 minutes after completing this 24-hour test run, on a simulated LOOP signal, the EDG starts and energizes the emergency buses with any permanently connected loads within 15 seconds and energizes auto-connected shutdown loads through the load sequencer.

The proposed change would revise the SR to allow for the separation of the LOOP load acceptance test from the 24-hour EDG test run. Alternatively, FPL proposes to conduct a hot restart of the EDG within 5 minutes of the completion of the 24-hour EDG test run and to verify the EDG's ability to achieve rated voltage and frequency within 15 seconds of the restart signal.

The LOOP load acceptance test will be uncoupled from the 24-hour EDG test run but will continue to be conducted on an 18 month interval as required by existing SR 4.8.1.1.2.g.4)

BACKGROUND As part of the NRC Technical Specification Improvement

Program, NUREG-1366 reported the findings and recommendations of a comprehensive examination of SRs in TS that require testing during power operation.

Certain recommendations from this study were designed to remove testing requirements which may be counter-productive to safety in terms of equipment degradation and availability, and were incorporated into the Improved Standard Technical Specifications (ISTS) issued by the NRC in September 1992

'he NRC issued Generic Letter (GL) 93-05, "Line-Item Technical Specifications Improvements to Reduce Surveillance Requirements for Testing During Power Operation,"

on September 27, 1993. For plants that have TS in a format that is different than the

STS, GL 93-05 provides guidance to assist licensees in preparing license amendment requests to implement recommendations contained in NUREG-1366 as line-item TS improvements.

The proposed TS changes of Attachment 3 are consistent with the intent of the

L-95-163 Attachment 1

Page 2

NUREG recommendations, the guidance of GL 93-05, and the format of the individual plant TS.

Section 10.1 of Enclosure 1 to GL 93-05 includes recommended improvements to Technical Specifications for EDGs.

One of the recommended improvements is that the hot start test following the 24-hour EDG test run should be an EDG start test only (i.e.,

electrically loading of the EDG is not required)

. If the hot start test is not satisfactorily accomplished within 5 minutes following the 24-hour EDG test run, it should not be necessary to repeat the 24-hour EDG test run.

The only requirement is that, should the post-24-hour EDG test run hot start test fail, the hot start test is to be re-performed within 5 minutes of operating the EDG at its continuous rating for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperatures have stabilized.

DESCRIPTION OF PROPOSED CHANGE FPL proposes to change the following TS SR.

Technical S ecification Surveillance Re uirement 4.8.1.1.2.

.7 Revise SR 4.8.1.1.2.g.7) to allow for the separation of the LOOP load acceptance test from the 24-hour EDG test run to read as follows (proposed change in bold).

I1 7 )* Verifying the diesel generator operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

During the first 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loaded to 2550-2750 kW (Unit 3),

2950-3150 kW (Unit 4)'* and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this

test, the diesel generator shall be loaded to 2300-2500 kW (Unit 3),

2650-2850 kW (Unit 4)" (editorial note:

these asterisks apply to footnote "**"on page 3/4 8-7, which

reads, "Momentary transients outside these load bands do not invalidate this test." 'and not to the "**"footnote on page 3/4 8-8).

The generator voltage and frequency shall be 4160

+ 420 volts and 60

+ 1.2 Hz within 15 seconds after the start signal; the steady-state generator voltage and frequency shall be maintained within these limits during this test.

Within 5 minutes after completing this 24-hour test, verify the diesel starts and accelerates to reach a

generator voltage and frequency of 4160

+ 420 volts and 60 +

1.2 Hz within 15 seconds after the start signal.*'"

Additionally, FPL proposes to revise footnote "**" on page 3/4 8-8 consistent with this proposed change:

"**Ifverification of the diesel's ability to restart and accelerate to a generator voltage and frequency of 4160

+ 420 volts and 60 + 1.2 Hz within 15 seconds following the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />

L-95-163 Attachment 1

Page 3

operation test of Specification 4.8.1.1.2.g.7) is not satisfactorily completed, it is not necessary to repeat the 24-hour test.

Instead, the diesel generator may be operated between 2300-2500 kW (Unit 3),

2650-2850 kW (Unit 4) for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or until operating temperature has stabilized (whichever is greater).

Following the 2 hour2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />s/operating temperature stabilization run, the EDG is to be secured and restarted within 5 minutes to confirm its ability to achieve the required voltage and frequency within 15 seconds."

Justification:

This change is proposed consistent with the intent of NUREG-1431, "Standard Technical Specifications Westinghouse Plants" and NUREG-1366. Specifically, SR 4.8.1.1.2.g.7) is revised to allow for the separation of the LOOP load acceptance test from the 24-hour EDG test run.

The safety function of the EDGs is to supply AC electrical power to plant safety systems whenever the preferred AC power supply is unavailable.

Corresponding to their importance to safety, EDGs have extremely detailed TS SRs compared to other pieces of mechanical and electrical equipment in a nuclear power plant.

Through

SRs, the ability of the EDGs to meet their load and timing requirements is confirmed.

Surveillance Requirement 4.8.1.1.2.g.7),

as proposed, will demonstrate that the diesel engine can restart from a hot condition, such as subsequent to shutdown from normal surveillances, and achieve the required voltage and frequency within 15 seconds.

The 15 seconds time is derived from the requirements of the accident analysis to respond to a design large break Loss of Coolant Accident (LOCA). By performing this SR after 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (or after two hours, in accordance with the proposed revised footnote),

the test is performed with the diesel sufficiently hot.

The load band is provided to avoid routine overloading of the EDG. Routine overloads may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain EDG OPERABILITY. The requirement that the diesel has been operated for at least two hours at full load is based on NRC staff guidance for achieving hot conditions.

Momentary transients due to changing bus loads do not. invalidate this test.

Separating these two required tests gives the plant operators added flexibility and prevents critical path complications during the outages.

As a result of the testing sequence currently dictated by the Turkey Point TS, a minimum of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of critical path time is spent each refueling outage performing the 24-hour EDG test run.

By separating the two surveillance requirements, the 24-hour EDG test run can be completed off refueling outage critical path time.

L-95-163 Attachment 1

Page 4

SUMMARY

The proposed modification of the Turkey Point TS would revise the SR to allow for the separation of the LOOP load acceptance test from the 24-hour EDG test run. Alternatively, FPL proposes to conduct a hot start verification of the EDG's ability to achieve rated voltage and frequency within 15 seconds subsequent to the 24-hour EDG test run.

The LOOP load acceptance test will be uncoupled from the 24-hour EDG test run but will continue to be conducted on an 18 month interval as required by existing SR 4.8.1.1.2.g.4)

. Consistent with the ISTS, the ability of the EDGs to restart from a hot condition, such as subsequent to shutdown from normal surveillances, and achieve the required voltage and frequency within 15 seconds, will be tested.

The LOOP load acceptance test will be commenced with the EDGs in a "standby" condition, which is also consistent with the ISTS.

Attachment 3

PROPOSED TECHNICAL SPECIFICATIONS Marked-up Technical Specification Pages:

3/4 8-8 B 3/4 8-4 Revised Insert A to pg. 3/4 8-8 Proposed Insert B to pg. 3/4 8-8 Proposed Insert C to pg. 3/4 8-8 Proposed Insert D to pg. B3/4 8-4