ML070120088

License Amendment Request 230 Emergency Diesel Generator Short-Time Load Testing

ML070120088
Person / Time
Site:	Kewaunee
Issue date:	01/10/2007
From:	Gerald Bichof Dominion Energy Kewaunee
To:	Document Control Desk, Office of Nuclear Reactor Regulation
References
07-0008, LAR-230
Download: ML070120088 (42)

Text

1)ominion Energy Kewaunee, Inc.

i l l 0 0 I h r n ~ n ~ ~ ~ n Roulcvard. Glen Allcn. VA 23000 January 10, 2007 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, DC 20555 Dominion' Serial No.

07-0008 KPSILICIGR: R1 Docket No.

50-305 License No. DPR-43 DOMINION ENERGY KEWAUNEE. INC.

KEWAUNEEPOWERSTATION LICENSE AMENDMENT REQUEST 230 EMERGENCY DIESEL GENERATOR SHORT-TIME LOAD TESTING Pursuant to 10 CFR 50.90, Dominion Energy Kewaunee, Inc. (DEK) requests an amendment to Facility Operating License Number DPR-43 for Kewaunee Power Station (KPS). This amendment would modify KPS Technical Specification (TS) 4.6.a.5 to permit performance of the emergency diesel generator rated load test at a reduced load consistent with the short-time rating for the emergency diesel generators. Specifically, the proposed amendment would lower the load at which the rated load test is performed from 2950 kW to a load band between 2730 kW and 2860 kW.

The proposed amendment is consistent with American National Standards Institute/lnstitute of Electrical and Electronics Engineering (IEEE) Std. 387-1977 (IEEE 387-1 977) and NRC Regulatory Guide 1.%I 993.

Additionally, the proposed amendment is consistent with NRC approved NEI technical specification task force travelers (TSTF) 276-A, Revision 2, "Revise DG full load rejection test," and TSTF 283-A, Revision 3, "Modify Section 3.8 Mode restriction Notes." Changes have also been proposed to align KPS TS 4.6.a.5 with NUREG 1431, "Standard Technical Specifications Westing house Plants," surveillance requirement 3.8.1.1 4.

DEK has evaluated the proposed amendment and concluded it qualifies for a no significant hazards determination.

DEK requests approval of the proposed amendment by March 31, 2007. An expedited review is needed to ensure a shutdown of the Kewaunee Power Station is avoided.

Currently, if outside air temperature exceeds 75°F) both emergency diesel generators must be declared inoperable and the unit shutdown. A review of the available historical information shows that the outside air temperature near KPS can exceed 75°F as early as April 6. Therefore, if NRC approval is received by March 31, 2007, DEK is projected to have at least one week to implement the approved amendment. Once approved, the amendment shall be implemented within 60 days. to this letter contains a description, a safety evaluation, a significant hazards determination, and environmental considerations for the proposed amendment.

Serial No. 07-0008 License Amendment Request 230 Page 2 of 4 contains the marked-up TS pages, and attachment 3 contains the proposed TS pages as revised. Attachment 4 contains the proposed marked-up TS basis pages and attachment 5 contains the TS basis pages as revised, for information only.

The Plant Operations Review Committee has approved the proposed amendment and a copy of this submittal has been provided to the State of Wisconsin in accordance with 10 CFR 50.91 (b).

If you have any questions or require additional information, please contact Mr. Gerald Riste at (920) 388-8424.

Very truly yours, Gerald T. ~ i s c h o P L /

Vice President - Nuclear Engineering Attachments:

1. Discussion of Change, Safety Evaluation, Significant Hazards Determination and Environmental Considerations

2. Marked-up TS Pages

3. Affected TS Pages

4. Marked-up TS Bases Pages

5. Affected TS Bases Pages Enclosure

1. Letter from David A. Strickland (MKW) to Mike Anthony (Duke Engineering and Services), dated June 1 1, 1992 Commitments made in this letter: None

Regional Administrator U. S. Nuclear Regulatory Commission Region Ill 2443 Warrenville Road Suite 21 0 Lisle, Illinois 60532-4352 Mr. R. F. Kuntz Project Manager U.S. Nuclear Regulatory Commission Mail Stop 0-7D1 A Washington, D. C. 20555 Mr. S. C. Burton NRC Senior Resident Inspector Kewaunee Power Station Public Service Commission of Wisconsin Electric Division P.O. Box 7854 Madison, WI 53707 Serial No. 07-0008 License Amendment Request 230 Page 3 of 4

Serial No. 07-0008 License Amendment Request 230 Page 4 of 4 COMMONWEALTH OF VIRGINIA

)

COUNTY OF HENRICO 1

)

The foregoing document was acknowledged before me, in and for the County and Commonwealth aforesaid, today by Gerald T. Bischof, who is Vice President - Nuclear Engineering of Dominion Energy Kewaunee, Inc. He has affirmed before me that he is duly authorized to execute and file the foregoing document in behalf of that Company, and that the statements in the document are true to the best of his knowledge and belief.

Acknowledged before me this /O

• day of

,2007.

u My Commission Expires:

u b&

h 4

~

Notary ~ 6 b l i c (SEAL)

ATTACHMENT 1 LICENSE AMENDMENT REQUEST 230 EMERGENCY DIESEL GENERATOR SHORT-TIME LOAD TESTING DISCUSSION OF CHANGE, SAFETY EVALUATION, SIGNIFICANT HAZARDS DETERMINATION AND ENVIRONMENTAL CONSIDERATIONS KEWAUNEE POWER STATION DOMINION ENERGY KEWAUNEE, INC.

Serial No. 07-0008 Page 1 of 21 Kewaunee Power Station License Amendment Request 230 Emergency Diesel Generator Short-time Load Testing INTRODUCTION In May 2006, Dominion Energy Kewaunee, Inc. (DEK) determined that the Kewaunee Power Station (KPS) emergency diesel generator (EDG) de-rating curves, based on inlet combustion air temperature, had been incorrectly applied. This resulted in the potential to operate the EDGs outside of the vendor recommended ratings during the initial EDG loading period (from 0 to 1 hours1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per KPS Updated Safety Analysis Report Table 8.2-1) following a design basis event.

On November 15, 2006, it was identified that both EDGs would not have been able to meet Technical Specification (TS) Surveillance 4.6.a.5, at all times when the EDGs were considered operable, due to elevated ambient temperatures. TS Surveillance 4.6.a.5 states:

"Each diesel generator shall be loaded to 2950 kW (nominal) for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> every operating cycle. "

KPS TS 4.0.a states in part:

"Failure to meet a surveillance requirement, whether such failure is experienced during the performance of the sun~eillance or between performances of the surveillances, shall be failure to meet the OPERA BlLl TY requirements for the LCO. " (Emphasis added)

DEK has determined, as described in reference 11, that when outside air temperature exceeds 75°F) the EDGs cannot be loaded to 2950 kW for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> and therefore would not be able to meet TS 4.6.a.5. Each EDG has been loaded to 2950 kW for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> within the required surveillance test interval (the surveillance requirement has been met). However, if outside air temperature exceeds 75°F between tests, the EDGs would be inoperable because they would not be capable of meeting TS Surveillance 4.6.a.5 without exceeding the vendor recommended rating curves.

1.0 DESCRIPTION

This letter is a request to amend Operating License DPR-43 for the KPS.

This proposed amendment would modify KPS TS Surveillance 4.6.a.5 establishing consistency with IEEE 387-1977 paragraph 6.4.3(2) and paragraph 6.6.2 (reference 1).

In November 1979, a proposed amendment was submitted to add a monthly surveillance requirement (SR) to KPS TS to test the EDGs in accordance with the intent of IEEE 387-1977, paragraph 6.4.3, "Rated Load Test."

IEEE 387-1977 paragraph 6.4.3, rated load test (RLT) states:

Serial No. 07-0008 Page 2 of 21 "Rated load tests shall demonstrate the capability of carrying the following loads for the indicated times without exceeding the manufacture's design limits:

(1) A load equal to the continuous rating for a time required to reach a temperature equilibrium plus 1 h.

(2) A load equal to the short time rating for 2 h. "

IEEE 387-1 977, paragraph 3.7.2, defines short time rating as:

"The electric power output capability that the diesel-generator unit can maintain in the service environment for 2 h in any 24-h period, without exceeding the manufactures design limit and without reducing the maintenance interval established for the continuous rating."

In April 1986, a proposed amendment to KPS TS (reference 5) was submitted to modify the RLT surveillance requirement by splitting the continuous rating 1-hour load test and the short-time 2-hour load test. The SR interval to load the KPS EDGs to their short-term (used synonymously with short-time) rating for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> was changed from monthly to every operating cycle. In the April 1986 proposed amendment, the short-term (short-time) rating was stated as 2950 kW.

This proposed amendment would revise TS 4.6.a.5 to reduce the short-time EDG load rating. The proposed new short-time load rating for the RLT is a load band between 105% and 1 10% of the continuous load rating for the EDGs. The proposed load band is consistent with IEEE 387-1 977 (reference 1) and NRC Regulatory Guide 1.9, "Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used As Class 1 E Onsite Electric Power Systems at Nuclear Power Plants," Revision 3, 1993, paragraph 2.2.9, "Endurance and Margin Test," (reference 8).

A review of the historical temperature extremes near KPS showed that an outside air temperature of 75°F or greater could be achieved as early as April. Therefore, DEK is requesting an expedited review of this license amendment request (LAR) to prevent a unit shutdown in the event that outside air temperature exceeds 75"FJ which would cause both EDGs to be inoperable and require KPS to shutdown.

This proposed amendment would also incorporate two technical specification task force (TSTF) items to the extent practicable, given KPS TS are custom TS.

1.

TSTF-276-A, Revision 2, "Revise DG full load rejection test."

This TSTF identified that in improved standard technical specifications (ITS)

(Reference 10) SR 3.8.1.9, 3.8.1.lo, and 3.8.1.14, the requirement that the full load rejection test be performed at a specified power factor was typically presented as a Note associated with the SR with clarifications addressing situations when the power factor cannot be achieved. When the DG is not

Serial No. 07-0008 Page 3 of 21 paralleled to the grid, the power factor is determined by plant load and cannot be adjusted. Therefore, power factor requirements are applicable only when the test is performed with the DG paralleled to the grid. This TSTF provides additional detail and was intended to improve clarity and ensure requirements are fully understood and consistently applied.

The proposed amendment would add Note 3 to TS 4.6.a.5 consistent with this TSTF. The proposed new Note is consistent with TSTF 276-A, Revision 2 in that the proposed new Note specifies that if grid conditions do not permit synchronization of the EDG to the offsite grid the power factor limit is not required to be met. However, under this condition "the power factor shall be maintained as close to the limit as practicable."

2. TSTF-283-A, Revision 3, "Modify Section 3.8 Mode restriction Notes."

This TSTF change modifies mode restrictions on the performance of Surveillances in ITS TS 3.8.1 and 3.8.4 in NUREG 1431 (reference 10). The MODE restriction Notes on Surveillances in ITS TS 3.8.1 and 3.8.4 are modified to allow performance of the Surveillances in the prohibited MODES in order to reestablish OPERABILITY.

The change added a statement allowing these Surveillances to be performed in MODES 1 or 2 to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced.

The proposed amendment would add Note 2, modified to align with the Mode definitions in the KPS TS, to TS 4.6.a.5.

2.0 PROPOSED CHANGE

This proposed amendment to KPS TS would modify the EDGs rated load test in TS 4.6.a.5 to meet the intent of IEEE 387-1977 and Regulatory Guide 1.9. In addition, the proposed amendment would modify the rated load test to incorporate two applicable TSTF items, TSTF-276-A, Revision 2 and TSTF-283-A, Revision 3.

KPS TS 4.6.a.5 currently states:

5.

Each diesel generator shall be loaded to 2950 KW (nominal) for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> every operating cycle.

This LAR proposes to change KPS TS 4.6.a.5 to state:

5. Each diesel generator shall be operated for 2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> every operating cycle:

Note 1 Momentary transients outside the load and power factor ranges do not invalidate this test.

Serial No. 07-0008 Page 4 of 21 Note 2 This Surveillance shall not normally be performed in the OPERATING MODE or HOT STANDBY MODE. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this surveillance requirement.

Note 3 If performed with the diesel generator synchronized with offsite power, it shall be performed at a power factor 5 0.9. However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable.

a. For 2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2 2730 kW and 5 2860 kW, and

b. For the remaining hours of the test loaded 2: 2340 kW and 5 2600 kW.

Therefore, the proposed changes are:

1. lncrease the run time of the test from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to greater than or equal to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

2. Reduce the loading requirement for the 2-hour portion of the 24-hour test from 2950 kW to a load band between 2730 kW and 2860 kW.

3. Add a new requirement to run the EDG for the remainder of the 24-hour test in a load band between 2340 kW and 2600 kW.

4. Add a new Note 1 to allow momentary transients outside the prescribed loading limits without invalidating the test.

5. Add a new Note 2 to provide restrictions and contingencies on the plant mode within which the test may be performed.

6. Add a new Note 3 to state the power factor restriction for the test and an allowance for when the restriction can be relaxed.

In summary, DEK is proposing changes to KPS TS 4.6.a.5 that are consistent with IEEE 387-1 977, Regulatory Guide 1.9-1 993, and NUREG 1431, Revision 3.1. The proposed changes generally will:

1. lncrease the rated load test run time from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />,

2. Reduce the short-time test loading requirement from 113.5% of the continuous load rating to between 105% and 11 0% of the continuous load rating, and

3. Add an additional loaded period at a load between 90% and 100% of the continuous load rating.

Serial No. 07-0008 Page 5 of 21 In addition, the KPS TS basis for TS 4.6.a.5 is being changed to provide additional information. The TS bases are being changed to provide KPS personnel with a commensurate amount of information that is contained in the NUREG 1431 basis for SR 3.8.1.14, modified as appropriate to match KPS licensing basis and plant design.

These TS basis changes are included as attachments 4 and 5 for information.

3.0 BACKGROUND

The KPS Auxiliary Electrical System is designed to provide a simple arrangement of buses requiring the minimum of switching to restore power to a bus in the event that the normal supply to that bus is lost.

The basic components of the plant electrical system are shown on the single line and circuit diagrams in the KPS Updated Safety Analysis Report (USAR), Figures 8.2-2 and 8.2-3. These figures show the 20-kV, 4160-V, 480-V, instrument bus A-C systems, and 125-V and 250-V D-C systems. In addition, KPS USAR Figures 8.2-1, 8.2-2, and 8.2-3 show the basic elements of the 13.8-kV, 138-kV, and 345-kV substation systems.

Normal Power The plant turbine-generator serves as the primary source of auxiliary electrical power during "on-line" operation. The plant turbine-generator voltage output is at 20-kV.

Power is supplied to the auxiliary electrical power system via a 20kV to 4.16-kV, three-winding, main auxiliary transformer (MAT), which is connected to the main leads from the turbine-generator.

The primary sources of electrical power for the auxiliaries associated with engineered safety features during "on-line" operation of the plant are the reserve auxiliary transformer (RAT) and the tertiary auxiliary transformer (TAT).

Power is normally supplied to B train bus (Bus 1-6) through the 138kV to 4.16kV1 three-winding RAT that is connected to the 138kV portion of the KPS Substation. Power is normally supplied to the A train bus (Bus 1-5) through the 13.8kV to 4.16kVJ two-winding TAT that is connected, by an underground line, to the 13.8kV tertiary winding of the 3451138113.8-kV auto transformer in the KPS Substation. Either source can supply either bus.

Auxiliary power required during plant startup, shutdown, and after a reactor trip is supplied from the 13.811381345-kV KPS Substation via the RAT and TAT. After a turbine-generator trip, the auxiliaries on the 4160-V buses being fed by the MAT are transferred by a fast bus transfer scheme using stored energy breakers to the RAT.

The plant batteries supply control power for the plant auxiliary breakers. The high-side (substation) breakers use the substation battery for control power.

The 4160-V system is divided into six buses, as shown in USAR Figure 8.2-2. Buses 1-1 and 1-2 are connected via bus main breakers to the MAT or the RAT. These buses supply power to the reactor coolant pumps and the feedwater pumps.

Serial No. 07-0008 Page 6 of 21 Buses 1-3 and 1-4 are also connected via bus main breakers to the MAT or the RAT.

These buses supply power to the normal balance-of-plant auxiliaries, and each bus supplies power to three 4160 to 480-V station service transformers.

A fourth transformer connected to bus 1-4 supplies power to the Technical Support Center. In addition, the Circulating Water Pumps, Condensate Pumps, and the Heater Drain Pumps are directly connected to buses 1-3 and 1-4.

Buses 1-5 and 1-6 are connected via bus main breakers to the MAT, RAT, or TAT. In addition, each bus is directly fed via a main breaker by an EDG. The two buses are tied together via two bus-tie breakers in series, one on each bus. Each bus supplies two of the four 4160 to 480-V station service transformers for the plant's 480-V ESF equipment. In addition, the service water pumps, auxiliary feedwater pumps, safety injection pumps, and the residual heat removal pumps are directly connected to buses 1-5 and 1-6. The bus-tie breakers between Bus 1-5 and Bus 1-6 can only be manually closed, and are interlocked so that the diesel generators cannot be operated in parallel.

Bus 1-5 is normally supplied from the TAT and Bus 1-6 is normally supplied from the RAT. Thus, no transfer is required for the ESF in the event of an incident unless offsite power is lost which de-energizes both the RAT and TAT.

Emergency Power If the turbine-generator and the offsite power sources should fail, two EDGs are provided: one connected to 4160-V Bus 1-5 (EDG A), and one connected to 4160-V Bus 1-6 (EDG B). Each of these is a General Motors Corporation, Electro-Motive Division, Model A-20-C1, diesel engine generator unit rated at 2600-kW, (2860-kW, 110% Overload, two thousand hours per year) 0.8 pf, 900 rpm, 4160-V, 3 phase, 60 Hertz. The generator has emergency ratings of 2950-kW for seven days continuous and 3050-kW for thirty minutes per year. See Table 1.

I Table 1 Emergency Diesel Generator Load Ratings I Overload, 30 minutes per year

( 3050 kW at 0.8 P.F. 1 1 17.3%

1 Continuous Continuous Overload, 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year Overload, 7 days per year Each EDG, as a backup to the normal standby AC power supply, is capable of sequentially starting and supplying the power requirements of one complete set of engineered safety features equipment. The electrical emergency power system logic diagrams are shown in KPS USAR Figures 8.2-4, 8.2-5, and 8.2-6. The units are 3250 kVA 2600 kW at 0.8 P.F.

2860 kW at 0.8 P.F.

2950 kW at 0.8 P.F.

100.0%

100.0%

11 0.0%

11 3.5%

Serial No. 07-0008 Page 7 of 21 located in separate rooms in the Class I portion of the Administration Building. These rooms are heated, assuring that the EDG can be started in cold weather.

Each EDG is automatically started on the occurrence of either of the following incidents:

a. Undervoltage on the associated 4160-V bus (Bus 1-5 or Bus 1-6) provided that the low voltage is not caused by a fault which operates the bus lockout relay, or

b. Initiation of a safety injection signal, which will start both diesel generators.

Issue for Resolution In May 2006, DEK determined that the EDG de-rating curves, based on inlet combustion air temperature, had been incorrectly applied. This resulted in the potential to operate the EDGs outside of the vendor recommended ratings during the initial EDG loading (from 0 to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> per KPS USAR Table 8.2-1) following a design basis event.

In June of 1992, MKW Power Systems responded by letter (enclosure 1) to a request from a diesel engine owners group concerning diesel engine rating curves. The letter states that the EMD 645 diesel engine ratings are based on 90°F engine intake air temperature. For intake air temperatures greater than 90°F, the engine must be de-rated in accordance with curves that were attached to the letter. The attachment had three curves labeled A, B, and C. Curve A was to be used for the 200-hour and four-hour ratings. Curve B was to be used for the continuous, short-time, and 2000-hour ratings. Curve C was to be used for the 30-minute rating. Use of the curves was further clarified based on engine coolant outlet temperature.

If the engine coolant outlet temperature is not limited to 190°F, the 30-minute rating still used curve C but all other ratings used Curve A. KPS EDG engine coolant outlet temperature is limited to less than 190°F (see Table 2). The de-rating curves are considered to bound acceptable diesel engine operation at intake air temperatures of greater than 90°F. The diesel engine vendor will not guarantee the engine ratings if the engine is not operated in accordance with these curves.

Serial No. 07-0008 Page 8 of 21 Table 2 Diesel Engine De-rating Curves

' )

See Enclosure 1 for diesel engine de-rating curves.

(2)

Electric power output capability that the EDG can maintain in the service environment for 8760 hours0.101 days <br />2.433 hours <br />0.0145 weeks <br />0.00333 months <br /> of operation per year with only scheduled outages for maintenance.

(3)

Electric power output capability that the EDG can maintain in the service environment for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 24-hour period without exceeding the manufacture design limits and without reducing the maintenance interval established for the continuous rating.

(4)

Electric power output capability that the EDG can maintain in the service environment for the specified time interval, after which the EDG would require annual maintenance.

Continuous (')

Short-time (3)

During a review of this information in May 2006, it appears that KPS personnel used Curve B to determine the de-rating of the diesel engine and did not consider the difference between outside air temperature and air temperature at the diesel engine intake. This difference between outside air temperature and the air temperature at the diesel engine intake is developed because diesel intake air comes from inside the diesel engine room, which the diesel engine heats when running. The outside air is supplied to the room to make up for the combustion air with additional outside air supplied for room cooling.

Calculations have shown that the difference between outside air temperature and diesel engine room air temperature is approximately 15°F to 20°F during the summer months. The temperature difference will vary because various factors such as diesel load, room ventilation configuration, and outside air temperature cause the temperature difference to change.

Applicable Curve ('I Engine Rating A review of previous evaluations regarding loading of the EDGs identified incorrect assumptions made regarding de-rating of the EDGs due to elevated combustion air intake temperatures. On three occasions, incorrect assumptions were made that the EDGs would not require de-rating when outside air temperatures resulted in increased combustion air intake temperatures.

Applicable Curve (')

Engine Coolant 5 190°F B

B The cause of the incorrect assumptions regarding de-rating of the EDGs due to elevated combustion air intake temperature included errors in:

Engine Coolant > 190°F A

A The relationship between EDG combustion air intake temperature and the outside air temperature, and Application of the de-rating curves.

Serial No. 07-0008 Page 9 of 21 The assumption that the combustion air intake temperature will essentially be the same as the outside air temperature is incorrect due to the design of the EDG room ventilation and combustion air intake system. The EDG room ventilation system consists of an outside air supply that is ducted to the respective EDG room and mixed with air within the room before reaching the actual combustion air intake.

During steady state operation of the EDG, room air is heated primarily by the hot exposed surfaces of the EDG. This assumption resulted in use of a combustion air intake temperature that was non-conservative.

The second incorrect assumption was that, since the EDG coolant water outlet temperature is maintained below 1 90°F, using the 'B' de-rating curve under all accident-loading conditions was appropriate. This is contrary to the guidance found on page 2 of the letter that included the de-rating curves (enclosure 1).

Page 2 states that for operation where engine coolant outlet temperature is limited to 190°F, curve 'A' shall be used for the 200-hour and 4-hour ratings. Curve 'B' allows combustion air temperature to be as high as 115°F before de-rating would be required, however, the maximum load associated with this curve is 2860 kW for 2000-hours. Since the worst case loading for the EDGs at KPS would require operation above 2860 kW but within the requirements of the 200-hour or 4-hour ratings, curve 'A' should have been used. Curve 'A' requires de-rating when the combustion air temperature exceeds 90°F.

Technical Specification History On November 16, 1979, KPS submitted a proposed amendment (reference 2) to add a monthly test for the EDGs, which meets the intent of IEEE 387-1977, paragraph 6.4.3 (KPS TS 4.5.a.l). This proposed change was also included in a proposed amendment submitted on January 28, 1981 (reference 3).

The NRC approved the proposed amendment as a part of Facility Operating License DPR-43 Amendment No. 33, by letter dated April 8, 1981 (reference 4).

On April 15, 1986, a proposed amendment to KPS TS was submitted to modify the rated load test surveillance requirement to split the continuous rating 1-hour load test and the short-time 2-hour load test (reference 5). The amendment proposed removal of the short-time rated load test from TS 4.6.a.l and addition of a new SR TS 4.6.a.5 for the short-time rating test. The SR interval for loading the KPS EDGs to their short-term rating for 2-hour (short-term rated load test) was changed from monthly to every operating cycle. In this amendment request, the short-term (short-time) load rating was stated as 2950 kW. The 2950 kW value was chosen because this was the highest load the EDG could operate at for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> without a reduction in the maintenance interval.

On July 10, 1986, the NRC approved the proposed amendment submitted on April 15, 1986, as Amendment No. 68 to Facility Operating License No. DPR-43 (reference 6).

The NRC safety evaluation states:

"The effect of the changes would be to apply the continuous rating load test on a monthly cycle and a short-term rating load test on a refueling cycle basis. We find that these changes are consistent with Paragraph

Serial No. 07-0008 Page 10 of 21 6.6.1 of IEEE Std. 387-1977, which requires monthly tests at the lower continuous rating, and Paragraph 6.6.2 of I Std. 387-1977, which requires less frequent tests at the higher short-term rating. We also find that the proposed testing frequencies are consistent with Regulatory Guide 1.108. "

KPS TS 4.6.a.5 is currently worded as approved by the NRC in reference 6.

DEK has reviewed the guidance provided in IEEE 387-1977 and Regulatory Guide 1.9 (Regulatory Guide 1.9 replaced Regulatory Guide 1.I 08, which was withdrawn in 1993 (reference 9)) and determined the load specified for the short-term test is greater than that described in these documents.

IEEE 387-1 977 defines short time rating as:

"The electric power output capability that the diesel-generator unit can maintain in the service environment for 2 h in any 24-h period, without exceeding the manufactures design limit and without reducing the maintenance interval established for the continuous rating. "

Regulatory Guide 1.9 (reference 8) defines an endurance and margin test (Paragraph 2.2.9) as:

"Demonstrate full-load carrying capability at a power factor between 0.8 and 0.9 for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are at a load equal to 105 to 1 10 percent of the continuous rating of the emergency diesel generator, and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> are at a load equal to 90 to 100 percent of its continuous rating.

Verify that voltage and frequency requirements are maintained. "

Regulatory Guide 1.9, Paragraph 2.3.2.3, "Refueling Outage Testing," states that overall emergency diesel generator unit design capability should be demonstrated at every refueling outage by performing the tests listed in Regulatory Guide 1.9, Table 1.

Regulatory Guide 1.9, Table 1, "Preoperational and Surveillance Testing," lists the endurance and margin test surveillance as to be performed in the preoperational test program and during refueling outages.

As previously shown in Table 1, the current short-term load test requirement of 2950 kW for the KPS EDGs is 113.5% of the continuous load rating. The load equivalent to 11 0% of the continuous load rating is the 2000-hour load rating of 2860 kW. Thus, this proposed amendment request is to modify the short-term load listed in TS 4.6.a.5 to 105% to 11 0% of the continuous load rating or 2 2730 kW and I 2860 kW, as stated in Regulatory Guide 1.9.

Serial No. 07-0008 Page 1 1 of 21 Comparison to NUREG 1431 (Improved Technical Specifications)

KPS TS 4.6.a.5 relates to NUREG 1431, "Standard Technical Specifications -

Westinghouse Plants," Specification 3.8, "Electrical Power Systems," Limiting Condition for Operation (LCO) 3.8.1, "AC Sources - Operating," item SR 3.8.1.14. Surveillance requirement (SR) 3.8.1.I 4 states:

Surveillance I.

Momentary transients outside the load and power factor ranges do not invalidate this test.

2. This Surveillance shall not normally be performed in MODE 1 or 2. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this SR

3. If performed with DG synchronized with offsite power, it shall be performed at a power factor I

[0.9]. However, if grid conditions do not permit, the power factor limit is not required to be met.

Under this condition the power factor shall be maintained as close to the limit as practicable.

Verify each DG operates for 2 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s:

a. For 2 [2] hours loaded 2 [5250] kW and 5

[5500] kW and

b. For the remaining hours of the test loaded r

[4500] kW and 5 [5000] kW.

The bases for SR 3.8.1.I 4 states

[I 81 months "Regulatory Guide 1.108 (Ref. 9), paragraph 2.a. (3), requires demonstration once per 18 months that the DGs can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, 1 [2] hours of which is at a load equivalent to 110% of the continuous duty rating and the remainder of the time at a load equivalent to the continuous duty rating of the DG. The DG starts for this Surveillance can be performed either from standby or hot conditions. The

Serial No. 07-0008 Page 12 of 21 provisions for prelubricating and warmup, discussed in SR 3.8.1.2, and for gradual loading, discussed in SR 3.8.1.3, are applicable to this SR.

The load band is provided to avoid routine overloading of the DG. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain DG OPERABILITY.

The [I8 month] Frequency is consistent with the recommendations of Regulatory Guide 1.108 (Ref. 9), paragraph Z.a.(3), takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

This Surveillance is modified by three Notes. Note 1 states that momentary transients due to changing bus loads do not invalidate this test.

Similarly, momentary power factor transients above the power factor operation will not invalidate this test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in MODE 1 or 2 is further amplified to allow the Surveillance to be performed for the purpose of reestablishing OPERABILITY (e.g., post work testing following corrective maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in MODE 1 or 2. Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this SR.

Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible.

When synchronized with offsite power, testing should be performed at a power factor of 5 [0.9]. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions.

Under certain conditions, however, Note 3 allows the Surveillance to be conducted as a power factor other than 5 [0.9].

These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to 5 10.91 results in voltages on the emergency busses that are too high. Under these conditions, the power factor should be maintained as close as practicable to [0.9] while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of

[0.9] may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the DG. In such cases,

Serial No. 07-0008 Page 1 3 of 21 the power factor shall be maintained close as practicable to 10.91 without exceeding the DG excitation limits. "

This proposed change models the NUREG 1431 SR 3.8.1.14 as closely as possible.

The model SR in NUREG 1431 uses the example of a diesel generator that has a continuous load rating of 5000 kW.

Based on a 5000 kW diesel generator, SR 3.8.1.14(a) loading for 105% to 110% would be 5250 and 5500, thus these are the bracketed numbers. The continuous load rating of the KPS EDGs is 2600 kW. Thus, for KPS, the appropriate loads corresponding to 105% and 110% of continuous load rating is 2730 kW and 2860 kW. The 2-hour run bracketed in NUREG 1431 SR, is used in the KPS TS. This 2-hour period is not a change from the current KPS TS and is consistent with IEEE 387-1 977 and Regulatory Guide 1.9.

NUREG 1431 Surveillance Requirement 3.8.1.1 4(b) is also being added to the KPS TS as TS 4.6.a.5.B. Although not listed in IEEE 387-1977 as a recommended site test, only as a type qualification test (IEEE 387-1977, paragraph 6.3.1), Regulatory Guide 1.9, paragraph 2.2.9 recommends this test be performed on a refueling cycle basis per paragraph 2.3.2.3.

4.0 TECHNICAL ANALYSIS

The purpose of this proposed amendment is to resolve an inconsistency between KPS TS 4.6.a.5 and IEEE 387-1977. The inconsistency is resolved by changing the load at which the test required by TS 4.6.a.5 is performed to the band recommended in Regulatory Guide 1.9 for the endurance and margin test.

IEEE 387-1 977 defines a short-term rating as the electric output capacity that the diesel generator unit can maintain in the service environment for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> in any 24-hour period, without exceeding the manufacturer's design limits and without reducing the maintenance interval established for the continuous rating. The KPS staff initially established this load as 2950 kW. Subsequently, the KPS staff has determined that operating the diesel engine at this load when outside air temperatures are greater than 75°F would reduce the maintenance interval established for the continuous rating. In addition, the de-rate curves for the KPS EDGs do not support EDG operability when outside air temperatures are greater than approximately 75"F, and therefore, there is no guarantee from the vendor that the diesel engine would operate for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at 2950 kW at these temperatures.

A calculation performed by KPS staff has shown that the EDGs can be loaded to 2864 kW with an outside air temperature of 97.8OF without requiring de-rate. A review of the outside air temperature near the site for the past three years has determined that the outside air temperature has not reached 97.8"F. Therefore, reducing the maximum load required by TS 4.6.a.5 from 2950 kW to 2860 kW would provide reasonable assurance that there will not be a failure to meet this surveillance requirement between performances of the surveillance. Additionally, facility modifications are in progress to

Serial No. 07-0008 Page 14 of 21 increase margin to the vendors engine rating at elevated temperatures curves (enclosure 1).

Changing the short-term load requirement of TS 4.6.a.5 between 105% to 1 10% of the continuous load rating of the KPS EDGs (2730 to 2860 kW) is consistent with the guidance provided in IEEE 387-1 977 and Regulatory Guide 1.9.

A summary of the proposed changes and the reason each change is acceptable is provided below:

1. Increase the run time of the test from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to greater than or equal to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of which at least 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> are at the short-time rating.

This change meets the intent of IEEE 387-1977, item 3.7.2, "Short Time Rating," and item 6.4.3(2). Additionally this change aligns the KPS TS with Regulatory Guide 1.9, item 2.2.9, "Endurance and Margin Test," and NUREG 1431, SR 3.8.1.14.

2. Reduce the loading requirement for the 2-hour portion of the 24-hour test from 2950 kW to a load band between 2730 kW and 2860 kW.

This change meets the intent of IEEE 387-1977, item 3.7.2, "Short Time Rating," and item 6.4.3(2). Additionally, this change aligns the KPS TS with Regulatory Guide 1.9, item 2.2.9, "Endurance and Margin Test," and NUREG 1431, SR 3.8.1.14.

3. Add a new requirement to run the EDG for the remainder of the 24-hour test within a load band between 2340 kW and 2600 kW.

This change aligns the KPS TS with Regulatory Guide 1.9, item 2.2.9, "Endurance and Margin Test," and NUREG 1431, SR 3.8.1.I

4.

4. Add a new Note 1 to allow momentary transients outside the prescribed loading limits without invalidating the test.

This change aligns the KPS TS with NUREG 1431, SR 3.8.1.14.

5. Add a new Note 2 to provide restrictions and contingencies on the plant mode at which the test can be performed.

This change aligns the KPS TS with NUREG 1431, SR 3.8.1.1 4.

6. Add a new Note 3 to state the power factor restriction for the test and an allowance for when the restriction can be relaxed.

This change aligns the KPS TS with NUREG 1431, SR 3.8.1. I 4.

Serial No. 07-0008 Page 15 of 21 5.0 REGULATORY SAFETY ANALYSIS 5.1 No Sianificant Hazards Consideration Dominion Energy Kewaunee, Inc. (DEK) is submitting a proposed amendment to the Kewaunee Power Station (KPS) technical specifications (TS) to change the specification for short-time testing of the emergency diesel generators (EDGs).

The proposed amendment would revise KPS TS 4.6.a.5 by reducing the short-time EDG loading requirement from 2950 kW to a load band between 2730 kW and 2860 kW. The proposed amendment would also incorporate two applicable technical specification task force (TSTF) items, TS TSTF-276-A, Revision 2 and TSTF-283-A, Revision 3.

The amendment proposes changes which are consistent with ANSIIIEEE 387-1977, "IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations," and NRC Regulatory Guide 1.9, "Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used As Class 1 E Onsite Electric Power Systems at Nuclear Power Plants," Revision 3, 1993, paragraph 2.2.9, "Endurance and Margin Test."

DEK has evaluated whether or not a significant hazards consideration is involved with the proposed amendment by focusing on the three standards set forth in 10 CFR 50.92, "Issuance of amendment," as discussed below:

1. Does the proposed amendment involve a significant increase in the probability or consequences of an accident previously evaluated?

No.

The proposed changes do not affect any of the previously evaluated accidents in the Updated Safety Analysis Report (USAR). The proposed change is to make the EDG test specified by TS 4.6.a.5 (referred to as the short-time or short-term test) consistent with IEEE 387-1977, Regulatory Guide 1.9-1993, and NUREG 1431, Revision 3.1.

The proposed amendment increases the total EDG test run time from 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> to 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> and decreases the maximum load value for the 2-hour portion of the test from 11 3.7% of continuous duty (2950 kW) to 11 0% of continuous duty (2860 kW).

The proposed amendment also adds a specification to run the EDG loaded to a maximum of it's continuous duty load (2600 kW) for the remainder of the 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The KPS (EDGs) are designed to supply electrical power to engineered safety features (ESF) electrical busses in the event of a loss of normal power sources to these busses.

The ESFs are designed to mitigate the consequences of an accident. The EDGs are not an accident initiator, and thus the proposed changes do not affect the probability of an accident previously evaluated in the USAR. The purpose of the EDGs is to supply reliable power at rated voltage and frequency to ESF equipment that is used

Serial No. 07-0008 Page 16 of 21 to mitigate the consequences of an accident. The proposed amendment modifies one of the EDG surveillances to make it consistent with IEEE 387-1977, Regulatory Guide 1.9-1 993, and NUREG 1431, Rev 3.1. The change does not reduce the reliability of the EDGs because the modified testing requirements will continue to assure their necessary quality and demonstrate that the EDGs are capable of performing their intended safety function. The EDG will continue to supply reliable power to the ESF equipment as required by the USAR accident analysis. Because the EDG will continue to supply the ESF power requirements and the change does not reduce the reliability of the EDGs, there is not a significant increase in the consequences of an accident previously evaluated Therefore, the proposed amendment does not involve a significant increase in the probability or consequences of an accident previously evaluated.

2. Does the proposed amendment create the possibility of a new or different kind of accident from any accident previously evaluated?

No.

The proposed amendment does not change the design function or operation of the EDGs. The proposed amendment would not change the methods of starting, loading, or monitoring the EDGs during testing in a manner that could create the possibility of a new or different kind of accident than previously evaluated. The proposed amendment would alter the run time for the EDG's when tested and the load at which the EDG's are tested.

However, no new equipment is being added or changed as a result of the proposed amendment.

Therefore, the proposed amendment does not create the possibility of a new or different kind of accident from any previously evaluated.

3. Does the proposed amendment involve a significant reduction in a margin of safety?

No.

The proposed amendment does not change the EDG output characteristics.

The EDG will remain capable of supplying the output necessary to meet post-accident loading requirements. The proposed amendment would change the length of the surveillance test and the load on the EDGs during the test.

However, these changes are consistent with accepted industry standards contained in IEEE 387-1 977, Regulatory Guide 1.9-1 993, and NUREG 1431.

Therefore, the proposed amendment does not involve a significant reduction in a margin of safety.

Serial No. 07-0008 Page 17 of 21 Based on the above, DEK concludes that the proposed amendment presents no significant hazards consideration under the standards set forth in 10 CFR 50.92(c), and, accordingly, a finding of "no significant hazards consideration" is justified.

5.2 A~~licable Reaulatorv Reauirementslcriteria The US Atomic Energy Commission (AEC) issued their Safety Evaluation (SE) of the KPS on July 24, 1972 with supplements dated December 18, 1972 and May 10, 1973.

The AEC's SE, section 3.1, "Conformance with AEC General Design Criteria," describes the conclusions the AEC reached associated with the General Design Criteria in effect at the time. The AEC stated:

"The Kewaunee plant was designed and constructed to meet the intent of the AEC's General Design Criteria, as originally proposed in July 1967.

Construction of the plant was about 50% complete and the Final Safety Analysis Report (Amendment No. 7) had been filed with the Commission before publication of the revised General Design Criteria in February 1971 and the present version of the criteria in July 1971. As a result, we did not require the applicant to reanalyze the plant or resubmit the FSAR. However, our technical review did assess the plant against the General Design Criteria now in effect and we are satisfied that the plant design generally conforms to the intent of these criteria."

As such, the appropriate General Design Criteria, from the Final Safety Analysis (Amendment 7), as updated and included in the KPS USAR, are shown below.

Criterion 2 - Performance Standards Those systems and components of reactor facilities which are essential to the prevention of accidents which could affect the public health and safety or to mitigation of their consequences shall be designed, fabricated and erected to performance standards that will enable the facility to withstand without loss of the capability to protect the public.

The additional forces that might be imposed by natural phenomena such as earthquakes, tornadoes, flooding conditions, winds, ice and other local site effects. The design bases so established shall reflect:

a. appropriate consideration of the most severe of these natural phenomena that have been recorded for the site and the surrounding area, and

b. an appropriate margin for withstanding forces greater than those recorded to reflect uncertainties about the historical data and their suitability as a basis for design.

Evaluation All electrical systems and components vital to plant safety, including the diesel generators are designed to Class I standards so that their integrity is not impaired by

Serial No. 07-0008 Page 18 of 21 the Design Basis Earthquake, wind storms, floods, or disturbances on the external electrical system. Power, control and instrument cabling, motors and other electrical equipment required for operation of the ESF are suitably protected against the effects of either a nuclear system accident or of severe external environmental phenomena in order to assure a high degree of confidence in the operability of such components in the event that their use is required.

Criterion 24 - Emeraencv Power For Protection Svstems In the event of loss of all off-site power, sufficient alternate sources of power shall be provided to permit the required functioning of the protection systems.

Evaluation The facility is supplied with normal, reserve and emergency power to provide for the required functioning of the protection systems.

In the event of a reactor and turbine trip, two diesel generators, as described in KPS USAR Section 8, are available to supply emergency power. Any one diesel generator is capable of supplying the emergency power requirements of the plant.

The instrumentation and controls portions of the protection systems are supplied from the 125-V station batteries during the diesel generator startup period, as detailed in KPS USAR Section 8.

Criterion 39 - Emeraencv Power For Enaineered Safetv Features Alternate power systems shall be provided and designed with adequate independency, redundancy, capacity, and testability to permit the functioning required of the engineered safety features. As a minimum, the on-site power system and the off-site power system shall each, independently, provide this capacity assuming a failure of a single active component in each power system.

Evaluation The above Criterion 39, as with others cited throughout this license application as a basis for design, is as suggested by AIF in its October 2, 1967 comments on the then-proposed AEC Criteria. As noted in KPS USAR Section 1.8 the design also meets the KPS staff's understanding of the intent of the Criteria as originally proposed by AEC in July 1967. In the case of Criterion 39, where a difference existed, the more stringent AEC criterion was followed. As a result, in our opinion the emergency power systems as designed also meet the intent of the General Design Criterion 17 adopted February 20, 1971, as amended July 7, 1971, the text of which follows.

Serial No. 07-0008 Page 19 of 21 Criterion 17--Electric Power Svstems.

An onsite electric power system and an offsite electric power system shall be provided to permit functioning of structures, systems, and components important to safety. The safety function for each system (assuming the other system is not functioning) shall be to provide sufficient capacity and capability to assure that:

(1) specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded as a result of anticipated operational occurrences, and (2) the core is cooled and containment integrity and other vital functions are maintained in the event of postulated accidents.

The onsite electric power supplies, including the batteries, and the onsite electric distribution system, shall have sufficient independence, redundancy, and testability to perform their safety functions assuming a single failure.

Electric power from the transmission network to the onsite electric distribution system shall be supplied by two physically independent circuits (not necessarily on separate rights-of-way) designed and located so as to minimize to the extent practical the likelihood of their simultaneous failure under operating and postulated accident and environmental conditions. A switchyard common to both circuits is acceptable. Each of these circuits shall be designed to be available in sufficient time following a loss of all onsite alternating current power supplies and the other offsite electric power circuit, to assure that specified acceptable fuel design limits and design conditions of the reactor coolant pressure boundary are not exceeded. One of these circuits shall be designed to be available within a few seconds following a loss-of-coolant accident to assure that core cooling, containment integrity, and other vital safety functions are maintained.

Provisions shall be included to minimize the probability of losing electric power from any of the remaining supplies as a result of, or coincident with, the loss of power generated by the nuclear power unit, the loss of power from the transmission network, or the loss of power from the onsite electric power supplies.

Independent alternate power systems are provided with adequate capacity and testability to supply the required ESF and protection systems.

The plant is supplied with normal, standby and emergency power sources as follows:

a. The main source of auxiliary power during plant operation is the plant's generator.

Power is supplied via the Main Auxiliary Transformer, which is connected to the main leads of the generator.

b. Standby power required during startup, shutdown and after reactor trip is supplied from the American Transmission Company's 138-kV and 345-kV transmission systems.

The Reserve Auxiliary and Tertiary Auxiliary

Serial No. 07-0008 Page 20 of 21 Transformers can both be powered from either transmission system through the interconnecting auto transformer.

Two diesel generators are connected to the engineered safety features buses to supply emergency shutdown power in the event of loss of all other AC auxiliary power.

Emergency power for vital instruments and for control is supplied from two safeguard 125-V DC station batteries and two non-safeguard 125-V DC station batteries. Emergency power for selected turbine and generator backup pumps is supplied from a non-safeguard 250-V DC station battery.

The diesel generators are located in the Class I section of the administration building and are connected to separate 4160-V auxiliary system buses. Each diesel generator will be started automatically on a safety injection signal or upon the occurrence of undervoltage on either of its corresponding 4160-V auxiliary buses.

Each diesel generator has adequate capacity to supply one set of the ESF for the design basis accident.

In conclusion, based on the considerations discussed above, (1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed manner, (2) such activities will be conducted in compliance with the Commission's regulations, and (3) the issuance of the amendment will not be inimical to the common defense and security or to the health and safety of the public.

6.0 ENVIRONMENTAL CONSIDERATION

A review has determined that the proposed amendment would change a requirement with respect to installation or use of a facility component located within the restricted area, as defined in 10 CFR 20, or would change an inspection or surveillance requirement. However, the proposed amendment does not involve (i) a significant hazards consideration, (ii) a significant change in the types or significant increase in the amounts of any effluent that may be released offsite, or (iii) a significant increase in individual or cumulative occupational radiation exposure. Accordingly, the proposed amendment meets the eligibility criterion for categorical exclusion set forth in 10 CFR 51.22(~)(9). Therefore, pursuant to 10 CFR 51.22(b), no environmental impact statement or environmental assessment need be prepared in connection with the proposed amendment.

Serial No. 07-0008 Page 21 of 21

7.0 REFERENCES

(1) ANSIIIEEE Std. 387-1 977, "IEEE Standard Criteria for Diesel-Generator Units Applied as Standby Power Supplies for Nuclear Power Generating Stations."

(2) Letter from E.R. Mathews (WPSC) to Office of Nuclear Reactor Regulation (NRC), "Proposed Technical Specification Amendment No. 41," dated November 16,1979.

(3) Letter from E.R. Mathews (WPSC) to Steven A. Varga (NRC), "Degraded Grid Voltage Protection Technical Specification," dated January 28, 1981.

(4) Letter from Steven A. Varga (NRC) to E.R. Mathews (WPSC), "Amendment No.

33 to Facility Operating License No. DPR-43," dated April 8, 1981.

(5) Letter from Carl W. Giesler (WPSC) to Harold R. Denton (NRC), "Proposed Amendment No. 74 to the KNPP Technical Specification - Diesel Generator Surveillance Testing," dated April 1 5, 1986.

(6) Letter from Morton 6. Fairtile (NRC) to D.C. Hintz (WPSC), "Amendment No. 68 to Facility Operating License No. DPR-43," dated April 8, 1 981.

(7) Letter from David A. Strickland (MKW) to Mike Anthony (Duke Engineering and Services), dated June 1 1, 1992.

(8) NRC Regulatory Guide 1.9, "Selection, Design, Qualification, and Testing of Emergency Diesel Generator Units Used As Class 1 E Onsite Electric Power Systems at Nuclear Power Plants, Revision 3, 1993."

(9) Federal Register Notice, "Regulatory Guide Withdrawal," Volume 58, Number 149, page 41 81 3, dated August 5,1993.

(1 0) NUREG 1431, "Standard Technical Specifications Westinghouse Plants."

(1 1) Letter from Leslie N. Hartz (DEK) to Document Control Desk (NRC), "Licensee Event Report 2006-004-01

,I1 dated December 28, 2006.

ATTACHMENT 2 LICENSE AMENDMENT 230 EMERGENCY DIESEL GENERATOR SHORT-TIME LOAD TESTING KEWAUNEE POWER STATION MARKED-UP TS PAGES:

DOMINION ENERGY KEWAUNEE, INC.

4.6 PERIODIC TESTING OF EMERGENCY POWER SYSTEM Applies to periodic testing and surveillance requirements of the emergency power system.

To verify that the emergency power sources and equipment are OPERABLE.

The following tests and surveillance shall be performed:

a. Diesel Generators

1. Manually-initiated start of each diesel generator, and assumption of load by the diesel generator.

This test shall be conducted monthly, loading the diesel generator to at least 2600 KW (nominal) for a period of at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

2. Automatic start of each diesel generator, load shedding, and restoration to operation of particular vital equipment, all initiated by a simulated loss of all normal a-c station service power supplies together with a simulated safety injection signal.

This test will be conducted at each REFUELING interval to assure that each diesel generator will start and assume required loads to the extent possible within 1 minute, and operate for 2 5 minutes while loaded with the emergency loads.

3. Each diesel generator shall be inspected at each major REFUELING outage.

4. Diesel generator load rejection test in accordance with IEEE 387-1977, Section 6.4.5, shall be performed at least once per 18 months.

LAR 230

5. S E a c h diesel generator shall be q x a k c L V I -

fnr >

7 This.-all nnt nnrmallv he &nr&

in thn OPFRATING nr HOT STANDRY MODF Hnwevw this Ehmahmx may he tn ree.wlish OPFRARll ITY n r

w an as.%ssmmj rml-v nf thn rrlant IS a

n h

w mav hF! fnr n r

f y

ths !smdhme rnmerlt.

R Fnr the r m l n n h n l r r s nf t w

> 734n Kw and <

6. Safeguard bus undervoltage and safeguard bus second level undervoltage relays shall be calibrated at least once per operating cycle.

b. Station Batteries The voltage of each cell shall be measured to the nearest hundredth volt each month. An equalizing charge shall be applied if the lowest cell in the battery falls c 2.13 volts. The temperature and specific gravity of a pilot cell in each battery shall be measured.

The following additional measurements shall be made quarterly: the specific gravity and height of electrolyte in every cell and the temperature of every fifth cell.

All measurements shall be recorded and compared with previous data to detect signs of deterioration.

The batteries shall be subjected to a load test during the first REFUELING and once every 5 years thereafter. Battery voltage shall be monitored as a function of time to establish that the battery performs as expected during heavy discharge and that all electrical connections are tight.

LAR 230

ATTACHMENT 3 LICENSE AMENDMENT 230 EMERGENCY DIESEL GENERATOR SHORT-TIME LOAD TESTING KEWAUNEE POWER STATION AFFECTED TS PAGES DOMINION ENERGY KEWAUNEE, INC.

4.6 PERIODIC TESTING OF EMERGENCY POWER SYSTEM Applies to periodic testing and surveillance requirements of the emergency power system.

QEEcIu To verify that the emergency power sources and equipment are OPERABLE.

The following tests and surveillance shall be performed:

a. Diesel Generators

1. Manually-initiated start of each diesel generator, and assumption of load by the diesel generator.

This test shall be conducted monthly, loading the diesel generator to at least 2600 KW (nominal) for a period of at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br />.

2. Automatic start of each diesel generator, load shedding, and restoration to operation of particular vital equipment, all initiated by a simulated loss of all normal a-c station service power supplies together with a simulated safety injection signal.

This test will be conducted at each REFUELING interval to assure that each diesel generator will start and assume required loads to the extent possible within 1 minute, and operate for 5 minutes while loaded with the emergency loads.

3. Each diesel generator shall be inspected at each major REFUELING outage.

4. Diesel generator load rejection test in accordance with IEEE 387-1977, Section 6.4.5, shall be performed at least once per 18 months.

5. Each diesel generator shall be operated for 2 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> every operating cycle:

Note 1 Note 2 Note 3 Momentary transients outside the load and power factor ranges do not invalidate this test.

This Surveillance shall not normally be performed in the OPERATING or HOT STANDBY MODE. However, this Surveillance may be performed to reestablish OPERABILITY provided an assessment determines the safety of the plant is maintained or enhanced. Credit may be taken for unplanned events that satisfy this surveillance requirement.

If performed with the diesel generator synchronized with offsite power, it shall be performed at a power factor S0.9. However, if grid conditions do not permit, the power factor limit is not required to be met. Under this condition the power factor shall be maintained as close to the limit as practicable.

A. For 2 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> loaded 2 2730 KW and 5 2860 KW, and B. For the remaining hours of the test loaded 2 2340 KW and 2600 KW.

6. Safeguard bus undervoltage and safeguard bus second level undervoltage relays shall be calibrated at least once per operating cycle.

b. Station Batteries The voltage of each cell shall be measured to the nearest hundredth volt each month. An equalizing charge shall be applied if the lowest cell in the battery falls

< 2.13 volts. The temperature and specific gravity of a pilot cell in each battery shall be measured.

The following additional measurements shall be made quarterly: the specific gravity and height of electrolyte in every cell and the temperature of every fifth cell.

All measurements shall be recorded and compared with previous data to detect signs of deterioration.

The batteries shall be subjected to a load test during the first REFUELING and once every 5 years thereafter. Battery voltage shall be monitored as a function of time to establish that the battery performs as expected during heavy discharge and that all electrical connections are tight.

ATTACHMENT 4 LICENSE AMENDMENT 230 EMERGENCY DIESEL GENERATOR SHORT-TIME LOAD TESTING KEWAUNEE POWER STATION MARKED-UP TS BASES PAGES:

DOMINION ENERGY KEWAUNEE, INC.

Inspections are performed at REFUELING outage intervals in order to maintain the diesel generators in accordance with the manufacturers' recommendations. The inspection procedure is periodically updated to reflect experience gained from past inspections and new information as it is available from the manufacturer.

th I nad Flqedton Test, TS 4. M The load rejection test demonstrates the capability of rejecting the maximum rated load without overspeeding or attaining voltages which would cause the diesel generator to trip, mechanical damage, or harmful overstresses.

Cycle Short-Term I nad Test, TS 4.6&

Loading the diesel generators to their short-term rating will demonstrate their capability to provide a continuous source of emergency AC power during a load perturbation of up to 1 I@?% of the I diesel generator's continuous rating.

I The I tn avnid r m e n v e r l m f thn -atnr RnlntnrtinF!

r n

n 1

n P

v e

h r tn d~esel -r OPFRARll ITY Thn "nnm ner onc?r;ltinncIe" f

f r

v h

the r

~

?

1 9.

7 3 3

n lntnmit m n

s r

m LAR 230 TS B4.6-2

F Risk I-s nr this Station batteries will deteriorate with time, but precipitous failure is extremely unlikely. The surveillance specified is that which has been demonstrated over the years to provide indication of a cell becoming unserviceable long before it fails.

If a battery cell has deteriorated, or if a connection is loose, the voltage under load will drop excessively, indicating need for replacement or maintenance.

LAR 230

ATTACHMENT 5 LICENSE AMENDMENT 230 EMERGENCY DIESEL GENERATOR SHORT-TIME LOAD TESTING KEWAUNEE POWER STATION AFFECTED TS BASES PAGES:

DOMINION ENERGY KEWAUNEE, INC.

Inspections are performed at REFUELING outage intervals in order to maintain the diesel generators in accordance with the manufacturers' recommendations. The inspection procedure is periodically updated to reflect experience gained from past inspections and new information as it is available from the manufacturer.

18-rQ~nth I Test: TS 4.6&

The load rejection test demonstrates the capability of rejecting the maximum rated load without overspeeding or attaining voltages which would cause the diesel generator to trip, mechanical damage, or harmful overstresses.

Cycle Short-Term I nad Test, TS 4.6&

Loading the diesel generators to their short-term rating will demonstrate their capability to provide a continuous source of emergency AC power during a load perturbation of up to 110% of the I diesel generator's continuous rating.

I IEEE 387-1977 paragraph 3.7.2, defines a diesel generators short time rating. Paragraph 6.4.3 defines the rated load test for diesel generators, item 2 states to load the diesel generator to the short time rating for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />. Paragraph 6.6.2 describes the operational testing to be performed for the diesel generators. Although the rated load test is not listed in paragraph 6.6.2, item 2 of paragraph 6.4.3 has been determined to be necessary to be performed on the emergency diesel generators.

Regulatory Guide 1.9, paragraph 2.3.2.3, and 2.2.9 requires demonstration at every refueling outage that the diesel generators can start and run continuously at full load capability for an interval of not less than 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, r 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of which is at a load equivalent to 105% to 11 0% of the continuous duty rating and the remainder of the time at a load equivalent to 90% to 100% of the continuous duty rating of the diesel generator. The diesel generator starts for this Surveillance can be performed either from standby or hot conditions. The provisions for prelubricating, warmup, and for gradual loading are applicable to this surveillance requirement.

The load band is provided to avoid routine overloading of the diesel generator. Routine overloading may result in more frequent teardown inspections in accordance with vendor recommendations in order to maintain diesel generator OPERABILITY.

The "once per operating cycle" frequency is consistent with the recommendations of Regulatory Guide 1.9, paragraph 2.3.2.3, takes into consideration unit conditions required to perform the Surveillance, and is intended to be consistent with expected fuel cycle lengths.

Three notes modify this Surveillance. Note 1 states that momentary transients due to changing busloads do not invalidate this test. Similarly, momentary power factor transients above the power factor operation will not invalidate the test. The reason for Note 2 is that during operation with the reactor critical, performance of this Surveillance could cause perturbations to the electrical distribution systems that could challenge continued steady state operation and, as a result, unit safety systems. This restriction from normally performing the Surveillance in the OPERATING or HOT STANDBY MODE is further amplified to allow the Surveillance to be performed for reestablishing OPERABILITY (e.g., post work testing following corrective

maintenance, corrective modification, deficient or incomplete surveillance testing, and other unanticipated OPERABILITY concerns) provided an assessment determines plant safety is maintained or enhanced. This assessment shall, as a minimum, consider the potential outcomes and transients associated with a failed Surveillance, a successful Surveillance, and a perturbation of the offsite or onsite system when they are tied together or operated independently for the Surveillance; as well as the operator procedures available to cope with these outcomes. These shall be measured against the avoided risk of a plant shutdown and startup to determine that plant safety is maintained or enhanced when the Surveillance is performed in the OPERATING or HOT STANDBY MODE. Risk insights or deterministic methods may be used for this assessment. Credit may be taken for unplanned events that satisfy this surveillance requirement.

Note 3 ensures that the DG is tested under load conditions that are as close to design basis conditions as possible. When synchronized with offsite power, testing should be performed at a power factor of 5 0.9. This power factor is representative of the actual inductive loading a DG would see under design basis accident conditions. Under certain conditions, however, Note 3 allows the Surveillance to be conducted as a power factor other than 5 0.9. These conditions occur when grid voltage is high, and the additional field excitation needed to get the power factor to 5 0.9 results in voltages on the emergency busses that are too high. Under these conditions, the power factor should be maintained as close as practicable to 0.9 while still maintaining acceptable voltage limits on the emergency busses. In other circumstances, the grid voltage may be such that the DG excitation levels needed to obtain a power factor of 0.9 may not cause unacceptable voltages on the emergency busses, but the excitation levels are in excess of those recommended for the diesel generator. In such cases, the power factor shall be maintained close as practicable to 0.9 without exceeding the diesel generator excitation limits.

Station batteries will deteriorate with time, but precipitous failure is extremely unlikely. The surveillance specified is that which has been demonstrated over the years to provide indication of a cell becoming unserviceable long before it fails.

If a battery cell has deteriorated, or if a connection is loose, the voltage under load will drop excessively, indicating need for replacement or maintenance.

ENCLOSURE 1 LICENSE AMENDMENT 230 EMERGENCY DIESEL GENERATOR SHORT-TIME LOAD TESTING KEWAUNEE POWER STATION Letter from MKW to Duke Engineering and Services Dated June 11,1992 DOMINION ENERGY KEWAUNEE, INC.

J u n e 11, 2992 JUN 1 7 1992 File

rummm

---I-,..

p-J c

0 t l l " l. V t O l Cocy to I ~&on/lnfo 1-L jccn-T-1 TiL1Ies Duke Engineering and Services, Inc.

Proj.File ( i 1 230 South Tryan Street P. 0. Box 1004 Charlotte, N. C. 28201 A t t e n t i a n : M i k e G n t h a n y

Dear M i k e,

It was a pleasure to meet you at the owner's Group meeting, i t is always n i c e to be able to tie a Pace ta an name and v o i c e.

X t

was my impression that the meeting was conducted v e r y well and produced p a s i t i v e results.

A s X announced at t h e meeting; Don Galeazzi requested a meeting w i t h END on Friday June 5, 1992 to discuss the e n g i n e r a t i n g curves. This was a direct result a f t h e concerns and 'valued input from t h e members, voiced d u r i n g the meeting.

We have attached t h e revised r a t i n g curves which were a result of that meeting.

We would appreciate it if you wauld d i s t r i b u t e to the O w n e r ' s Group m e m b e r s.

S i n c e r e l y,

I n c.

Nuclear Sates Representative Post Oflice Elox 1928 Rocky Mount. North Carolina 27802-t928 Phone: (919) 977-2720 TWX: (510) 929-0725 r :AX:

(919) 446-3830

EMD 645E4 Diesel Engine Ratings at Elevated Temperatures June 3.1, 1992 THE EMD 643 DIESEL ENGINE RATINGS ARE BASED ON 904F ENGINE INTAKE A I R TEMPERATURE.

FOR HIGHER INTAKE O I R TEMPERATURES THE ENGINE MUST BE DERATED I N PCCORDANCE WITH THE ATTRCHED CURVE(5) AS DESCRIBED BELOW:

1.

FOR OPERATION WHERE THE ENGINE CUULFINT TEMPERATURE OUT OF THE ENGXNE I S LIMITED T0 190.F:

I A.

USE CURVE 8'1 FOR THE "CONTINUOUS", "9HORT-TIME1' AND "2000 HR" RfiTINGS.

t B.

USE CURVE "A" FOR THE "200 WR", AND "4 HR" RATINGS.

X C.

USE CURVE "C" FOR THE "30 MEN" RRTING.

d Where these curves i n t e r s e c t the 2000 hr r a t i n g curve, the 2000 h r rating curve w i l l a p p l y.

2-FOR OPERRTLON WHERE THE ENGINE COOLANT TEMPERATURE CIUT CIF THE ENGINE 15 ABOVE 190°F:

A.

USE CURVE "A" FOR A L L RATINGS EXCEPT THE "30 M I N "

RATING.

B. USE CURVE "C" FOR THE "30 M I N " RGTING.