ML12226A255
| ML12226A255 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 08/07/2012 |
| From: | Schrader K, Sharp M Pacific Gas & Electric Co |
| To: | Office of Nuclear Reactor Regulation |
| Sebrosky J | |
| References | |
| TAC ME9042, TAC ME9043 | |
| Download: ML12226A255 (36) | |
Text
DIABLO CANYON POWER PLANT Pre-application Meeting, Diesel Generator License Amendment Request August 7, 2012 Ken Schrader Regulatory Services Pacific Gas & Electric Co.
Avila Beach, CA kjse@pge.com 805-545-4328 Mark Sharp Engineering Manager, Licensing Basis Verification Project Pacific Gas & Electric Co.
Avila Beach, CA masl@pge.com 805-788-0134 1
Agenda Diablo Canyon Power Plant (DCPP)
Diesel Generator (DG) Licensing Basis Issues to be Resolved by License Amendment Request (LAR)
DCPP DG Loading Analyses Scope of Tech Spec (TS) Changes Specific TS Changes Staff Feedback 2
DCPP DG Licensing Basis Safety Guide 9 (SG 9), dated March 10, 1971 Provides basis for DG design DG Ratings:
2600 kW, Continuous (8000 hours0.0926 days <br />2.222 hours <br />0.0132 weeks <br />0.00304 months <br /> per year) 2750 kW, 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> per year 3000 kW, 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> per 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> 3100 kW, 30 minutes per year Generator full load rating at 80% PF = 3250 kVA Approved exception to SG 9, Regulatory Position C.4 for AFW pump frequency recovery time 3
DCPP DG Licensing Basis Regulatory Guide (RG) 1.108, Revision 1 Provides basis for DG testing Approved exceptions to RG 1.108, Rev 1:
Regulatory Position 2.a for DG surveillance frequency Regulatory Position 2.a.(5) for modified DG hot start Regulatory Positions 2.a.(9), 2.d, 2.e, and 3 for DG test validation Regulatory Positions 2.a.(3) and 2.c.(2) for verification that DG cooling system functions within design limits 4
DCPP DG Licensing Basis RG 1.137, Revision 1 Endorses ANSI N195-1976 which provides basis for fuel oil and lube oil volume requirements 5
Issues to be Resolved by LAR DG maximum steady state loading exceeds 2000-hour DG rating (2750 kW) at current Surveillance Requirement (SR) maximum frequency value Current SR maximum frequency value = 61.2 Hz Current administratively controlled maximum frequency value = 60.5 Hz DG loading analyses maximum frequency value = 60.8 Hz, maintains load < 2750 kW 6
Issues to be Resolved by LAR Current SR load values based on Standard TS (STS) that are based on RG 1.9, Rev 3 as opposed to RG 1.108, Rev 1 RG 1.9, Rev 3 assumes maximum loading below continuous DG rating RG 1.108, Rev 1 requires demonstration of full-load-carrying capability (continuous DG rating)
DG maximum loading at 60.8 Hz (2743 kW) exceeds continuous DG rating (2600 kW) 7
Issues to be Resolved by LAR Current SR Power Factor (PF) values do not bound DG loading analysis calculated values Current SR minimum PF value = 0.87 DG loading analysis minimum PF value = 0.848 Current administratively controlled minimum PF = 0.85 8
Issues to be Resolved by LAR Current SR day tank volume based on continuous rating versus maximum loading RG 1.137, Rev 1 endorses ANSI N195-1976, which requires each day tank to contain fuel oil for at least 60 minutes of DG operation assuming fuel oil consumption with the DG running at 100%
continuous rated load plus 10% additional margin Required fuel oil for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> of DG operation at maximum loading (2743 kW) is greater than current SR minimum day tank volume (250 gal) 9
Issues to be Resolved by LAR Current SR full load rejection test value does not meet RG 1.108, Rev 1 requirements RG 1.108, Rev 1 requires demonstration of proper operation during DG load shedding, including a test of complete loss of load Consistent with STS, current SR provides a loading band between 90% and 100% of continuous DG rating (2340 kW to 2600 kW)
DG maximum loading at 60.8 Hz (2743 kW) exceeds continuous DG rating (2600 kW) 10
Issues to be Resolved by LAR Current SR capability test load values do not meet RG 1.108, Rev 1 requirements RG 1.108, Rev 1 requires demonstration of full-load-carrying capability (continuous DG rating) for intervals not less than 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> (SR 3.8.1.3) and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> (SR 3.8.1.14)
Consistent with STS, current SRs provide a loading band between 90% and 100% of continuous DG rating (2340 kW to 2600 kW) for full-load-carrying capability tests 11
DCPP DG Loading Analyses To address the NRC resident inspector observations related to NRC Temporary Instruction 2515/176, PG&E commissioned DG Loading Analyses to evaluate vital 4160 V Engineered Safety Features (ESF) bus loading under various Design Basis Accident (DBA)
Scenarios Preliminary DG Loading Analyses are complete, currently being reviewed by PG&E 12
DCPP DG Loading Analyses The following DBAs are considered in the DG Loading Analyses:
Event 1: Large Break Loss of Coolant Accident (LBLOCA)
Event 2: Small Break Loss of Coolant Accident (SBLOCA)
Event 3: Steam Generator Tube Rupture (SGTR)
Event 4: Steamline Rupture Inside Containment at Power Event 5: Steamline Rupture Inside Containment at Hot Zero Power Event 6: Feed Line Break Event 7: Loss of Normal Feedwater Event 8: Loss of Offsite Power (LOOP)
Event 9: Station Blackout (SBO) 13
DCPP DG Loading Analyses The following vital 4160 V ESF bus loading cases are considered for each of the postulated DBAs evaluated in the DG Loading Analyses:
Case 1: All DGs operating, all vital 4160 V ESF buses (F, G & H) energized with single component failure considerations Case 2: Vital 4160 V ESF bus F has failed resulting in accident loads being supplied by vital 4160 V ESF buses G and H Case 3: Vital 4160 V ESF bus G has failed resulting in accident loads being supplied by vital 4160 V ESF buses F and H Case 4: Vital 4160 V ESF bus H has failed resulting in accident loads being supplied by vital 4160 V ESF buses F and G 14
DCPP DG Loading Analyses The DG Loading Analyses determine the mechanical equipment load demands for the large 4160 V and 480 V rotating equipment (pumps &
fans) powered by the vital 4160 V ESF buses Both limiting single component failures and vital 4160 V ESF bus failures were considered in the analyses to determine the maximum steady state mechanical load demands of the rotating equipment on the vital 4160 V ESF buses As-installed vendor pump/fan curves were utilized to determine the most limiting mechanical loading considering either the actual equipment performance or the equipment run-out conditions where appropriate 15
DCPP DG Loading Analyses The DG Loading Analyses utilize the DCPP Emergency Operating Procedure pathways and the Safety Analyses of Record to determine electrical demands that are manually loaded onto the vital 4160 V ESF buses following the postulated DBAs The analyses determine when and for how long operator manipulated and automatically sequenced loads are energized following the postulated DBAs and develop the vital 4160 V ESF bus loading sequence profiles No credit was taken for any Time Critical Operator Action assumed operator reduction of automatic vital 4160 V ESF bus loading 16
DCPP DG Loading Analyses The maximum mechanical load demands, the manually initiated demands, and the automatically initiated demands are then tabulated to determine all 480 V and 4160 V electrical demands that are automatically and manually loaded onto the vital 4160 V ESF buses following the postulated DBAs The DG Loading Analyses evaluate the sequenced load on the DGs at the maximum DG output voltage (4400 V) and frequency (60.8 Hz) and consider the effects of DG output voltage, system frequency, and equipment load losses on the DGs 17
DCPP DG Loading Analyses The summarized vital 4160 V ESF bus loading results from the DG Loading Analyses with the DG operating at the proposed maximum steady state frequency of 60.8 Hz and 4400 V are as follows:
Power Generator Unit DG Bus Description Loading Factor Load Event 1, Case 4; 1-3 F LBLOCA, Bus H is De-Energized 2740 kW 84.9% 3228 kVA Event 1, Case 4; 1 1-2 G LBLOCA, Bus H is De-Energized 2681 kW 85.6% 3132 kVA Event 1, Case 3; 1-1 H LBLOCA, Bus G is De-Energized 2703 kW 86.6% 3122 kVA Event 1, Case 4; 2-3 F LBLOCA, Bus H is De-Energized 2743 kW 84.8% 3237 kVA Event 1, Case 4; 2 2-1 G LBLOCA, Bus H is De-Energized 2673 kW 84.9% 3148 kVA Event 1, Case 3; 2-2 H LBLOCA, Bus G is De-Energized 2672 kW 86.5% 3089 kVA 18
DCPP DG Loading Analyses The DG Loading Analyses demonstrate that the DGs have sufficient capacity and margin to fulfill the onsite power source requirements established in GDC 17, Electric Power Systems, 1971 The DG Loading Analyses demonstrate the DGs satisfy SG 9, Regulatory Position C.4 requirement that the peak continuous steady-state loading of the DGs under maximum output voltage and frequency following a postulated DBA does not exceed the smaller of the 2000-hr DG rating (2750 kW), or 90% of the 30-minute DG rating (90% of 3100 kW = 2790 kW) 19
Scope of TS Changes SR 3.8.1.3 (1-hour DG capability test)
DG full-load-carrying capability test band revised SR 3.8.1.4 (fuel oil day tank volume)
Day tank fuel oil requirement revised from volume to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> supply, day tank fuel oil specific volume value relocated from the TS to the TS Bases Consistent with TSTF-501 change SR 3.8.1.10 (DG full load rejection)
DG operating PF value revised DG full-load rejection test load value revised 20
Scope of TS Changes SR 3.8.1.11 (LOOP)
DG maximum steady state operating frequency revised SR 3.8.1.14 (24-hour DG capability test)
DG operating PF value revised DG 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> full-load-carrying capability test load values revised SR 3.8.1.15 (DG hot re-start test)
DG full-load-carrying capability pre-test load values revised 21
Scope of TS Changes SR 3.8.1.19 (LOOP and Safety Injection)
DG maximum steady state operating frequency revised LCO 3.8.3, Condition A, Condition B, SR 3.8.3.1, and SR 3.8.3.2 Specific numerical fuel oil and lube oil volumes relocated from the TS to the TS Bases consistent with TSTF-501 Surveillances revised to be based on 7 day supply Conditions A and B revised to be based on 6 to 7 day supply Consistent with TSTF-501 change 22
Specific TS Changes SR 3.8.1.3 (1-hour DG capability test)
Current loading band revised from 2340 kW and 2600 kW to 2650 kW and 2750 kW Minimum load band value bounds continuous DG rating and maximum DG loading at nominal frequency of 60 Hz (2634 kW)
Maximum load band value bounds maximum DG loading at frequency of 60.8 Hz while allowing for immediate retest PG&E believes revised SR meets RG 1.108, Rev 1, Regulatory Position C.2.c.(2) requirement to demonstrate full-load-carrying capability (continuous DG rating) 23
Specific TS Changes SR 3.8.1.4 (fuel oil day tank volume)
Consistent with TSTF-501, Rev 1, current specific numerical value for the day tank fuel oil volume relocated from the TS to the TS Bases so that it may be modified under licensee control Columbia License Amendment No. 215 provided precedent for acceptance of SR 3.8.1.4 day tank fuel oil volume requirement relocation to TS Bases as part of TSTF-501 Revised day tank volume to be incorporated in TS Bases under TS Bases Control Program 24
Specific TS Changes SR 3.8.1.4 (fuel oil day tank volume)
Current day tank fuel oil volume requirements are revised for operation at 2000-hour DG rating (2750 kW)
Meets ANSI N195-1976 requirement to ensure each day tank contains fuel oil for at least 60 minutes of operation assuming fuel oil consumption with the DG running at 100% continuous rated load plus a minimum additional fuel oil volume margin of 10%
Use of 2000-hour DG rating bounds continuous DG rating and maximum DG loading at frequency of 60.8 Hz 25
Specific TS Changes SR 3.8.1.10 (DG full load rejection)
Current loading band revised from 2340 kW and 2600 kW to 2650 kW and 2750 kW Minimum load band value bounds continuous DG rating and maximum DG loading at nominal frequency of 60 Hz Maximum load band value bounds 2000-hour DG rating and maximum DG loading at frequency of 60.8 Hz and voltage of 4400 V 26
Specific TS Changes SR 3.8.1.10 (DG full load rejection)
Current PF revised from 0.87 to 0.84 to bound DG load analysis minimum power factor of 0.848 Consistent with STS, note is added that if grid conditions do not permit, the PF is not required to be met and shall be maintained as close as practicable 27
Specific TS Changes SR 3.8.1.11 (LOOP)
Current maximum steady state frequency revised from 61.2 Hz to 60.8 Hz DG loading analyses establish maximum steady state DG loading at a maximum frequency of 60.8 Hz Current maximum frequency administratively controlled 60.5 Hz Instrument uncertainty values included in surveillance test procedures 28
Specific TS Changes SR 3.8.1.14 (24-hour DG capability test)
Current loading band for 2-hour portion revised from 2600 kW and 2860 kW to 2750 kW and 2860 kW Minimum load band value bounds 2000-hour DG rating and maximum DG loading at maximum frequency of 60.8 Hz and maximum voltage of 4400 V Maximum load band value is unchanged and corresponds to 110% of continuous DG rating 29
Specific TS Changes SR 3.8.1.14 (24-hour DG capability test)
Current loading band for 22-hour portion revised from 2340 kW and 2600 kW to 2650 kW and 2750 kW Minimum load band value bounds continuous DG rating and maximum DG loading at nominal frequency of 60 Hz Maximum load band value corresponds to 2000-hour DG rating and bounds maximum DG loading at maximum frequency of 60.8 Hz and maximum voltage of 4400 V 30
Specific TS Changes SR 3.8.1.14 (24-hour DG capability test)
Current PF revised from 0.87 to 0.84 to bound DG load analysis minimum power factor of 0.848 Consistent with STS, note is added that if grid conditions do not permit, the PF is not required to be met and shall be maintained as close as practicable 31
Specific TS Changes SR 3.8.1.15 (DG hot re-start test)
Current loading band for pre-test DG operation revised from 2340 kW and 2600 kW to 2650 kW and 2750 kW Meets RG 1.108, Rev 1, Regulatory Position C.2.a.(5) requirements to demonstrate functional DG capability at full-load temperature conditions 32
Specific TS Changes SR 3.8.1.19 (LOOP and Safety Injection)
Current maximum steady state frequency revised from 61.2 Hz to 60.8 Hz DG loading analyses establish maximum steady state DG loading at a maximum frequency of 60.8 Hz Current maximum frequency administratively controlled 60.5 Hz Instrument uncertainty values included in surveillance test procedures 33
Specific TS Changes TS 3.8.1 Bases Revision of maximum steady state frequency (from 61.2 Hz to 60.8 Hz) for SRs 3.8.1.11 and 3.8.1.19 where DG is fully loaded Clarification that requirement for DG steady state frequency for SRs that do not include specific DG loading requirements is 58.8 to 61.2 Hz Addition of statement that DG loads in SRs are treated as nominal values, no instrument uncertainties for load included in surveillance procedures DG loads are not modeled in accident analyses DG loads are limited by vendor ratings (define maintenance intervals)
Instrument uncertainty for DG load displayed by digital meters on the control room vertical board = 90 kW Difference in DG loading at nominal frequency of 60 Hz and maximum frequency of 60.8 Hz ( = 1.3%) is 109 kW ( = 4.1%)
After loading, DGs operate at frequency within 0.5Hz of nominal Does this change require NRC approval?
34
Specific TS Changes LCO 3.8.3, Condition A/B, SR 3.8.3.1/3.8.3.2 Consistent with TSTF-501 Rev 1, current volume values for fuel oil storage tank and lube oil relocated to the TS Bases Condition A and Condition B revised to address fuel oil storage tank and lube oil inventory volumes less than a 7-day supply and greater than a 6-day supply Fuel oil storage tank and lube oil inventory volume requirements to be greater than a 7-day supply for SR 3.8.3.1 and SR 3.8.3.2 Revised fuel oil storage tank and lube oil inventory volumes to be incorporated in TS Bases under TS Bases Control Program 35
Staff Feedback Staff Feedback 36