ML17146A530

Safety Evaluation Supporting Amends 60 & 30 to Licenses NPF-14 & NPF-22,respectively

ML17146A530
Person / Time
Site:	Susquehanna
Issue date:	09/19/1986
From:	Office of Nuclear Reactor Regulation
To:
Shared Package
ML17146A529	List: ML17146A528 ML17146A530
References
GL-84-15, NUDOCS 8609260119
Download: ML17146A530 (13)

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~gR REPp UNITEDSTATES NUCLEAR REGULATORY COMMISSION C

WASHINGTON, D. C. 20555 0

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SAFETY EVALUATION BY THE OFFICE OF NUCLEAR REACTOR REGULATION SUPPORTING AMENDMENT NO. 60 TO FACILITY OPERATING LICENSE NO. NPF-14 AND AMENDMENT NO. 30 TO FACILITY OPERATING LICENSE NO. NPF-22 PENNSYLVANIA POWER 5 LIGHT COMPANY SUS UEHANNA STEAM ELECTRIC STATION UNITS 1 AND 2 DOCKET NOS.

50-387 AND 50-388 1.0

2.0 INTRODUCTION

By letters dated April 23, July 17, and August 29, 1986, the licensee requested changes to Technical Specification 3.8. 1.1 which would reduce the number of required diesel generator starts when in a limiting condition of operation (LCO) or during the 18 month surveillance test.

The licensee's requested changes are in accordance with NRC Generic Letter 84-15 and do not reduce the ability of the diesels to mitigate the consequences of an accident but are intended to increase the diesel's reliability by not causing undue wear due to excessive testing.

In the submittal of July 17, 1986, the licensee proposed changes to Tech-nical Specifications (TS) 4.8. 1, 1.2.d.4, 4.8.1.1.2.d.5, and 4.8. 1.1.2.d.6 to delete a loss of offsite power test and an ECCS actuation test and to substitute signal testing only without diesel start.

The licensee also proposed changes to TS 4.8.1.1.2.d.8 to clarify the verification of loads for each diesel generator would be performed by calculation.

These proposed changes were susbsequently withdrawn by the August 29, 1986, submittal.

The August 29, 1986, submittal also clarified the mode of operation under which the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> surveillance run of TS 4.8.1.1.2.d.7 is conducted.

All changes requested by the licensee in their August 29, 1986, submittal were granted except for Specification 3.8. 1. 1 Action a which has been oranted in part.

The words "unless previously and successfully tested within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" have been removed from Action a.

The staff will address this issue in a later action.

BACKGROUND The objective of diesel generator periodical surveillance testing is to meet the reliability goals of Regulatory Guide 1. 108 for the diesel gener-ators.

Such surveillance testing provides a degree of assurance of the availability of the diesel generators in mitigating various transients and postulated events following a loss of offsite power.

Therefore, the existing DG testing concept is that the above assurance has to be demon-strated with more frequent testing as the number of failure increases.

Thus, Standard Technical Specifications require that the DGs be tested in 8609260119 860919 PDR ADOCK 05000387 P

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accordance with Regulatory Guide 1. 108 where the test interval depends on the demonstrated DG performance.

Furthermore, the test interval is established conservatively on a per nuclear unit basis rather than on a per diesel generator basis.

3,0 EVALUATION The Pennsylvania Power 5 Light Company has proposed the changes to Technical Specifications to accomplish its objective-to reduce unnecessary testing of the diesel generator.

The staff has for some time been evaluating the

,frequency of DG testing and the associated potential for. severe degradation of engine parts due to excessive testing.

The test interval is established conservatively on a per nuclear unit basis rather than on a per diesel generator basis.

Thus, improper diagnosis of a DG failure could potentially result in more frequent testing of all the diesel generators.

Also, test intervals that are too short could have an adverse impact on DG reliability.

The staff concludes that this test frequency can be reduced to minimize this potential without affecting the overall DG reliability.

The licensee was also encouraged to propose TS changes in additional areas identified below to reduce excessive DG testing.

These changes are consistent with Generic Letter 84-15 guidelines.

The guidelines are summarized as follows:

(1)

Reduced testing of diesel qenerators from everv eiqht hours to once within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when a diesel generator or an offsite power supply is inoperable.

(2)

Testing of DG based on the number of failures on a per diesel generator basis.rather than unnecessarily testing all diesel generators in the nuclear plant.

(3)

Reduced test frequency for an individual diesel generator based on the number of failures from the present minimum interval of every three days to a minimum interval of seven days.

The staff has reviewed the proposed changes to determine whether these changes are in line with the above guidelines.

The result of our review follows:

l.

TS 3.8.1.1, ACTION a and b:

Present TS ACTION Statement a "With either one offsite circuit or one diesel generator,..."

is divided into the two Action Statements, which are ACTION Statement a "With one offsite circuit,..." and ACTION State-ment b "With one diesel generator...".

Proposed ACTION Statement a also added the following phrase "...unless previously and successfully tested within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />..." reoarding the necessity of testing all four

diesel generators within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

The obiective of the Action State-ment in the existing Technical Specifications is to demonstrate the immediate operability of the remaining A.C. electrical sources by per-forming the Surveillance Requirements in the event one offsite circuit or one diesel generator is inoperable.

At this time, the staff does not believe successful testing of the required A.C. electrical sources for operability prior to entry into this Action Statement meets the above stated objective or provides positive assurance of the avail-ability of the remaining A.C. electrical sources after entry into the Action Statement.

The staff will address this issue in a later action'.

The remainder of the ACTION a and ACTION b statements are in accordance with the above guideline and, therefore, are acceptable.

2.

TS 3.8.1.1, ACTION c:

The time requirement for testing the remaining three operable diesel generators is presently within two hours and at least once per eight hours thereafter.

The proposed change will require testing of, the operable diesel qenerators pursuant to Specification 4.8. 1.1.2.a.4, within eight hours.

This change is consistent with the intent of the above guideline of GL 84-15 and, therefore, is acceptable.

The last sentence of the restoration statement for the other A.C.

power sources has been added with proposed ACTION c chanqes.

The addition of the restoration statement is purely administrative and is proposed only for clarification and, therefore, the proposed change to add the last sentence is acceptable.

3.

TS 3.8.1.1, ACTION d:

The only change to ACTION d is editorial in nature due to the proposed renumbering of the Action Statements and, therefore, reference to ACTION a or b should be changed to ACTION b or c as applicable.

4.

TS 3.8.1.1, ACTION e:

Present test requirements for four diesel generators with two of the required offsite circuits inoperable are to perform'.8. 1.1.2.a.4 for one diesel qenerator at a time, within four hours.and at least once per eight hours thereafter.

The proposed change will allow diesel generator testing to be performed within eight hours.

The proposed change complies with the above guideline to reduce excessive diesel generator testing and, therefore, is acceptable.

5.

TS 3.8.1.1, ACTION f:

The performance of Surveillance Requirement 4.8.1.1.1.a, verification of breaker alignment, will be performed within one hour after entering

the Action Statement and at least once per eight hours thereafter.

The proposed change to add the following sentence "at least once per eight hours thereafter" is consistent with Action Statements a,

b and c.

This change is also consistent with Standard Technical Specifications and, therefore, is acceptable.

6.

TS 4.8.1.1.3 and Table 4.8.1.1.2-1 Testing the diesel generator provides a degree of assurance of the availability of the DGs between tests.

The DG testing concept reflected on this table is that the above assurance has to be demon-strated with more frequent testing as the number of DG failures increases.

Thus, current TS require that diesel generators be tested in accordance with RG 1.108 where the test interval depends on the demonstrated DG failures.

Also, the test interval is established conservatively on a per nuclear unit basis rather than on a per diesel generator basis.

Test intervals that are too short could have an adverse impact on DG reliability.

The staff and industry consensus is that current requirements for testing of OPERABLE DGs do not improve reliability of the OPERABLE DGs and may be a factor in potential for degradation of the OPERABLE DGs and may have negative effects on their overall expected life and hence such testing is not warranted.

There-

fore, we concur with the licensee's proposal to limit DG failure on a

per diesel generator basis and the frequency of testing a

DG will be based on its own failure rate.

This is consistent with GL 84-15 guide-lines on DG reliability and is, therefore, acceptable.

Also, according to the quideline of GL 84-15 to reduce unnecessary testing of a DG, the staff approves a change to current Technical Specifications Table 4.8. 1. 1.2-1 of the minimum interval of every three days to a minimum interval of every seven days.

7.

TS 4.8.1.1.2.d.11 The licensee requested the deletion of Technical Specification 4.8. 1. 1.2.d. 11.

This specification requires that the licensee ver ify that the fuel transfer pump transfers fuel from each fuel storaqe tank to the engine-mounted day tank of each diesel via the installed cross connection lines.

Regulatory Guide 1. 108, which describes a method for complying with the Commission's regulations regarding periodic testing of the diesel generators and support systems, suggests a

demonstration every 18 months that the engine will perform its intended function if switching from one fuel oil supply system to another where necessary.

FSAR Section 9.5.4.2 discusses the diesel generator fuel oil storage tanks and transfer pumps.

There are four 50,000 gallon capacity storage tanks (one for each diesel),

which are sufficient for seven days of continuous full load (the largest oper-atinq load indicated in FSAR Section 8.3 for a Design Basis Accident (DBA) operation).

The licensee has not taken credit in any analysis

for the transfer of fuel between the fuel oil storaqe tanks to diesel generato day tanks to which it is not normally aligned.

Each diesel generator day tank is filled from its associated fuel oil storage tank, which contains sufficient fuel to meet the seven day requirement.

The fuel transfer pumps are capable of providing an increase in the day tank inventory even while the diesels are running, if necessary.

The fuel oil inventorv in the storage tanks and day tanks is continuously monitored.

The level is indicated at the local control panel in the diesel generator building.

The proposed deletion is acceptable.

8.

TS 4.8.1.1.2.d.7 The licensee requested that Technical Specification 4.8. 1. 1.2.d.7 be modified.

The licensee proposed separating the performance of the hot restart capability test from the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load run test.

The licensee will perform the hot restart test when the diesel has run for one hour or reached stable operating temperatures.

The purpose of this test is to demonstrate that the diesel generators can auto start and accept load while the machine is at normal operating tempera-tures and pressures.

A 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> period is not required to bring the diesel generator up to normal operating conditions therefore it is of no advantage to perform this verification following a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run.

The licensee is not proposing to eliminate any testing, rather re-arrange the sequence in which the testing is performed.

The diesel generator is not suspected of being any less reliable as a result of this change since current technical specifications provide for the same testing in the event the hot restart is not sucessfully completed after the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run.

The proposed modification is acceptable.

Because the diesel generators are shared between two units, the licensee has proposed performing the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> endurance run with at least one Unit in Operational Condition 4 or 5.

This change to the surveillance requirements addresses the concerns identified in IE Information Notice 84-69 and is acceptable.

9.

TS 4.8.1. 1.2.d.3, Susquehanna Unit I The licensee

'noted that the surveillance indicates generator voltage shall not exceed 4360 volts.

The number "4360" is a typographical error made in Amendment No. 36 to NPF-14.

The correct value is 4560.

The proposed modification is acceptable.

10.

TS 4.8.1.1.2.d.13 The licensee proposed a change in the wording of the surveillance for verifying lockout features.

The change is intended to reflect more

accurately, the manner in which the lockout features are verified.

This is a wording change only that says the same thing and is, there-fore, acceptable.

The licensee has proposed general reductions in the testing frequency requirements for the onsite emergency diesel generators in the Susuquehanna Technical Specifications.

These changes involve both routine surveillance testing and special testing due to restriction of the plant operation.

The staff has reviewed the licensee's submittals and concludes the following:

Reckoning diesel generator failure on a per diesel generator basis rather than on a per nuclear unit basis is consistent with GL 84-15 guideline and is, therefore, acceptable.

(2)

(3)

Changing Technical Specification Table 4.8.1. 1.2-1 of the minimum interval of every three days to a minimum interval of every seven days complies with the guideline of GL 84-15 and is, therefore, acceptable.

Reducing testing of diesel generators on Susquehanna from every eight hours to within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> when one diesel generator or one offsite supply is inoperable is in accordance with GL 84-15 guideline and is, therefore, acceptable.

However, an additional condition to ACTION Statement a which reads "unless previously and successfully tested within the last 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />" is inconsistent with Standard Technical Specification and outside the scope of GL 84-15.

The staff will address this in a later action.

(4)

(5)

(7)

(8)

Changing Action Statement F to perform the Surveillance Requirement 4.8.1. l.l.a, verification of breaker alignment, within one hour after entering the action and at least once per eight hours thereafter is acceptable.

Deleting Technical Specification surveillance requirement 4.8.1.1.2.d. 11 is acceptable.

Modifying Technical Specification surveillance requirement 4.8. 1. 1.2.d.7 is acceptable, since the licensee is not eliminating testing, but rearranging the testing sequence.

Correcting the typographical error contained in Technical Specification surveillance requirement 4.8.1.1.2.d.3 is acceptable.

Modifying the wording of Technical Specification 4.8.1.1.2.d.13 is administrative and acceptable.

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3.0 ENVIRONMENTAL CONSIDERATION

These amendments involve a chanoe in the installation or use of a facility component located within the restricted area as defined in 10 CFR Part 20 and chanqes in surveillance requirements.

The staff has determined that the amendments involve no significant increase in the amounts, and no significant change in the types, of any effluents that may be released offsite and that there is no significant increase in individual or cumula-tive occupational radiation exposure.

The Commission has previously issued a proposed finding that these amendments involve no siqnificant hazards consideration, and there has been no public comment on such finding.

Accordingly, these amendments meet the eligibilitycriteria for categorical exclusion set forth in 10 CFR 51.22(c)(9).

Pursuant to 10 CFR 51.22(b) no environmental impact statement nor environmental assessment need be prepared in connection with the issuance of these amendments.

4.0 CONCLUSION

The Commission made a proposed determination that the amendments involve

'no significant hazards consideration which was published in the Federal Re later (61 FR 29008) on August 13,

1986, and consulted with the state of ennsy vania.

No public comments were received, and the state of Pennsylvania did not have any comments.

The staff has concluded, based on the considerations discussed above, that:

(1) there is reasonable assurance that the health and safety of the public will not be endangered by operation in the proposed

manner, and (2) such activities will be conducted in compliance with the Commission's regulations and the issuance of these amendments will not be inimical to the common defense and security nor to the health and safety of the public.

Principal Contributors:

Mari-rosette Campaanone, BWD No. 3, DRL Sang Rhow, EICSB, DBL Dated:

September 19, 1986

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