ML17215A613

Responds to Item 2 of Generic Ltr 84-15 Re Improvement & Maint of Diesel Generator Reliability.Formal Log to Readily Meet Intent of Reg Guide 1.108 Implemented

ML17215A613
Person / Time
Site:	Saint Lucie
Issue date:	10/23/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
GL-84-15, L-84-274, NUDOCS 8410290046
Download: ML17215A613 (6)

Text

REGULATORY, FORMATION DISTRIBUTION SY 'EM (RIDS)

ACCESSION NBk;801 0290006 DOC ~ DATE: 84/10/23 NOTARIZED: YES DOCKET FACIL:50-335 St. Lucie Plant< Unit 1, Flor ida Power 5 Light Co. 05000335 50-389 St, Lucie Planti Unit 2< Florida Power 5 Light Co ~ 05000389 AUTH. NAME AUTHOR AFFILIATION l'JILLI AMS i J ~ N. Florida Power 8 Light Co ~

RECIP NAME

~ RECIPIENT AFFILIATION EISENHUTg D G, ~ Division of Licensing

SUBJECT:

Responds to Item 2 of Generic Ltr 84-15 re improvement 8, maint of diesel generator reliability Formal log to readily

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meet intent of Reg Guide 1. 108 implemented, DISTRIBUTION CODE: A056D COPIES RECEIVED:LTR ENCL SIZE; TITLE: OR Submittal:Fast Cold Starts of Diesel Generat r s GL"83-Oi NOTES: 05000335 OL: 02/01/76 05000389 OL:OQ/06/83 R~CIPI~~~ COPIES RECIPIENT COPIES ID CODE/NAME LTTR ENCL ID CODE/NAME LTTR ENCL NRR ORB3 BC 01 NRR ORB3 BC 01 INTERNAL: ADM/LFMB AEOD 07 1 1 IE/DEPER/EAB 08 NRR/DL/DRAB 09 1 1 NRR/DSI/PSB 10 IB 2 NRR/DST/SPEB 11 E F 00 1 RES BARANONSKI RES/DRA/RRB 1? 1 RGN2 06 EXTERNAL: ACRS 13 LPDR 03 1 j NRC PDR 02 NSIC 05 1 NTIS TOTAL NUMBER OF COPIES REQUIRED: LTTR 28 ENCL

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FLORIDA POWER & LIGHT COMPANY October 23, 1984 L-84-274 Office of Nuclear Regulation Attention: Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Commission Washington, D. C. 20555

Dear Mr. Eisenhut:

Re: St. Lucie Units 1 and 2 Docket Nos. 50-335, 50-389

. Generic Letter 84-15 By letter dated July 2, 1984, the NRC requested that Florida Power and Light Company provide responses to three items concerning improving and maintaining diesel generator reliability. As discussed in my letter of August 31, 1984, the information herein is provided to respond to item 2 of Generic Letter 84-15.

In accumulating the below information, we researched the operators log, the out of service log, maintenance records, and interviewed both operations and maintenance personnel. It became apparent that this review of collective logs was very time consuming and does not provide a timely vehicle to collect data regarding reliability of our emergency diesel gener'ators. We have implemented a formal log to meet the intent of Regulatory Guide 1.108, paragraph 3.a to more readily discern the reliability of each emergency diesel generator at St. Lucie Plant.

We are providing only the data for the last 20 valid demands per diesel per RG 1.108 for the following reasons:

As noted above, our former record keeping methods did not easily allow conclusive findings.

Unit 1 returned to operation in May 1984 after a 14 month outage. During this outage significant modifications were made to the diesel generators and extensive testing was required.

Unit 2 received its operating license April 6, 1983 and did not finish all diesel generator modifications and testing until early May 1983. Neither units'iesel generators have 100 "valid demands" per RG 1.108 during this interval May 1983 September 1984.

84lOZ90046"'841023 PDR ADOCK 05000335 P PDR PEOPLE... SERVING PEOPLE

Office of Nuclear Regulation Page Two For both units, the existing technical specifications and RG 1.108 differ widely regarding testing. Many diesel generator starts without loading are required by technical specifications. Although RG 1.108 says tests, intentionally terminated without loading are not valid tests, we do not believe that considering any actual failures to start not to be "failures" would be technically reasonable or acceptable to the NRC. The proposed technical specifications will eliminate many of these unloaded starts but there are other required tests which do not count as valid demands where failures would count.

We will attempt to address this area in preparing the technical speci-fication changes also requested by Generic Letter 84-15.

The data is tabulated below'.

Reliabilit Data Unit 1 "1A" Diesel Generator 0 failures last 20 demands Unit 1 "1B" Diesel Generator 0 failures last 20 demands Unit 2 "2A" Diesel Generator failure last 20 demands Failure occurred 8/22/84 and was repaired, tested, and returned to service on 8/22/84 Unit 2 "2B" -Diesel Generator 0 failures last 20 demands The St. Lucie Plant has not previously kept a "yearly data report" on

, each diesel generator's reliability. It should be noted that using the RG 1.108 counting methods the last 100 demands would encompass a calendar year and the proposed technical specifications will require such a report.

We also would like to point out that we feel we have aggressively pursued diesel generator reliability and details will be provided in part 3 of our response to Generic Letter 84-15.

Very truly yours, J. W. Williams, Jr.

Group Vice President Nuclear Energy JWW/RRJ:esr cc: J. P. O'Reilly, Region II Harold F. Reis, Esquire

STATE OF FLORIDA COUNTY OF DADE J. W. Williams Jr. being first duly sworn, deposes and says:

That he is a Grou Vice President of Florida Power & Light Company, the Licensee herein; That he has executed the foregoing document; that the statements made in this document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document on behalf of said Licensee.

J. W. Williams, Jr.

Subscribed and sworn to before me this

~day of , l9~.

",'('t,'~TARY PUBLIC, in and for the County j"' 1= of Gade,'State of Florida r

STATE OF FLORIOA q T1OTARP+UOLIC ITY'Cg)MISSION EXP. FEB 14,1988 rr r BQROEO THRU GENERAL lRS. 't.'RO.

xll</t,r, My 'Commission expires:

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