ML17221A451

Proposed Changes to Diesel Generator Tech Specs in Response to Generic Ltr 84-15

ML17221A451
Person / Time
Site:	Saint Lucie
Issue date:	10/19/1987
From:	FLORIDA POWER & LIGHT CO.
To:
Shared Package
ML17221A450	List: ML17221A449 ML17221A451
References
GL-84-15, NUDOCS 8710230067
Download: ML17221A451 (45)

Text

ATTACHMENT I Marked-up Technical Specification Pages 3/4 8-l (with inserts) 3/4 8-2 (with inserts) 3/4 8-3 (with inserts) 3/4 8-4 (with insert) 3/4 8-5 (with insert) 3/4 8-6 (with insert) 3/4 8-8 (with insert) 3/4 8-9 (with insert)

B3/4 8-l 8710230067 871019&

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3/4.8 ELECTRICAL POWER SYSTEMS 3/4.8.1 A.C. SOURCES OPERATING LIMITING CONDITION FOR OPERATION 3.8.1.1 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. Two physically independent circuits between the offs e transmission network and the onsite Class IE distribution system, and

b. Two separate and independent diesel generators, each with:

1. Two separate engine-mounted fuel tanks containing a minimum volume of 200 gallons of fuel each,

2. A separate fuel storage system containing a minimum volume of 40,000 gallons of fuel, and 3 ~ A separate fuel transfer pump.

APPLICABILITY: MODES 1, 2, 3, and 4.

ACTION:

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a. With one offsite circuit of 3.8. I.l.a inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.I. I. I.a within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter. If either EDG has not been successfully tested within the past 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, demonstrate its OPERABILITY by performing Surveillance Requirement 4.8.I.I.2a.4 separately for each such EDG within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

Restore the offsite circuit to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />.

INSERT /72

b. With one diesel generator of 3.8.I. I.b inoperable, demonstrate the OPERABILITY of the A.C. sources by'performing Surveillance Requirement 4.8.l.l.l.a within I hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the EDG became inoperable due to any cause other than preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.I.I.2.a.4 within 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />s+; restore the diesel generator to OPERABLE status within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Additionally, verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> that:

I. All required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and

2. When in MODE I, 2, or 3, the steam driven auxiliary feed pump is OPERABLE.

INSERT jj3 This OPERABILITY requirement can be met with one Unit 2 startup transformer (2A or 2B) inoperable, provided that a Unit I startup transformer (I A or IB) connected to the same A or B offsite power circuit is administratively available to both units and not required for use on Unit I.

INSERT /$ 4

+This test is required to be completed regardless of when the inoperable EDG is restored to OPERABILITY.

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ELECTRICAL POWER SYSTEMS ACTION (Continued)

SURVEILLANCE RE UIREMENTS

4. 8. 1. 1. 1 Each of the above required independent circuits between the offsite transmission network and the onsite Class lE distribution system shall be:

a. Determined OPERABLE at least once per 7 days by verifying correct breaker alignments, indicated power availablity, and

b. Demonstrated OPERABLE at least once per 18 months by transferring (manually and automatically) unit power supply from the normal circuit to the alternate circuit.-

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Inserts for 3/4 8-2 INSERT N5 c With one offsite A.C. circuit and one diesel generator inoperable, demonstrate the OPERABILITY of the remaining A.C. sources by performing Surveillance Requirement 4.8.l.l.l.a within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; and if the EDG became inoperable due to any cause other than preplanned preventative maintenance or testing, demonstrate the OPERABILITY of the remaining OPERABLE EDG by performing Surveillance Requirement 4.8.I.I.2.a.4 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />". Restore at least one of the inoperable sources to OPERABLE status within 12 hours1.388889e-4 days <br />0.00333 hours <br />1.984127e-5 weeks <br />4.566e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Restore the other A.C. power source (offsite circuit or diesel generator) to OPERABLE status in accordance with the provisions of Section 3.8.l.l. ACTION Statement a or b, as appropriate, with the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable A.C. power source. Additionally, verify within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> that:

I. All required systems, subsystems, trains, components and devices that depend on the remaining OPERABLE diesel generator as a source of emergency power are also OPERABLE, and

2. When in MODE I, 2, or 3, the steam-driven auxiliary feed pump is OPERABLE.

INSERT //6

d. With two of the required offsite A.C. circuits inoperable, demonstrate the OPERABILITY of two diesel generators by sequentially performing Surveillance Requirement 4.8.I. I.2.a.4 on both diesels within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, unless the diesel generators are already operating; restore one of the inoperable offsite sources to OPERABLE status within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br />. Following restoration of one offsite source, follow ACTION Statement a. With the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable offsite A.C. circuit.

INSERT P7:

e. With two of the above required diesel generators inoperable, demonstrate the OPERABILITY of two offsite A.C. circuits by performing Surveillance Requirement 4.8.l.l.l.a. within one hour and at least once per 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> thereafter; restore one of the inoperable diesel generators to OPERABLE status within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or be in at least HOT STANDBY within the next 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> and in COLD SHUTDOWN within the following 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br />. Following restoration of one diesel generator unit, follow ACTION Statement b with the time requirement of that ACTION Statement based on the time of initial loss of the remaining inoperable diesel generator.

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This test is required to be completed regardless of when the inoperable EDG is restored to OPERABILITY.

E JW4/036/6,

ELECTRICAL POWER SYSTEM SURVEILLANCE RE UIREMENTS Continued 4.8. 1. 1.2 Each diesel generator shall be demonstrated OPERABLE:

'a 0 In accordance with the frequency specified in Table 4.8-1 on a STAGGERED TEST. BASIS by:

l. Verifying the fuel level in the engine-mounted fuel tank,

2. Verifying the fuel level in the fuel storage tank,

3. Verifying the fuel transfer pump can be started and transfers.

fuel from the storager system to the engine-mounted tank, gl 4. Verifying the diesel starts from ambient condition and

> pprogiv~ aes o 900 rpm in less than or equal to seconds The generator voltage and frequency shall be 4160 t 420 volts and 60 + 1.2 Hz within 10 seconds after the

'W start signal. The diesel generator shall be started for this test by'using one of the following signals:

a) Manual.

b) Simulated loss-of-offsite power by itself.

c) Simulated loss-of-offsite power in conjunction with an ESF-actuation test signal.

d) An ESF actuation test signal by itself.

5. Verifying the generator is synchronized, loadegto greater than

++4 or e ual to 3685 kW , and 4)itl id C} operates for at least an additional 60 minutes, and lo<g b+~d og zygo ~ >'. Verifying the diesel generator is aligned to provide standby power to the associated emergency busses.

b. At least once per 31 days and after each operation of the diesel where the period of operation was greater than or equal to 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> by checking for and removing accumulated water from the engine-mounted fuel tanks.

C. At least once per 92 days and from new fuel prior to addition to the storage tanks, by obtaining a sample of fuel oil in accordance with ASTM-0270-1975, and by verifying that the sample meets the fol'lowing minimum requirements and is tested within the specified time limits:

l. As soon as sample is taken or prior to adding new fuel to the storage tank verify in accordance with the test specified in ASTM-0975-77. that the sample has:

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ST. LUCIE - UNIT 2 3/4 8-3

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""The diesel generator start (IO sec) from ambient conditions shall be performed at least once per I84 days in these Surveillance tests. All other engine starts for purposes of this Surveillance testing may be preceded by an engine prelube period and/or other warmup procedures recommended by the manufacturer.

INSERT 8 I 0:

""+Timing for the test shall start upon the closing of the diesel generator breaker. Loading for the purpose of this test may be performed according to manufacturer's recommendations. The indicated load band is meant as guidance to avoid routine overloading. Variations in loads in excess of the band due to changing bus loads shall not invalidate this test.

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ELECTRICAL POWER SYSTEMS SURVEILLANCE RE UIREMENTS Continued a) A water and sediment content of less or equal to .

0.05 volume percent.

b) A kinematic viscosity 8 40 C of greater than or equal to 1.9 centistokes, but less than or equal to 4.1 centistokes.

c) A specific gravity as specified by the manufacturer 0 60/60 F of greater than or equal to 0.8 but less than or equal to 0.99 or an API gravity 9 60 F of greater than or equal to 11 degrees but less than or equal to 47 degrees.

2. Within 1 week after obtaining the sample, verify an impurity level of less than 2 mg of insolubles per 100 al when tested in accordance with ASTN-02274-70.

3. Within 2 weeks of obtaining the sample verify that the other properties specified in Table 1 of ASTN-0975-77 and Regulatory Guide 1.137 Position 2.a are set when tested in accordance with ASTM-0975-77.

e. At least once per 18 months during shutdown by:

1. Subjecting the diesel to an inspection in accordance with procedures prepared in conjunction with its manufacturer's recoaaendations for this class of standby service.

2. Verifying the generator capability to reject a load of greater than or equal to 453 kW while maintaining voltage at 4160 +

420 volts and frequency at 60 + 1.2 Hz.

3. Verifying the generator capability to reject a load of 3685 kW without tripping. The generator voltage shall not exceed 4784 volts during and following the load rejection.

4. Simulating a loss-of-offsite power by itself, and:

a) Verifying deenergization of the eaergency busses and load shedding froa the eaergency busses.

b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected shut-down loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization, the steady-state voltage and frequency of the eaergency busses shall be maintained at 4160 a 420 volts and 60 a 1.2 Hz during this test.

ST. LUCIE - UNIT 2 3/4 8-4

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+"This test may be conducted in accordance with the manufacturer's recommendations concerning engine prelube period and/or other warmup procedures.

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ELECTRICAL POWER SYSTBIS SURVEILLANCE RE UIREHENTS Continued

5. Verifying that on an ESF actuation test si nal (without loss-of-offsite power) the diesel generator starts on the auto-start signal and operates on standby for greater than or equal to 5 minutes. The steady-state generator voltage and frequency shall be 4160 a 420 volts and 60 t 1.2 Hz within 10 seconds after the auto-start signal; the generator voltage and frequency shall be maintained within these limits during this test.

6. Simulating a loss-of-offsite power in conjunction with an ESF actuation test signal, and a) Verifying deenergization of the emergency busses and load shedding from the emergency busses.

b) Verifying the diesel starts on the auto-start signal, energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected emergency (accident) loads through the load sequencer and operates for greater than or equal to 5 minutes while its generator is loaded with the emergency loads. After energization, the steady-state voltage and frequency of the emergency busses shall be maintained at 4160 +

420 volts and 60 a 1.2 Hz during this test.

c) Verifying that all automatic diesel generator trips, except engine overspeed and generator differential, are automatically bypassed upon loss of voltage on the emer-gency bus concurrent with a safety injection actuation signal. ~

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

Ouring the firs 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of this test, the diesel generator shall be loade and during the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the diesel generator shall be loaded The generator g,Q;> a /~b voltage and frequency shall be 4160 t 420 volts and 60 a 1.2 Hz within 10 seconds after the start signal; the steady-state 6aad of g'Iso generator voltage and frequency shall be maintained within these

+ a68s k~ limits during this test. Within 5 minutes after completing this 24-hour test, perform Surveillance Requirement 4.8. 1. 1.2e.4.b).

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Insert for 3/4 8-5 INSERT /5 l2:

This band is meant as guidance to avoid routine overloading of the engine.

Variations in load in excess of this band due to changing bus loads shall not invalidate this test.

E J W4/036/9

ELECTRICAL POWER SYSTEMS SURVEILLANCE RE UIREMENTS Continued Verifying that the auto-connected loads to each diesel 8.

generator do" not exceed the 2000-'hour rating of~s9'as kW.

9. Verifying the diesel generator's capability to:

a) Synchronize with the offsite power source while the generator is loaded with its emergency loads upon a simulated restoration of offsite power, b) Transfer its loads to the offsite .power source, and c) Be restored to its standby status.

10. Verifying that with the diesel generator operating in a test mode (connected to its bus), a simulated safety injection signal overrides the test mode by (1) returning the diesel generator to standby operation and (2) automatically energizes the emergency loads with offsite power.

ll. Verifying that the fuel transfer pump transfers fuel from each fuel storage tank to the engine-mounted tanks of each diesel via the installed cross connection lines.

gnSCR+ H<+ f. At least once per 10 years or after any modificatio s which could affect diesel generator interdependence by starting the diesel g~g yg'//Ae ~ generators simultaneously, during shutdown, and verifying that the JPg(u a'4c ~~ ~ diesel generators accelerate to~~es4- 900 rpm in less than or equal to 10 seconds. 4ppioxi'm 4 kly q.g./. /.28, IZ p Rn ched g. At least once per 10 years by:

l. Draining each fuel oil storage tank, removing the accumulated sediment and cleaning the tank using a sodium hypochlorite so'lution, and

2. Performing a pressure test of those portions of the diesel fuel oil system designed to Section III, subsection NO of the ASME Code at a test pressure equal to llOX of the system design pressure.

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ST. LUCIE - UNIT 2 3/4 8-6

Insert for 3/4 8-6 New Surveillance Requirement 4.8. I. I.2e. I2.

12. Verifying that the automatic load sequence timers are operable with the interval between each load lock within + I second of its design interval.

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TABLE 4.8-1 DIESEL GENERATOR TEST SCHED LE Number of Failures Last 100 Valid Tests. Test Fre uenc At least once per 31 days At least once per 14 days At least once per 7 days

> 4 At least once per 3 days

~Crlter>a for determining numb r of fail es and number of valid tests

,shall be in accordance with egulatory Po ition C.2.e of Regulatory Guide l. 108, Revision 1, A ust 1977, wher the last 100 tests are determined on a per nucle unit basis. For the purposes of this test schedule, only vali tests conducted aft the Operating License issuance date shall be 'luded in the computat'on of the "last 100 valid tests". Entry i o this test schedule sha be made at the 31 day test frequency x'n sm.f u~

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'T. LUCIE - UNIT 2 3/4 8"8

Insert for 3/4 8-8 Table 4.8-I DISESEL GENERATOR TEST SCHEDULE Number of Failures in Last 20 Valid Tests+ Test Fre uenc At least once per 3I days 2 At least once per 7 days""

+Criteria for determining number of failures and number of valid tests shall be in accordance with Regulatory Position C.2.e of Regulatory Guide I. I08, Revision I, August I 977, where the number of tests and failures is determined on a per diesel generator basis.

""This test frequency shall be maintained until seven consecutive failure free demands have been performed and the number of failures in the last 20 valid demands has been reduced to one or less.

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ELECTRICAL POWER SYSTB5 A.C. SOURCES SMUTDOWN LIHITING CONDITION FOR OPERATION 3.8.1.2 As a minimum, the following A.C. electrical power sources shall be OPERABLE:

a. One circuit between the offsite transmission network and the onsite Class 1E distribution system, and

b. One diesel generator with:

1. Two engine-mounted fuel tanks each containing a minimum volume of 200 gallons of fuel,

2. A fuel storage system containing a minimum volume of 40,000 gallons of fuel, and

3. A fuel transfer pump.

APPLICABILITY: HODES 5 and 6.

ACTION:

With., less than the above minimum required A.C. electrical power sources OPERABLE, iaaediately suspend all operations involving CORE ALTERATIONS, positive reactivity changes, movement of irradiated fuel, or crane operation with loads over the fuel storage pool, and within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />, depressurize and vent the Reactor Coolant System through a greater than or equal to 3.58 square inch vent. In addition, when in NODE 5 with the reactor coolant loops not filled, or in NODE 6 with the water level less than 23 feet above the reactor vessel flange, i~diately initiate corrective action to restore the required sources to OPERABLE status as soon as possible.

SURVEILLANCE RE UIREMENTS ol 4.8.1.2$ The above required A.C. electrical power sources shall be demonstrated OPERABLE by the. performance of each of the Surveillance Requirements of 4.8. 1.1.1, 4.8.1.1.2 (except for, requirement 4.8.1.1.2a.5).

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ST. LUCIE - UNIT 2 3/4 8"9

Insert 3/4 8-9 4.8.I.2.2 Insert:

~Re orts - All diesel generator failures, valid or non-vaiid, shall be reported to the Commission pursuant to Specification 6.9.I. Reports of diesel generator failures shall include the information recommended in Regulatory Guide l.l08, Revision I, August 1977. If the number of failures in the last l00 valid tests (on a per nuclear unit basis) is greater than or equal to 7, the report shall be supplemented to include the additional information recommended in Regulatory Position C.3.b of Regulatory Guide I. I 08, Revision I, August l977.

E J W4/036/ I 2

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3/4.8 ELECTRICAL POWER SYSTEMS BASES 3/4.8.1 3/4.8.2 and 3/4.8.3 A.C. SOURCES D.C SOURCES and ONSITE POWER DISTRIBUTION SYSTEMS The OPERABILITY of the A.C. and D.C. power sources and associated distribution systems during operation ensures that sufficient power will be available to supply the safety related equipment requi'red for 1) the safe shutdown of the facility and 2) the mitigation and control of accident condi-tions within the facility. The minimum specified independent and redundant A.C. and D.C. power sources and distribution systems satisfy the requirements of General Design Criterion 17 of Appendix "A" to 10 CFR 50.

The ACTION requirements specified for the levels of degradation of the power sources provide restriction upon continued facility operation commen-surate with the level of degradation. The OPERABILITY of the power sources are consistent with the initial condition assumptions of the safety analyses and are based upon maintaining at least one redundant set of onsite A.C. and D.C. power sources and associated distribution systems OPERABLE during accident conditions coincident with an assumed loss of offsite power and single failure of the other onsite A. C. source. The A. C. and D. C. source allowable out-of-service times are based on Regulatory Guide 1.93, "Availability of Electrical Power Sources," December 1974. When one diesel generator is inoperable, there is an additional ACTION requirement to verify that all required systems, subsystems, trains, components and devices, that depend on the remaining OPERABLE diesel generator as a source of emergency power, are also OPERABLE, and that the steam-driven auxiliary feedwater pump is OPERABLE. This require-ment is intended to provide assurance that a loss of offsite power event wi 11 not result in a complete loss'f safety function of critical systems during the period one of the diesel generators is inoperable. The term verify as used in this context means to administratively check by examining logs or other information to determine if certain components are out-of-service for maintenance or other reasons. It does not mean to perform the surveillance requirements needed to demonstrate the OPERABILITY of the component.

The OPERABILITY of the minimum specified A.C. and D.C. power sources and associated distribution systems during shutdown and refueling ensures that

1) the facility can be maintained in the shutdown'or refueling condition for extended time periods and 2) sufficient instrumentation and control capability is available for monitoring and maintaining the unit status.

The Surveillance Requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recomiendations of Regulatory Guides 1. 9 "Selection of Diesel Generator Set Capacity for Standby Power Supplies," March 10, 1971, and 1. 108 "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants," Revision 1, August 1977, and 1. 137, "Fuel Oil Systems for Standby Diesel Generators,"

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ATTACHMENT 2 SAFETY EVALUATION BACKGROUND On July 2, l984, NRC issued Generic Letter 84-15 (Proposed Staff Actions to Improve and Maintain Diesel Generator Reliability). This Generic Letter presented NRC's conclusion that the frequency of diesel generator cold fast start surveillance tests from ambient conditions should be reduced to prevent premature diesel engine degradation, and encouraged licensees to submit changes to their Technical Specifications to accomplish a reduction in the number of cold fast start surveillance tests from ambient conditions.

Generic Letter 84-l5 also presented NRC's conclusion that excessive testing results in degradation of diesel engines, and NRC encouraged licensees to propose Technical Specifications to delete the requirements for testing diesel generators while emergency core cooling equipment is inoperable.

Typical Technical Specifications, as well as an elaboration of the example performance Technical Specifications proposed to maintain reliability levels, were included with the Generic Letter.

On April 25, l985, NRC issued Amendment No. 48 to Facility Operating License No. NPF-7 for North Anna Unit 2. The amendment revised the emergency diesel generator Technical Specifications by reducing the required testing. The changes reduced the parameters for each test, reduced the number of tests, and applied to both routine surveillance and special tests. North Anna Unit 2 had requested the amendment based on diesel generator failures that had occurred and had been attributed to the excessive testing requirements, and based on recommendations identified in Generic Letter 84- I5.

On August 27, l985, FPL submitted a request to amend the St. Lucie Unit 2 Technical Specifications to be similar to the North Anna Unit 2, Amendment No.

48 Technical Specifications. As a result of NRC review and further discussion with NRC, the August 27, l985 application was revised by FPL letter L-86-I89, dated May 7, l986. As a result of a site visit to St. Lucie Units I and 2 by the NRC Staff in September l986, and further discussions with the staff, FPL has revised the proposed Technical Specifications, submitted August 27, I 985 and May 7, l986. FPL's submittal L-86-50I, dated December l2, l986 proposing to amend the emergency diesel generator fuel oil surveillance Technical Specifications is unaffected by this amendment.

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DISCUSSION Emergency diesel generators (EDGs) are credited in all FSAR Chapter l5 accident analyses that assume a loss of offsite power. The analyses include virtually every type of accident, from reactivity initiated accidents (e.g., CEA Drop and CEA Ejection) to primary and secondary system pipe breaks (e.g., Steam Line Break and Loss of Coolant Accident). When evaluating these accidents it is assumed that one EDG fails to start and/or load, hence each EDG must be capable of powering the Engineered Safety Features (ESF) that are necessary to mitigate the consequences of the accident.

ln the case of St. Lucie Unit 2, it has been calculated that the initial peak accident load (i.e., the power that must be available for the first two hours of the design basis accident) is approximately 3506 kW. The St. Lucie Unit 2 EDGs have design load ratings of 3985 and 3685 kW for 30 minutes and continous operation, respectively. In order to ensure that these EDGs can perform as they were designed, it is important that they be tested on a routine basis. However, when the testing becomes excessive (as much as 3 times a day for some ACTION Statements) the tests themselves can lead to EDG degradation, and subsequently, reduce reliability and availability. The proposed change to this Technical Specification provides for an overall reduction in diesel generator testing that is consistent with the guidelines provided by NRC Generic Letter 84-15 and other EDG Technical Specification changes previously approved by the NRC. The proposed change will improve the overall reliability and availability of the diesel generators.

The intent of this Specification is to ensure there is sufficient power available to

>>supply the safety-related equipment required, for safe shutdown of the plant and mitigation and control of accident conditions. The redundancy of the power sources required (2 onsite sources and 2 offsite sources) ensures that even during an accident with a coincident loss of offsite power and a single failure of one onsite power source, there is still sufficient power to supply all required safety systems. Since the proposed change has no effect on the Limiting Condition for Operation (LCO), these requirements are unaffected. The ACTION Statements to the LCO restrict operation of the plant in a manner commensurate with the level of degradation. For example, when one EDG is inoperable, the ACTION Statements require verification that all other A.C. power sources are operable and that all required systems, subsystems, trains and components that depend on the remaining EDG are also operable. This provides assurance that a loss of offsite power will not result in a complete loss of safety function of critical systems during the time one EDG is inoperable. The proposed changes to the ACTION Statements are either administrative (such as dividing the current ACTION Statement "a" into separate ACTION Statements "a" and "b") or they implement the reduced testing requirements recommended by NRC Generic Letter 84-15.

These changes will result in increased reliability and availability of the EDGs.

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TECHNICAL SPECIFICATION CHANGES 3.8. I. I LCO: a.

A footnote has been added to allow one Unit I startup transformer, when not being used on Unit I, to satisfy the OPERABILITY requirements of two physically independent circuits between the offsite transmission network and the onsite Class IE distribution system when one Unit 2 startup transformer is inoperable.

This is consistent with the existing St. Lucie Unit 2 Technical Specification 3.8. I. I ACTION: f. which is being deleted for conformance to the North Anna Unit 2 format.

S ecification 3.8. I. I ACTION Statements This section has been revised to reflect the following combinations of inoperability:

I offsite circuit:~ro osed Action a.i ftresent Action a.

I diesel generator: ~ro osed Action b.i ~resent Action a. and Action c.

I offsite circuit and I diesel generator:

~ro osed Action c.; ftresent Action b. and c.

2 offsite circuits: ~ro osed Action d.; present Action d.

2 diesel generators: ~ro osed Action e.; ftresent Action e.

Unit startup transformer:~ro osed LCO footnote; present Action f.

These proposed ACTION Statements are discussed below.

3.8.I.I ACTION: a.

This ACTION Statement has been changed to meet the intent of North Anna Unit 2 and GL 84-l5 with regard to offsite circuit operability.

3.8. I. I ACTION: b.

This ACTION Statement has been changed to read like North Anna Unit 2 plus the requirement to verify the OPERABILITY of systems, subsystem, trains, components and devices which rely on the remaining OPERABLE diesel generator for emergency power. This requirement is currently included in the St. Lucie Unit 2 Technical Specifications as Action c. A footnote """ has been added to be in conformance with the North Anna Unit 2 format.

3.8.I.I ACTION: c.

This ACTION Statement has been changed to read like North Anna Unit 2.

The requirement to verify the OPERABILITY of systems, subsystems, trains, components and devices which rely on the remaining OPERABLE diesel generator for emergency power has been added. This requirement is currently included in the St. Lucie Unit 2 Technical Specifications as Action c.

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3.8.I. I ACTION: d.

This ACTION Statement has been changed to read like North Anna Unit 2.

3.8.l. I ACTION: e.

This ACTION Statement has been changed to read like North Anna Unit 2.

4.8.I.I.2a.4 This Surveillance rpm limitation was changed from "at least" to "approximately" to be consistent with the allowable frequency band of 60 Hz plus (t) l.2 Hz and minus (-) I.2 Hz.

Footnote "~ was added to be consistent with the recommendations of Generic Letter 84-I5 'and North Anna Unit 2,with respect to engine warmup and pre-lube

'to minimize engine'wear.

4.8.l.l.2a.5 This Surveillance was changed to be consistent with Generic Letter 84-l5 and also defines an acceptable loading band of 3450 to 3685 kW.

Footnote +"+ was added to:

I) Provide guidance on the point at which diesel generator loading timing commences for purposes of meeting Surveillance Requirements.

2) Clarify load band requirements with regard to avoiding diesel generator overloading.

3) Provide clarification with regard to loads in excess of the specified load band not invalidating a particular Surveillance test as a result of bus load variations.

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4.8.1.1.2b and 4.8.1.1.2c Emergency diesel generator fuel oil Surveillance Requirements were proposed for revision per FPL letter L-86-501, dated December 12, 1986.

4.8.I.I.2d The present Surveillance was moved to 4.8.1.1.2e. I 2 and the Surveillance periodicity is proposed to be changed to 18 months versus 12 months as discussed below in Section 4.8.1.1.2e. I 2.

4.8.1.1.2e.4.b) 4.8.1.1.2e.5 and 4.8.1.1.2e.6 Footnote ++ was added to be consistent with Generic Letter 84-15 and North Anna Unit 2 with respect to engine pre-lube and warmup to minimize engine wear.

4.8.1.1.2e.7 The Surveillance was changed to be consistent with Generic Letter 84-15 with the appropriate St. Lucie Unit 2, 2-hour rating.

4.8.1.1.2e.8 This Surveillance change is to correct 2000-hour rating, which, per the vendor technical manual, is 3935 kW, and not 3985 as currently shown in the Technical Specifications. This change is editorial in nature.

4.8.1.1.2e.l2 This Surveillance was added and is the current specification 4.8.1.1.2d. except that the 12 month Surveillance interval is changed to an 18 month interval.

The electropneumatic timing relays which required the 12 month Surveillance interval have been replaced with Agastat DSC solid state devices which are more accurate and reliable and need only be verified on an 18 month interval per Standard Technical Specifications.

4.8.1.1.2f Footnote +" was added to be consistent with the recommendations of Generic Letter 84-15 and North'Anna Unit 2 with respect to engine warmup and pre-lube to minimize engine wear.

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The requirement to accelerate to 900 rpm in less than or equal to IO seconds was changed from "at least" to "approximately" to be consistent with Surveillance Requirement 4.8.l.l.2a.4.

TABLE 4.8-I This Table was changed to read similar to Generic Letter 84-I5.

4.8.I.2 This change proposes to delete Surveillance Requirement 4.8.I.I.3 from 4.8.I.2 and renumber 4.8.1.2 as 4.8.1.2.1 since Surveillance Requirement 4.8.1.1.3 ~Re orts does not demonstrate OPERABILITY of the diesel generators.

A new Surveillance Requirement, 4.8.1.2.2, is proposed to be added to clearly indicate that diesel generator failures under Technical Specification 3.8. I.2, A. C.

Sources Shutdown are required to be reported pursuant to Specification 8.9.1.

urveillance Requirement 4.8.1.1.3 ~ee>orts has been repeated verbatim as new Surveillance Requirement 4.8.1.2.2.

This change is editorial in nature.

BASES 3/4.8 These changes include Generic Letter 84-15 and Amendment No. 48 to Facility Operating License'NPF-7 for North Anna Unit 2 as additional Bases for diesel generator testing.

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ATTACHMENT3 DETERMINATIONOF NO SIGNIFICANT HAZARDS CONSIDERATION The standards used to arrive at a determination that a request for amendment involves no significant hazards consideration are included in the Commission's regulations, IO CFR 50.92, which states that no significant hazards considerations are involved if the operation of the facility in accordance with the proposed amendment would not (I) involve a significant increase in the probability or consequences of an accident previously evaluated; or (2) create the possibility of a new or different kind of accident from any accident previously evaluated or (3) involve a significant reduction in a margin of safety. Each standard is discussed as follows:

(I) Operation of the facility in accordance with the proposed amendment would not involve a significant increase in the probability or consequences of an accident previously evaluated.

The probability of occurrence of an accident previously evaluated in the FSAR has not been affected since the emergency diesel generators do not affect the probabilities of occurrence of accidents.

The consequences of an accident previously evaluated in the FSAR have not been increased. Reducing the test frequency and modifying the starting requirements to be consistent with the diesel manufacturer's recommendations are intended to enhance diesel reliability by minimizing severe test conditions which can lead to premature failures.

The probability of a malfunction of equipment important to safety previously evaluated in the FSAR has been reduced since the severe test requirements have been reduced which will result in increased diesel engine reliability.

The consequences of a malfunction of equipment important to safety have not changed since the new surveillance requirements will not affect the operation or operability of the diesels or any other safety related equipment.

(2) Use of the modified specification would not create the possibility of a new or different kind of accident from any accident previously evaluated.

The possibility of an accident of a new or different kind of accident other than that analyzed in the FSAR has not been created since the change affects the starting and load practices during testing only and has no impact on actual accident analysis.

The possibility of a malfunction of equipment important to safety of a different type than any analyzed in the FSAR has not been increased. In fact, the probability of equipment malfunction has been reduced as the result of the improved testing conditions and frequency of testing as discussed in Generic Letter 84-I 5.

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(3) Use of the modified specification would not involve a significant reduction in a margin of safety.

The margin of safety as defined in the basis for any Technical Specification is not reduced by the proposed changes. The changes in the testing requirements do not affect the capability of the diesels to perform their function. The purpose of the change is to increase the diesel engine reliability.

Based on the above, we have determined that the amendment request does not (I) involve a significant increase in the probability or consequences of an accident previously evaluated, (2) create the probability of a new or different kind of accident from any accident previously evaluated, or (3) involve a significant reduction in a margin of safety; and therefore does not involve a significant hazards consideration.

As indicated, the changes are either editorial/administrative changes, changes similar to changes already approved by NRC, or changes based on NRC recommendations included in Generic Letter 84-I 5.

Examples (i), (vii) and (iii) of the staff procedure for determination of no significant hazards considerations apply to this amendment request.

For these reasons it has been determined that these changes involve no significant hazards consideration.

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