ML17306A539

Informs That Util Did Not Perform Periodic Full Load Rejection Testing of Edg,Per Reg Guide 1.108,Rev 1,1977

ML17306A539
Person / Time
Site:	Palo Verde
Issue date:	03/02/1992
From:	Trammell C Office of Nuclear Reactor Regulation
To:	Conway W ARIZONA PUBLIC SERVICE CO. (FORMERLY ARIZONA NUCLEAR
References
RTR-REGGD-01.108, RTR-REGGD-1.108 NUDOCS 9203120361
Download: ML17306A539 (9)

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UNITED STATES NUCLEAR REGULATORY COMMISSION WASHINGTON, D. C. 20555 March 2, 1992 Docket Nos.

50-528, 50-529 and 50-530 Mr. William F.

Conway Executive Vice President, Nuclear Arizona Public Service Company P.

O.

Box 53999

Phoenix, Arizona 85072-3999

SUBJECT:

EMERGENCY DIESEL GENERATOR TESTING REQUIREMENTS In reviewing your Technical Specification Amendment request dated August 21,

1991, regarding changes to Technical Specification Surveillance Requirement 4.8. 1. 1, "A.C. Sources",

and based on discussions with members of your staff, we determined that APS has not performed periodic full load rejection testing of the Emergency Diesel Generators (EDG) as required by Regulatory Guide

1. 108, Revision 1,

1977 'our commitment to these requirements in the PVNGS UFSAR Section 1.8 did not take exception to the full load rejection testing requirement.

The PVNGS UFSAR Section 8.3. 1. 1.4.7 "Testabi lity (of onsite power systems)"

notes that during full load testing with the EDG paralleled to the preferred (offsite) power supply, a SIAS or AFAS will cause the EDG output breaker to automatically trip open, causing a full load rejection from the EDG.

The EDG will continue to run and revert to the isochronous voltage regulator mode.

The startup and operation of the EDG in the isochronous mode is the design response to a SIAS/AFAS condition and therefore periodic demonstration of full load rejection capability appears to be appropriate and necessary to show compliance with the UFSAR and the licensing basis.

Although the original PVNGS Unit 1 Technical Specifications included an 18 month EDG full load reject test requirement, Units 2 and 3 were issued Technical Specifications without this requirement, with the bases for Specifi-cation 3/4.8.

1 stating that "surveillance requirements for demonstrating the OPERABILITY of the diesel generators are in accordance with the recommenda-tions of Regulatory Guide

1. 108 "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants,"

Revision 1,

August 1977.

Your amendment request of May 14,

1986, sought to change Unit 1

specifications to conform to Units 2 and 3.

This request was based in part on your assurance that the modified specifications "follow the directions of existing regulatory guidance (RG 1. 108)... ".

The NRC staff issued the requested change as Amendment No.

9 having found that "the proposed changes in Palo Verde Unit 1 Technical Specification 3/4.8.

1 are consistent with curren regulatory guidance...".

We now find that absence of a periodic EDG full load reject testing requirement does not conform with current regulatory 92031203&i 920302 PDR ADOCK 05000528 P

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Mr. William F.

Conway

guidance, which includes standard Combustion Engineering Technical Specifica-tions (GETS),

as well as Regulatory Guide

1. 108 requirements.

Stated more simply, it appears to us that an error was made at some point in the licensing process and this surveillance requirement was dropped from the technical specifications on Unit 2, and thereafter replicated on the other units.

In light of the above, we request that you clarify whether or not Palo Verde Units 1, 2, and 3 are periodically conducting the full load rejection testing?

If not, how does APS intend to address this apparent discrepancy with its documented commitments'?

You are requested to review this matter and provide a written response within 60 days of your receipt of this letter.

This request for information affects fewer than 10 respondents.

Therefore, it is not subject to Office of Management and Budget review under Pub.

L.96-511.

Please contact us should you have any questions regarding this request.

Sincerely, Charles M ~ Trammell, Sr. Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation

'cc:

See next page

Mr. William F.

Conway Arizona Public Service Company Palo Verde CC:

Nancy CD Loftin, Esq.

Corporate Secretary

& Counsel Arizona Public Service Company P.

O.

Box 53999, Hail Station 9068

Phoenix, Arizona 85072-3999 Jack R.

Newman, Esq.

Newman

& Holtzinger, P.C.

1615 L Street, N ~ W., Suite 1000 Washington, D.C.

20036 James A. Beoletto, Esq.

Southern California Edison Company P.

O.

Box 800

Rosemead, California 91770 Senior Resident Inspector U.S. Nuclear Regulatory Commission HC-03 Box 293-NR

Buckeye, Arizona 85326 Regional Administrator, Region V

U.

S. Nuclear Regulatory Commission 1450 Haria Lane Suite 210 Walnut Creek, California 94596 Ignacio R. Troncoso Senior Vice President El Paso Electric Company Post Office Box 982 El Paso, Texas 79960 Roy P.

Lessey, Jr.,

Esq.

Bradley W. Jones, Esq.

Arkin, Gump, Strauss, 8auer and Feld El Paso Electric Company 1333 New Hampshire Ave., Suite 400 Washington, O.C.

20036 Hr. Charles B, Brinkman, Manager Washington Nuclear Operations ABB Combuston Engineering Nuclear Power 12300 Twinbrook Parkway, Suite 330 Rockvi lie, Maryland 20852 Mr. William A. Wright, Acting Director Arizona Radiation Regulatory Agency 4814 South 40 Street

Phoenix, Arizona 85040 Chairman Maricopa County Board of Supervisors 111 South Third Avenue

Phoenix, Arizona 85003

Mr. William F.

Conway

guidance, which includes standard Combustion Engineering Technical Specifica-tions (GETS),

as well as Regulatory Guide

1. 108 requirements.

Stated more simply, it appears to us that an error was made at some point in the licensing process and this surveillance requirement was dropped from the technical specifications on Unit 2, and thereafter replicated on the other units.

In light of the above, we request that you clarify whether or not Palo Verde Units 1, 2,

and 3 are periodically conducting the full load rejection testing?

If not, how does APS intend to address this apparent discrepancy with its documented commitments?

You are requested to review this matter and provide a written response within 60 days of your receipt of this letter.

This request for information affects fewer than 10 respondents.

Therefore, it is not subject to Office of Management and Budget review under Pub.

L.96-511.

Please contact us should you have any questions regarding this request.

Sincerely, Original siQQQ) f)y Charles M. Trammell, Sr. Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc:

See next page DISTRIBUTION

'-Docket, Files J

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Hr. William F.

Conway

guidance, which includes standard Combustion Engineeri g Technical Specifica-tions (GETS),

as well as Regulatory Guide

1. 108 requ ements.

Stated more simply, it appears to us that an err was made at some point in the licensing process and this surveillance re i rement was dropped from the technical specifications on Unit 2, and there ter replicated on the other units.

In light of the above, we request t t you clarify whether or not Palo Verde Units 1, 2, and 3 as periodically co ucting the full load rejection testing?

If not, how does APS intend to ddress this apparent discrepancy with its documented commitments?

You ar requested to review this matter and provide a written response within 60 d ys of your receipt of this letter."

This request for information affect fewer than 10 respondents.

Therefore, it is not subject to Office of Manage ent and Budget review under Pub.

L.96-511.

Please contact us should you hav any questions regarding this request.

Sincerely, Catherine H. Thompson, Project Manager Project Directorate V

Division of Reactor Projects III/IV/V Office of Nuclear Reactor Regulation cc:

See next pag DISTRIBUTION Docket Files TQuay ACRS (10)

NRC 8

LPDRs CThompson RZimmerman, RV PDV r/f BBoger PDV p/f

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