ML17346A619

Forwards Response to 840702 Generic Ltr 84-15 Re Improving & Maintaining Diesel Generator Reliability.Program Developed to Reduce Rapid Start Testing of Emergency Diesel Generators.Reliability of Each Diesel Generator Reported

ML17346A619
Person / Time
Site:	Turkey Point
Issue date:	11/06/1984
From:	Williams J FLORIDA POWER & LIGHT CO.
To:	Eisenhut D Office of Nuclear Reactor Regulation
References
GL-84-15, L-84-316, NUDOCS 8411090269
Download: ML17346A619 (11)

Text

REGULATORY FORMATION DISTRIBUTION SY EM (RIDS)

ACCESSION'BR'8411090269 DOC ~ DATE 84/11/06NOTARIZED NO DOCK FACIL:50-250 TUr key Point Planti Un)t 3i Florida Power and Light C 50.-'251 Turkey Point, Planti Unit 4i Flot ida Power~ and Light C 05000251 AUTH'AME AUTHOR AFFILIATION WILLIAMS'iJ'iH, F 1 oride Power. 8 Light Co, RECIP NAME'ECIPIENT AFFILIATION

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EISENHUT'<DE G, Division of Licensing

SUBJECT:

Forwar'ds r esponsel to 840702" Generic Ltr 84 15 re improving 8 maintainjng diesel generator reliabili,ty.Program developed to reduce rapid start testing of emergency diesel generators, Reliability of each diesel generator reported

DISTRIBUTION CODE; A056D COPIES RECEIVED! LTR ENCL SIZE'.

TITLE - OR Submittal:Fast Cold Star ts of Diesel Generators GL 83-41 (GL 84 15 NOTES:- 05000250 OL: 07/19/72 05000251 OL; 04/14/.73 RECIPIENT -COPIES RECIPIENT'D COPIES ID CODE/NAME>> LTTR ENCL CODE/NAME LTTR NRR ORB1 BC- 01>> 3 3 ENCL'NTERNAL:

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FLORIDA POWER & LIGHT COMPANY November 6, 1984 L-84-316 Office of Nuclear Reactor Regulation Attention: Mr. Darrell G. Eisenhut, Director Division of Licensing U. S. Nuclear Regulatory Coommission Washington, D. C. 20555

Dear Mr. Eisenhut:

Re: Turkey point Units 3 and 4 Docket Nos. 50-250 and 50-251 Generic Letter 84-15 Your letter dated July 2, 1984 requested that we respond to three items concerning improving and maintaining diesel generator reliability. Please find attached our response.

In addi tion, we have reviewed the model Technical Specification change you have attached regarding reducing the number of cold starts. We agree with the intent of proposed change and we plan on submitting a proposed amendment to the Turkey Point Technical Specifications as soon as time permits.

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

Group Vice President Nuclear Energy JWW/JEM/js Attachment cc: J. P. O'Reilly, Region II Harold F. Reis, Esquire PNS-LI-84-390-2 841i090269 5000250 PDR @DOCK; PD P

PEOPLE... SERVING PEOPLE

Res onse to Generic Letter 84-15 Reduction of Emer enc Diesel Generator Cold Fast Start Surveillance Tests Re uest Area 1:

1. Licensees are requested to describe their current programs to avoid cold fast start surveillance testing or their intended actions to reduce cold fast start surveillance testing for diesel generators.

Res onse 1:

No formal program existed to reduce rapid start testing of the Emergency Diesel Generators. An analysis of the rapid start tests since the beginning of 1982 has been performed. As a result of this analysis, FPRL developed a program containing the following aspects:

a. An Operations Department maintenance coordinator has been assigned to coordinate the performance of periodic maintenance with scheduled engine operability tests.

b. The method used to schedule Technical Specification operability tests will be changed to eliminate unnecessary periodic tests on the Emergency Diesel Generator. The present tracking system does not take credit for post maintenance operability checks performed during the surveillance interval. This results in unnecessary operability

'tests being performed.

c Engine operability tests are being performed at a 10 day interval.

The review of the engine start data has indicated that the tests should be conducted on a 30 day interval, based on the number'.of engine failures observed in the orevious 100 valid starts. The tracking program for engine starts did not take all valid starts into consideration. FPdcL plans to install a start counter on each Emergency Diesel Generator to track all valid engine starts.

Area 2: Diesel Generator Reliability Data Receuest2:

ao Licensees are requested to report the reliability of each diesel generator at their plant for its'ast 20 and 100 demands. This should include the number of failures in the last 20 and 100 valid demands, indicating the time history of these failures.

b. Licensees are requested to indicate whether they maintain a record which itemizes the demands and failures experienced by each diesel generator unit, in a manner outlined in Regulatory Guide 1.108 Position c.3.a for each diesel generator unit.

Response to Generic Letter 80-15 Page 2 c Licensees should also indicate whether a yearly data report is maintained for each diesel generator's reliability. Criteria for determining the reliability of diesel generators is as follows:

a. Valid demands and failures are determined in accordance with the recommendations of Regulatory Guide 1.108 Position c.2.e.

b. The reliability of each diesel generator will be calculated based on the number of failures in the last 100 valid demands.

~Res ense 2 ae ~ Failures Last //Failures Last Reliability 20 Starts 100 Starts "A" Emergency Diesel 1.0 Generator "B" Emergency Diesel .97 Generator The time history for each Emergency Diesel Generator (EDG) for the last 20 and 100 valid demands and failures follows:

IIAII EDGII 100th Start March 5, 1983 20th Start May 10, 1980 No failures in last 100 starts Data Date for last start September 18, 1980 BII ED 100th Start March 11, 1983 One failure to start in required 15 seconds November 17, 1983 One failure. in the air start system December 15, 1983 One failure of voltage regulator May 5, 1980 20th start May 9, 1980 No failures in last 20 starts Data date for last start September 27, 1980

Res onse to Generic Letter 80-15 Page 3 2 b. FPRL maintained a log that itemized Emergency Diesel Generator test starts and failures. However, the log did not include all valid starts. This resulted in an increased test frequency.

2 Ce FPRL does not prepare a yearly data report for each Diesel Generator's reliability.

Area 3: Diesel Generator Reliabilit Receuest 3a. Licensees are requested to describe their programs, if any, for attaining and maintaining a reliability goal for their diesel generators.

3b. Licensees are requested to comment on, and compare their existing program or any proposed program with the example performance specifications.

~Res onse:

3a. The following steps have, or will be taken by FPRL to enhance the reliability of the Emergency Diesel Generators.

A review of the diesel engine maintenance program has been conducted by FPRL Engineering and a consulting Technical Representative. As a result of this .review, an expanded maintenance program is being implemented.

2e A review of the engine operating procedures has been performed by Engineering and a consulting Technical Representative. One Operating Procedure has been eliminated as being detrimental to long term engine reliability. The data taking requirements for the remaining procedures have been substantially increased to improve performance monitoring of the engines.

30 FPRL is evaluating additional instrumentation for the engines to improve performance monitoring.

FPRL is evaluating the installation of an improved vibration damper and lube oil cooler on the engines.

5. An evaluation of vendor proposed modifications to improve reliability is being .performed by FPRL Engineering. The modifications include installation of a redundant air start system and high capacity turbo charger.

6. FPRL plans to have a consulting Technical Representative monitor engine performance during future eight hour full load tests.

7. FPRL Engineering will monitor engine performance by reviewing periodic operability test data.

Res onse to Generic Letter 80-15 Page 0

8. FPRL will develop a trending program of key engine parameters to predict potential problems.

D:c:007

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