LR-N980155, Forwards Addl Rev to SR 4.8.1.1.2.f & Change to Definition of Standby Conditions Proposed in 960925 Submittal Re EDG Testing
| ML18106B059 | |
| Person / Time | |
|---|---|
| Site: | Salem  |
| Issue date: | 02/08/1999 |
| From: | Storz L Public Service Enterprise Group |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| Shared Package | |
| ML18106B060 | List: |
| References | |
| LR-N980155, NUDOCS 9902180306 | |
| Download: ML18106B059 (10) | |
Text
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Louis F. Storz Public Service Electric and Gas Company Public Service Electric* and Gas Company P.O. Box 236, Hancocks Bridge, NJ 08038 609-339-5700
~13nior Vice President - Nuclear Operations FEB 8*1999 LR-N980155 LCR S95-36 Rev. 2 United States Nuclear Regulatory Commission Document Control Desk Washington, DC 20555 REVISION TO REQUEST FOR CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERATOR TESTING SALEM GENERATING STATION UNIT NOS. 1 AND 2 FACILITY OPERATING LICENSES Dl?R-('O AND DPR-75 DOCKET NOS. 50-272 AND 50-311 1
Gentlemen:
In accordance with 1 OCFR50.90, on September 25, 1996, Public Service Electric and Gas (PSE&G) submitted letter LR-N96228, requesting a revision to the Technical Specifications (TS) for the Salem Generating Station Unit Nos. 1 and
- 2. In accordance with 10CFR50.91(b)(1), a copy of this submittal was sent to the State of New Jersey.
The proposed TS changes revise Specification 3/4.8.1, "Electrical Power Systems," to change the Emergency Diesel Generator (EOG) voltage and frequency limits as a result of updated EOG load calculations and ambiguity in the testing methodology for EOG start timing.
The proposed changes were evaluated in accordance with 1 OCFR50.91 (a)(1 ),
using the criteria in 1 OCFR50.92(c) and PSE&G concluded that the request involved no significant hazards consideration~.* This letter provides an additional
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revision to surveillance requirement (SR) 4.8.1.1.2.f and a change to the definition of 'standby conditions' proposed in the previous submittal. The information provided in this submittal does not impact the significant hazards considerations. Attachment 1 to this letter provides the description of the change to the surveillance requirements. Attachment 2 provides the new proposed TS
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SR 4.8.1.1.2.f and change to the definition of 'standby conditions', the other
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changes to TS pages 3/4 8-5 and B 3/4 8-1 pr~viously submitted under LR-'
N96228 remain valid and are not affected by this revision.
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9902180306 990208
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- ADOCK.05000272 P
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Document Control Desk LR-N980155 2
FEB 8 1999
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Should you have any questions regarding this request, we will be pleased to discuss them with you.
Attachments (2) c Mr. Hubert J. Miller, Administrator - Region I U. S. Nuclear Regulatory Commission 475 Allendale Road King of Prussia, PA 19406 Mr. P. Milano, Licensing Project Manager - Salem U.S. Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike Mail Stop 14E21 Rockville, MD 20852 Mr. S. Morris (X24)
USNRC Senior Resident Inspector - Salem Mr. K. Tosch, Manager, IV Bureau of Nuclear Engineering 33 Arctic Parkway P.O. Box 415 Trenton, NJ 08625 95-4933
STATE OF NEW JERSEY
)
COUNTY OF SALEM
)
) SS.
REF: LR-N980155 LCR S95-36, Rev. 2 L F. Storz, being duly sworn according to law deposes and says:
I am Senior Vice President - Nuclear Operations of Public Service Electric and Gas Company, and as such, I find the matters set forth in the above referenced letter, concerning Salem Generating Station, Unit Nos. 1 and 2, are true to the best of my knowledge, information and belief.
. Subs*c.-ibed and Sworn to before me
. this_ 8~ ~
day of ~:h..6-v,1a;,0 1999
- -~L}~
- Notary Public of New Jersey DELORIS D. HADDEN Notary Public of New Jersey My Commission Expires My Commission expires on -----"-0""""-:i.-'-?-'a.-'-?0-'-0-'I')------
Document Control Desk LR-N980155 3
BC Senior Vice President - Nuclear Engineering (N 19)
Senior Vice President - Nuclear Operations (X04)
General Manager - Salem Operations (S05)
Director - QA/NSR (X01)
Program Manager - NRB (N38)
Manager - Business Planning & Co-Owner Affairs (N18)
J. J. Keenan, Esq. (N21)
J. Geissner (S01)
K. Fliescher (SOB)
Records Management (N21)
Microfilm Copy File Nos. 1.2.1 (Salem), 2.3 (LCR S95-36)
FEB 8 1999J LR-N980155 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERA TOR TESTING In submittal LR-N96228, dated September 25, 1996, Public Service Electric and Gas (PSE&G) requested a change to Emergency Diesel Generator (EOG) surveillance requirement (SR) 4.8.1.1.2.f. This proposed change to the hot restart SR 4.8.1.1.2.f in letter LR-N96228 was to modify the surveillance requirement from:
Current SR 4.8.1.1.2.f "At least once per 18 months, the following test shall be performed within 5 minutes of diesel shutdown after the diesel has operated for at least two hours at 2500-2600 kw**:
Verifying the diesel starts and accelerates to 900 rpm in less than or equal to 10 seconds*. The generator voltage and frequency shall be 2::
3950 volts and =::; 4580 volts and 60 +/- 1.2 Hz within 13 seconds after the start signal."
Proposed Revision contained in LR-N96228 (second paragraph of SR)
"... Verifying the diesel generator starts from standby conditions*
and achieves ~ 3910 volts and ~ 58.8 Hz in ~ 13 seconds, and subsequently achieves steady state voltage of~ 3910 and ~ 4400 volts and frequency of 60 +/- 1.2 Hz."
The basis for the changes to the voltage, frequency and start timing changes is provided in letter LR-N96228 and is not affected by the change to SR 4.8.1.1.2.f proposed in this letter.
Upon subsequent review of the proposed changes to SR 4.8.1.1.2.f contained in submittal LR-N96228, PSE&G determined that revising the SR to perform the hot restart start from 'standby conditions' was in error. Since the hot restart test is required to be performed within 5 minutes of running the EOG for two hours at 2500-2600 kw, the EOG jacket water and lube oil temperatures would still be at the running temperatures when the EOG would be required to be started by the proposed surveillance requirement. There is insufficient time for the EOG to cool down to 'standby conditions' prior to having to start the EOG to meet the loading time requirements of SR 4.8.1.1.2.f. Since the purpose of the hot restart surveillance is to verify the ability of the EOG to start from a hot condition, such 1of3 LR-N980155 as subsequent to shutdown from normal surveillances, PSE&G proposes to r~vise S.R 4.8.1.1.2.f as follows (changes to current SR indicated in bold):
"....Verifying the diesel generator starts and achieves ~ 3910 volts and
> 58.8 Hz in < 13 seconds, and subsequently achieves steady state voltage of~ 3910 and~ 4400 volts and frequency of 60+/-1.2 Hz."
The above proposed change to SR 4.8.1.1.2.f modifies the request contained in letter LR-N96228 by removing the requirement to start the EOG from a 'standby condition.'
In addition to the revision to proposed changes to SR 4.8.1.1.2.f, PSE&G is also proposing to revise the definition of the term 'standby conditions' from the one proposed in letter LR-N96228. In letter LR-N96228 the term 'standby condition'
- is defined in the proposed changes to bases section 3/4.8.1 and 3/4.8.2 as follows:
'Standby condition' for the purpose of defining the condition of the engine immediately prior to starting for surveillance requirements requires that the jacket water and lube oil are within the temperature bands controlled by the automatic heaters.
As discussed in LR-N96228, SR 4.8.1.1.2.a.2 for the monthly start and load testing of the EOGs is being revised to state the EOGs are started from 'standby conditions'. Starting the EOGs from a 'standby condition' during the monthly surveillance testing is appropriate and is also consistent with the surveillance requirements in the improved "Standard Technical Specifications Westinghouse Plants," NUREG-1431 (ITS). However, if SR 4.8.1.1.2.a.2 is being performed to comply with the TS action statement (TSAS) requirements b, c, and d of Limiting Condition of Operation (LCO) 3.8.1.1, the EOGs may not always be in their
'standby condition' as defined above. TSAS b of LCO 3.8.1.1 requires that the remaining EOGs be demonstrated operable by performing SR 4.8.1.1.2.a.2 within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />. TSAS c and d of LCO 3.8.1.1 requires that the remaining EOGs to be demonstrated operable by performing SR 4.8.1.1.2.a.2 within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />. In the event that one of the operable EDGs had just completed surveillance testing prior to entering either TSAS b, c, or d of LCO 3.8.1.1, this EOG may not have sufficient time to cool down to 'standby conditions' as defined above prior to exceeding the TSAS time of either 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> or 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> to perform SR 4.8.1.1.2.a.2.
The purpose of performing SR 4.8.1.1.2.a.2 under the TSAS is to ensure the operability of the remaining EOGs. Waiting for an EOG to cool down to 'standby conditions' as defined above to comply with the initial conditions of the surveillance requirement while being in an action statement may cause the plant 2 of 3 LR-N980155 to endure unnecessary hardship and may result in a failure to comply with the tir:ne requirements of the action statements. Therefore, PSE&G proposes to revise the definition of 'standby condition' to define the lube oil system standby temperature band from 100 to 170°F and remove the jacket water system from the definition. The change to the definition of standby condition is as follows:
"'Standby condition' for the purpose of defining the condition of the engine immediately prior to starting for surveillance requirements requires that the lube oil temperature be between 100 °F and 170 °F."
The lower limit for lube oil temperature is consistent with current operational limits. The upper limit for lube oil temperature is similar to the definition of standby conditions in the Diablo Canyon Technical Specifications. The Diablo Canyon EDGs are the same manufacturer and type engines. Based on a review of approximately 200 starts of the Salem EDGs (including monthly surveillance tests, maintenance runs, and hot restart testing), starting times of the diesels do not appear to be sensitive to initial lube oil temperature. Additionally, the 170 °F temperature is below the nominal setpoint of the lube oil temperature control valve.
The engine keep-warm system consists of a lube oil circulating and heating system. This system continuously circulates engine oil and heats the oil to allow the engines to start and accept load in the times required by the Technical Specifications. Because this system is in constant circulation, there is good indication of the bulk oil temperatures in the engine using installed instrumentation. In addition to the lube oil circulating and heating system, jacket-water heaters (block heaters) are used to maintain the jacket water in the engines above 90 degrees. Prior to the engine starting, jacket water is not circulated. There are no installed temperature indications that allow for readout of the jacket water temperature in the engine. Local instrumentation is on uninsulated piping external to the engine (see attached drawing). With the engine in standby, the local installed indications of jacket water temperature do not accurately reflect temperatures in the engine. Therefore, use of the installed jacket water temperature indications to determine engine standby is not appropriate. This position was agreed to by the engine vendor. The current Technical Specification Bases define engine operability in terms of lube oil temperature.
The changes to SR 4.8.1.1.2.f and the definition of 'standby conditions' proposed in this submittal do not impact or change the significant hazards evaluation provided in LR-N96228, dated September 25, 1996. PSE&G continues to conclude that the proposed changes to the TS do not involve a significant hazards consideration.
3 of 3 LR-N980155 SALEM GENERATING STATION UNIT NOS.1AND2 FACILITY OPERATING LICENSES DPR-70 AND DPR-75 DOCKET NOS. 50-272 AND 50-311 CHANGE TO TECHNICAL SPECIFICATIONS EMERGENCY DIESEL GENERATOR TESTING TECHNICAL SPECIFICATION PAGES WITH PROPOSED CHANGES The following Technical Specifications for Facility Operating License No. DPR-70 are affected by this change request:
Technical Specification 4.8.1.1.2.f B 3/4.8.1 and 3/4.8.2 Page 3/4 8-5 B 3/4 8-1 The following Technical Specifications for Facility Operating License No. DPR-75 are affected by this change request:
Technical Specification 4.8.1.1.2.f B 3/4.8.1 and 3/4.8.2 Page 3/4 8-5 B 3/4 8-1 LR-N980155 Revised. Insert C: (changes in bold from LR-N96228)
The minimum voltage and frequency stated in the Surveillance Requirements (SR) are those necessary to ensure the Emergency Diesel Generator (EOG) can accept Design Basis Accident (OBA) loading while maintaining acceptable voltage and frequency levels. Stable operation at the nominal voltage and frequency values is also essential in establishing EOG OPERABILITY, but a time constraint is not imposed. The lack of a time constraint is based on the fact that a typical EOG will experience a period of voltage and frequency oscillations prior to reaching steady state operation if these oscillations are not dampened out by load application. In lieu of a time constraint in the SR, controls will be provided to monitor and trend the actual time to reach stable operation within the band as a means of ensuring there is no voltage regulator or governor degradation that could cause an EOG to become inoperable.
"Standby condition" for the purpose of defining the condition of the engine immediately prior to starting for surveillance requirements requires that the lube oil temperature be between 100 °F and 170 °F. The minimum lube oil temperature for an OPERABLE diesel is 100 °F.
The thirteen second time requirement for the Emergency Diesel Generator to reach rated voltage and frequency was originally based on a Westinghouse assumption of fifteen seconds that included the delay time between the occurrence of the incident and the application of electrical power to the first sequenced safeguards pump (BURL-3011, dated November 13, 1974) and included an instrument response time of two seconds (BURL-1531, dated July 27, 1970). The times specified in UFSAR Section 15.4 bound the thirteen seconds specified in the TS.
The narrower band for frequency specified for testing performed in steady state isochronous operation will ensure the EOG will not be run in an overloaded condition (steady state) during accident conditions. Steady state is assumed to be achieved after one minute of operation in the isochronous mode with all required loads sequenced on the bus.
The narrower band for steady state voltage is specified for operation when the EOG is not synchronized to the grid to ensure the voltage regulator will protect driven equipment from over-voltages during accident conditions. Procedural controls will ensure that equipment voltages are maintained within acceptable limits during testing when paralleled to the grid.
LR-N980155 The wider band for frequency is appropriate for testing done with the governor in the droop mode. Likewise the wider band for voltage is appropriate when paralleled to the grid.
All voltages and frequencies specified in SR 4.8.1.1.2 are representative of the analytical values and do not account for postulated instrument inaccuracy.
Instrument inaccuracies for EOG voltage and frequency are administratively controlled.
Preventive maintenance includes those activities (including pre-test inspections, measurements, adjustments and preparations) performed to maintain an otherwise OPERABLE EOG in an OPERABLE status. Corrective maintenance includes those activities required to correct a condition that would cause the EOG to be inoperable.
Insert 0:
Verifying the diesel generator starts and achieves~ 3910 volts and ~ 58.8 Hz in
~ 13 seconds, and subsequently achieves steady state voltage of~ 3910 and ~
4400 volts and frequency of 60 +/- 1.2 Hz.