ML18227B285

Submit Proposed Amendment to Facility Operating Licenses Which Relates to Surveillance Requirements for Diesel Generator Units Used as Onsite A.C. Power Source

ML18227B285
Person / Time
Site:	Turkey Point
Issue date:	09/08/1978
From:	Robert E. Uhrig Florida Power & Light Co
To:	Stello V Office of Nuclear Reactor Regulation
References
L-78-292
Download: ML18227B285 (20)

Text

REGULATORY INFORMATION DI TRIBUTION SY TEM'RID DISTRIBUTION FOR INCOMING MATERIAL 0-25 51 REC:

STELLO V NRC ORG:

UHRIG R.E FL PWR 8( LIGHT DOCDATE: 09/08/78 DATE 'RCVD: 09'/13/78 DOCTYPE:

LETTER NOTARIZED:

YES COPIES RECEIVED

SUBJECT:

LTR 3 ENCL 40 FORWARDING LIC NQS DPR-1 4 41 APPL FQR AMEND:

APPENDIX A TECH SPEC PROPOSED CHANGE CONCERNING REVI ION TO SURVEILLANCE REQUIREMENT FOR TklL= DIESEL GENERATOR UNITS UESED AS TIIE ONSITE A. C.

PWR SOURCE AT SUBJECT FACII ITY"S... NOTARIZED 09/08/78.

PLANT NAME: TURI<EY PT 03 TURKEY PT 64 REVIEWER INITIAL:

XJM DISTAIBUTER INITIAL:

es4Ht4~s4~4HHHt>>4k+%>>l DISTRIBUTION OF THIS NATERIAL IS AS FOLLOWS ONGITE EMERGENCY POWER SYSTEMS.

<DISTRIBUTION CODE AO15)

'FOR ACTION:

INTERNAL:

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',MIPC%<W/ENCL AUXILIARYSYS BR>~W/ENCL AD FOR SYS 8( PROJ4>W/ENCL REACTOR SAFETY BR+%W/ENCL

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P,O. BOX 013100, MIAMI, FL 33101 FLORIDAPOWER & LIGHTCOMPANY September 8,

1978 L-78-292 Director of Nuclear Reactor Regulation Attention:

Nr. Victor Stello, Director Division of Operating Reactors U.

S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Nr. Stello:

Re:

Turkey Point Units 3 and 4

Docket. Nos.

50-250 and 50-251 Proposed Amendment to Facilit O eratin Licenses DPR-31 and DPR-41 In accordance with 10 CFR 50.30, Florida Power 6 Light, Company submits hhrewith three (3) signed originals and forty (40) copies of request to amend Appendix A of Facility Operating Licenses DPR-31 and 41.

This proposed amendment. relates to the surveillance requirements for the diesel generator units used as the onsite A.C. power source at Turkey Point Units 3 and 4. It is being submitted at the request of members of the NRC staff.

The staff request specified that our proposed technical specifica-tions were to incorporate the requirements of Regulatory Guide 1.108 "Periodic Testing of Diesel Generator Units Used as Onsite Electric Power Systems at Nuclear Power Plants."

Based upon the information available to us at, that time, at a meeting with members of the NRC staff on June 5 1978, FPL agreed to comply with the testing require-ments contained in Regulatory Guide 1.108 provided that these require-ments would not necessitate any design changes.

FPL has since reviewed in detail the Regulatory Positions contained in the guide; the results of that, review and the manner in which we comply or will comply are contained in Attachment A.

Based upon our subsequent review and discussions with the diesel engine manufacturer, FPL believes that the requirements for testing frequency contained in Regulatory Position C.2.d should be modified for Turkey Point Units 3 and 4.

Regulatory Guide 1.108 was originally issuIhd in August 1977.

Its inception therefore came several years after the diesel generator units at Turkey Point had been procured and installed and the Operating Licenses issued.

Recent correspondence with our diesel engine manufacturer indicates that the testing requirements set forth in the guide are excessive and, if implemented, may lead to pre-mature failures.

Since it. is in the best interest of all concerned parties that diesel engine surveillance enhance xather than degrade engine reliability, representatives from FPL and the diesel engine man-facturer would be willing to meet with the NRC for further discussion 7821$ P~+9 PEOPLE... SERVING PEOPL'E

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Mr. Victor Stello, Director of this issue.

The proposed technica1 specification changes are shown on the accom-panying technical specification pages contained in Attachment B

bearing the date of this letter in. the lower right hand corner.

These proposed changes have been reviewed by the Turkey Point Plant Nuclear Safety Committee and the Florida Power 6 Light Company Nuclear Review Board, They have concluded that. this amendment does not in-volve an unreviewed safety question.

They have further concluded that any additional testing requirements beyond those contained in Attach-ment B may constitute an.unreviewed safety quests;on due to the poten-ial for degraded reliability of the diesel generator units.

FPL believes that the proposed amendment is fee exempt since it has been requested by the Commission and, as presented by FPL, has only minor safety significance.

Therefore no amendment, fee is required.

Very uly yours, Robert E. Uhrig Vice President REU:LLL:MAS:pit Attachments cc:

Mr. Games P. 0"Reilly., Region XX Harold F. Reis, Esquire

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ATTACHI1ENT A Re:

Turkey Point Units 3

& 4 Docket Nos. 50-250 and 50-251 Evaluation of Proposed Technical Specifications Diesel Generator Units C.2.a(1)

Presently required by TS 4.8.l.b.

C.2.a(2) lie concur with this section.

C.2.a(3)

C.2.a(4)

FPL proposes to include this as an 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test.

The diesel reaches equilibrium in 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> or less.

Eight hours provides a factor of 4 over the time required to reach equilibrium temperature.

Since we must perform both diesel generator and electrical switchgear preventative maintenance each outage, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run would delay these items and therefore add unnecessary forced outage time.

Me concur with the verification of generator capability to withstand the loss of the largest single load without tripping.

Our D/G sets were designed to accommodate this degree of load rejection.

The loss of all load is an unnecessary test and poses a risk of significant damage to the D/G.

However, it has been demonstrated once by preoperational test.

To ensure that any control or governor system degradation is detected, we will add the voltage and frequency requirements suggested by the =NRC, i.e.,

4160 V + 624 volts

(+ 15%); 60 HZ + 1..2 HZ (+ 2/), to the loss of the largest single load test.

C.2.a(5)

C.2.a(6)

C.2.a(7)

Although the vendor has stated that they have never experienced hot restart (vapor lock) failures, we agree to do a hot start within 15 minutes and load the D/G to full load rating

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maintaining safety-related components in line-ups capable of producing the design accident loading sequence would preclude RCS/ECCS maintenance and delay each refueling.

Therefore, we maintain that loading the D/G to full lqad meets the intent of C.2.a.(5) without unnecessarily delaying plant outages.

Also, the sequencing controls are not affected in any manner by the temperature conditions of the D/G and this portion of the suggested testing merely duplicates C.2.a(2).

In order to do the monthly load test, it is necessary to synchronize the D/G and pick up load (which is greater than emergency load).

This demonstrated synchronization.

At the end of the monthly test the load is transferred to off-site power and the D/G is shutdown (after opening the output breaker) and returned to a standby line up.

Thus, the 18 month test is redundant to the already existing monthly periodic test.

Not applicable.

By design, the Turkey Point engines have one fuel supply system.

ATTACHMENT A PAGE 2 C.2.a(8)

We maintain that this item should not be, required because the necessary demonstration would include a rejection of full load by the diesel generator.

As discussed under C.2.a(4)

above,

.full load rejection poses a risk of significant damage to the diesel generator.

C.2.b C.2.c(l)

C.2.c(2)

C.2. d C.3. b We concur with most of this section.

However, we do not agree that the "every 10 years" portion is necessary.

This is in reference to a

design feature which is tested during the preoperational test program.

We already have an administrative design control system, including retest requirements, as required by various NRC regulations to ensure that system design is not degraded.

Me concur with this item and include a requirement for verifying time for starting the D/G.

We concur with this item.

This requires assuming load at the "maximum practical rate".

Since our.system requires manual

loading, we interpret this to be the maximum, safe loading rate to ensure that the D/G is not over loaded.

It should be noted that our standard practice has been* to. load. the 'D/G 'expeditiously, and in any case it is impossible to even approach the design accident loading rate of about 2000 Kw in 33 seconds (FSAR Table 8.2-3).

We feel that the proposed increased testing frequencies are very undesirable and may lead to eventual degradation of the on-site emergency power system.

Our diesel engine manufacturer shares our position that more frequent emergency starting creates a strong likelihood that the engine rel.iability will be degraded.

Emergency startup is known to be one of the most stressful and wear producing evolutions possible and this section potentially increases the number of fast cold starts and rapid loadings by a factor of 10 over existing requirements.

We would like to suggest that the NRC use an existing program which.

specifically addresses diesel generator reliability.

The NRC Division of Inspection and Enforcement reviews all Licensee Event Reports and ensures that corrective action is prompt, appropriate and addresses generic or repeated failures. If the NRC feels D/G reliability is not being properly addressed, then an appropriate action might be to more fully implement the existing program, not to impose additional tests on equiyment.

Regulatory Guide 1.108 reporting requirements are not the same as our present reporting requirements which are based on Regulatory Guide l. 16.

Me plan to continue reporting in accordance with Regulatory Guide 1.16 as implemented by Technical Specification 6.9.2.

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ATTACHNENT B Re:

Turkey Point Units 3 and 4

Oocket Nos.

50-250 and 50-251 Proposed Techni cal Speci ficati ons Diesel Generator Units

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TABLE 4.1-2 (Sheet 2 of 3)

MINIMUMFREQUENCIES FOR EQUIPMENT AND SAMPLING TESTS ll.

Reactor Coolant Sys-Evaluate tern Leakage Daily NA 12.

13.

14.

15.

Spent Fuel Pit Secondary Coolant Vent Gas P'articulates 5

Fire Protection Pump

& Power Supply Boron Concentration I-131 Concentration I-131

& Particulate Activity Operable Prior to refueling.

Weekly*g Weekly*

Monthly NA.

10 10 16.

Turbine Stop and Con-trol Valves, Reheater Stop and Intercept Valves Closure Monthly***

45 17.

LP Turbine Rotor Inspection (w/o rotor disassembly)

V, MT, PT Every 5 Years 6 Years 18.

Spent Fuel**

Cask Crane Interlocks Functioning Within 7 days of using crane to lift spent fuel cask 7 days when.cran is being used to maneuver spent fue3 cask r

wF N.A. during cold or. refueling. shutdowns.

The speCified tests; however shall be performed prior.to heatup above 200 F.

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"When activity exceeds 10% of specification,.frequency shall be:.changed t'o daily.

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• >In the interim period until-t'e. spent fuel cask cr'ane interlocks are installed (instal-lation is to be completed no later than June.1977) the following controls shall be used to prevent movement of the cask over spent fuel:

l.

Indexing of the crane and trolley will 'be implemented.

2.

Once properly positioned, the respective crane bridge and trolley drives will be de-energized as appropriate.

3.

In addition, a mechanical bumper will be installed to limit trolley travel in the westward direction, such that movement of the spent fuel shipping cask over spent fuel. is.prevented.

9/8/78

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4.8 Et1ERGENCY POHER SYSTEV PERIODIC TESTS

~ab ective:

Applies to periodic testing and surveillance requirements of the mergency power system.

To verify that the emergency power system will respond promptly and properly.

The fol.lowing tests and surveillance shall be performed as stated:

1.

Diesel Generator Each diesel generator shall be demonstrated OPERABLE:

a.

At least once per 31 days by:

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Verifying the fuel level in the day and engine-mounted fuel tank.

2.

Verifying the fuel level in the fuel storage tank.

I 3.

Verifying a fuel transfer pump can be started and transfers fuel from the Diesel Oil Storage Tank to the Day Tank.

4. 'erifying the diesel starts from ambient condition and accelerates to provide a nominal 60 Hz frequency in

< 15 seconds.

5.

Verifying the generator is synchronized, loaded to

> 2500 kw within 10 minutes and operates for

> 60 minutes.

C b.

At least once per 92 days by verifying that, a sample of, diesel fuel from the fuel storage tank is within accept-able limits when checked for viscosity, water and sediment.

c.

At least once per 18 months by:

1.

Subjecting the diesel to an inspection in conjunction with its manufacturer's recommendations for this class of standby service.

2.

Verifying the generator capability to reject a load of > 200 kw without exceeding 4160 V + 624 V and 60 Hz + 1.2 Hz.

3.

Simulating a loss of offsite power and a safety injection signal, and.

pv a)

Verifying de-energization and load shedding from 4160 Volt busses.

4.8-1 9/8/78

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b)

Verifying the diesels start from ambient condition on the auto-start signal, energize the 4160 volt

busses, energize appropriate emergency loads through the load sequencing

system, and operate for > 5 minutes.

4.

Verifying the diesel generator operates for a 1'east 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.

During the first two hours of this test, the diesel generator shall be loaded to

> 2750 kw and during the remaining 6 hours6.944444e-5 days <br />0.00167 hours <br />9.920635e-6 weeks <br />2.283e-6 months <br /> the load shall be

> 2500 kw.

Within 15 minutes after completing the 8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> test, repeat Specification 4.8.1.a.5.

5.

Verifying that the auto-connected loads to each diesel generator do not exceed 2750 kw.

2.

Station Batteries a.

The pilot cell specific gravity shall be read and recorded daily.

The pilot cell shall be rotated on a

monthly basis.

b.

Monthly the battery shall be given an equalizing charge, and afterwards specific gr'avity and voltage readings shall be taken and recorded for each cell..

Water shall be added to restore normal level and total water use shall be recorded.

Complete visual inspection of'atteries shall be made monthly.

c.

quarterly detailed visual inspection shall be made of chargers.-

d.

Annually connections shall be checked, for tightness and anti-corrosion coating shall be applied to interconnections.

e.

Perform load test annually.

4.8-2 g/8/78

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STATE OF FLORIDA

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COUNTY OF DADE

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ss Robert E. Uhrig, being first duly sworn, deposes and says:

That he is a Vice President of Florida Power 6 Light Company, the Licensee herein;

-That he has executed the foregoing document; that the state-ments made in this said 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.

Robert E. Uhrig Subscribed and sworn to before me this day of NOTARY PUBLlC, in and for the county of Dade, State of Florida NOTA' e98tlC STAW~ OF FLORlDA et tARGG MY COMlAISS!DN

~ EKPAltS lAARCH 27.

l932 Ny commi'ssion.'expires:

eoNDED TNRU NAYNARD 80NDolG 4QfN

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