ML20056E339

Requests Concurrence W/Testing Program by 940115,to Support Outage Schedule Re EDG Upgrade Project

ML20056E339
Person / Time
Site:	Calvert Cliffs
Issue date:	08/17/1993
From:	Denton R BALTIMORE GAS & ELECTRIC CO.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9308230204
Download: ML20056E339 (6)

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BALTIMORE ,

GAS AND l ELECTRIC l

%, l 1650 CALVERT CUFFS PARKWAY LUSBY, MARYLAND 20657-4702 ROBERT E. DENTON VICE PRESIDENT j l

NUCLEAR ENERGY

, ( io) reo-4.ss I

. August 17,1993 U. S. Nuclear Regulatory Commission Washington,DC 20555 ,

I ATTENTION: Document Control Desk

SUBJECT:

Calvert Cliffs Nuclear Power Plant Unit Nos.1 & 2; Docket Nos. 50-317 & 50-318 Emercency Diesel Generator Uncrade Proicct

REFERENCE:

(a) Letter from H. Silver (NRC) to W.3. Wilgus (FPC), dated .

September 25,1989, C ystal River Unit 3 - Pre-Operational Testing l of the Upgraded Emergency Diesel Generator We are proposing to modify our existing Emergency Diesel Generators (EDGs) to improve their electrical capacity. This modification will provide additional margin for the electricalloading of the 4.16 kv safety related busses. In turn, this gives the operators flexibility in the addition of discretionary loads post-accident. The capacity upgrade is described in the Attachment. The upgrade is the same type as the one performed at Crystal River in 1990. At that time, the NRC Staff proposed a testing program to re-qualify the load capacity and reliability of the EDGs (Reference a).

We have reviewed that testing program and established a testing program almost identical to it. Our testing program is described in the Attachment.

We request that you review our testing program and concur that it will provide reasonable assurance c,f the load capacity and reliability of the upgraded EDGs. We intend to upgrade EDG No.11 during the spring 1994 refueling outage with the other two EDGs upgraded during subsequent outages.

Therefore, we request concurrence with our testing program by January 15,1994 to support the outage schedule.

Should you have any questions regarding this matter, we will be pleased to discuss them with you.

Very truly yours, 5

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. Document Control Desk August 17,1993 Page 2 cc: D. A. Brune, Esquire J. E. Silberg, Esquire R. A. Capra, NRC D. G. Mcdonald, Jr., NRC T. T. Martin, NRC P. R. Wilson, NRC R. I. McLean, DNR J. H. Walter, PSC i

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'. ATTACIIMENT (1) i EMERGENCY DIESEL GENERATOR UPGRADE

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DESCRIPTION ,

l We are planning to modify our existing Fairbanks-Morse diesel generators to improve their electrical capacity. The diesel engines provided to Calvert Cliffs were shipped in 1970 with a 300 HP/ cylinder i design. An engine conversion is now available which will improve the design of the engine to i 350 HP/ cylinder. The modifications to the diesel generator will involve: the pistons, cylinder liners, j air inlet check valves, turbochargers, blowers, injection nozzles, combustion air piping, and support systems. As a result of these modifications the following ratings will be achieved:

Ratine (existine) Ratine (Upgraded) Time Limit 0 -2500 kw 0 - 3000 kw Continuous 2501 -2700 kw 3001 -3300 kw 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> 2701 - 3000 kw 3301 -3500 kw 200 hour0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> 3501 - 3600 kw 30 minutes The capacity upgrade is being pursued to gain additional margin between the accident loads and the capacities of the machines. The emergency diesel generator upgrade consists of two distinct parts:

capacity upgrades and qualification testing. The capacity upgrade consists of the following: ,

• Upgraded design cylinderliners

> Upgraded design blowers

> Upgraded design pistons

> Larger turbochargers

> Upgraded design combustion air piping Included in the upgrade is an evaluation of the support systems for the diesel generators. The following systems will be evaluated to determine if modifications are required: Service Water System, Electrical Distribution System, Starting Air System, Fuel Oil System and the Ventilation System.

Based on preliminary engineering, it appears that none of these systems will require modification.

However, additional modifications to the diesel generator will include: a new lube oil heat exchanger tube bundle, a new air cooler heat exchanger tube bundle, a new intercooler heat exchanger, and newintercooler pipmg.

The second part of the upgrade will consist of the qualification testing program described below.

OUALIFICATION TESTING PROGRAM We intend to perform a preoperational testing program which meets the intent of Regulatory i Guide 1.9, Resision 3 (draft, April 1992) and IEEE 387 (1984). These guidance documents are not part of our licensing basis for the Fairbanks-Morse diesels and performance of this testing program does not commit us to any other portion of these documents. Because we intend to perform these tests on diesel generators which are already installed at Calvert Cliffs, and we are not modifying other parts of our onsite emergency power system, we will not be able to perform the tests exactly as the standard requires. Our testing program is described below and is almost identical to that proposed by the NRC Staff for Crystal River (Reference a) with the only exception being the 30 start and load tests. As described below (item 8), we will be performing 25 start snd load tests in accordance with Regulatory Guide 1.9, Revision 3 (draft, April 1992).

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. A*ITACIIMENT (1)

EMERGENCY DIESEL GENERATOR UPGRADE Factory Testine As described in IEEE-387, initial design qualification is accomplished by the performance of type tests, or analysis, or a combination of both. The proposed testing would utilize a modified diesel engine identical to the installed engines at Calvert Cliffs. We provided Fairbanks-Morse with our spare engine and they are performing the upgrade on that engine. Fairbanks-Morse has proposed a testing program similar to that performed on Crystal River's diesel generator. They propose running the engine at 3300 kW for 2000 hours0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br />, 3500 kW for 200 hours0.00231 days <br />0.0556 hours <br />3.306878e-4 weeks <br />7.61e-5 months <br /> and then perform an engine inspection. The engineering report produced from this testing would qualify the engine ratings given above. We consider the testing program recommended by the manufacturer to be adequate to meet the IEEE requirement. This is contingent upon the successful completion of the pre-operational testing described below.

Site Testine Regulatory Guide 1.9, Revision 3 (draft, April 1992) provides guidance for supplementing the requirements given in Section 7 of IEEE-387. Based on this Regulatog Guide and the IEEE Standard, we propose the following test program. 'Ihese tests will be conducted in-situ on each upgraded diesel generator. These tests will be performed in conjunction with the Baltimore Gas and Electric Company (BG&E) required post modification acceptance testing. Credit will be taken for any BG&E acceptance test that is essentially identical to a test in the pre-operational test program.

1. Start and Imad-Run Test

a. Start Test: We will demonstrate proper startup from ambient conditions and verify that the required design voltage and frequency is attained. For these tests, the diesel generator will be pre-lubricated, have pre-warmed oil and water circulating and will reach rated speed on a pre-specified schedule that is selected to minimize stress and wear.

b. Imad-Run Test: We will demonstrate the emergency load carrying capability of 90-1009c of its continuous rating (2700 to 3000 kW) for one hour. The loading and unloading of the diesel generator during this test will be gradual and based on a prescribed schedule that is selected to minimize stress and wear on the diesel generator.

2. Fast Start Test We will demonstrate that each diesel generator starts from ambient (pre-lubricated) conditions and reaches stable rated voltage and frequency within the limits and time defined in Technical Specification 4.8.1.1.2.a.4 and 4.8.1.1.2.c.

3. Combined Safety Iniection Actuation Sicnal and less-of-Offsite Power Test We will demonstrate that: (1) the emergency busses are de-energized and loads are shed from the emergency busses, (2) the diesel generator starts from its ambient (may be pre-lubricated) condition and attains the required rated voltage and frequency within the limits and time required by the plant Technical Specifications, (3) energizes the auto-connected loads through the load sequencer and, (4) operaies at least five minutes loaded with the auto connected loads.

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l A*ITACilMENT m EMERGENCY DIESEL GENERATOR UPGRADE

4. Sincle Load Rejection Test We will demonstrate the diesel generators capability to reject its largest single load (500 hp) and verify the voltage and frequency requirements are met.

5. Fullload Reiection Test We will demonstrate the capability of the diesel generator to reject a load equal to 90-100%

ofits continuous rating (approximately 2700-3000 kW). During this test we will verify that voltage requirements are met and that the diesel generator does not trip on overspeed.

6. Endurance and Marcin Test We will demonstrate the full-load carrying capability for an interval of 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, of which 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> will be at 3150 to 3300 kW (105-110% of the continuous rating) and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at a load of 2700-3000 kW (90-100% of the continuous rating). We will verify that voltage and frequency are maintained.

7. Hot Restart Test The hot restart functional capability at full load temperatures will be verified by starting the diesel generator, attaining the required vohage and frequency within the limits and time provided in the Technical Specifications, and operating loaded to 2700 - 3000 kW (90-100%

continuous rating) for at least an hour.

8. ReliabilityTests We will demonstrate that an acceptable level of reliability has been achieved on each diesel generator by performing 25 start and load tests as described in item 1 above without a failure.

Start and load failures are defimed by Regulatory Guide 1.108 and are in accordance with our existing reliability program. The number of tests was selected in accordance with Regulatory Guide 1.9, Resision 3 (draft, April 1992), Position 2.3.1. This position requires, "a minimum of 25 valid start and load demands in accordance with Regulatory Positions 2.2.2 and 2.2.3. . . ." Those regulatory positions require that a load-run test be performed and that we perform fast starts from standby conditions. We will perform the suggested 25 starts, however, to the extent possible they will be slow starts (in accordance with the manufacturers recommendations) from either hot or ambient conditions. This reduces the wear on the diesel generators caused by fast starts (Generic Letter 84-15) and tests the slow start circuitry. Slow starts will comprise the majority of our Technical Specification surveillance testF.

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3 ATTACIIMENT (1)

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. EMERGENCY DIESEL GENERATOR UPGRADE )

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1 To the extent that they apply, the starting and loading performed as part of the manufacturer ,

i recommended testing or surveillance testing will be counted toward the 25 start tests. Baltimore Gas 1 and Electric Company considers the testing program outlined in items 1, 2, 4, 5, 6, and 7 to l adequately demonstrate Operability of the diesel generator for Modes 4,5, and 6. Following these ,

tests, the diesel will be considered Operable for these Modes. While reliability testing is being l performed, the diesel generator may be under manual control and may not start immediately  !

i following a loss-of-offsite power. However, in Modes 4,5, and 6, time is available following a loss-of-

offsite power to manually start a diesel generator and restore power to the decay heat removal

systems. Prior to being considered Operable for Modes 1,2, and 3, the diesel generator will have ,

i successfully completed items 3 and 8. j

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CONCLUSION i

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We believe that the test program outlined above will demonstrate the capability and reliability of the l upgraded diesel generators. The test program was developed by balancing the NRC's guidance with j the merits of performing such an extensive test program. Additionally, with regard to test 8, an attempt has been made to satisfy the Regulatory Guide 1.9 guidance on the performance of 25 starts per machine without having a significant impact on the length of the refueling outage.

I At the completion of this. upgrade program, we will have diesel generators with more available margin than currently exists. Tnis will provide the operators with more flexibility during conditions

where the diesel generators are providing onsite power.

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