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Application to Amend Tech Specs,Changing Testing & Surveillance Requirements to Prevent Overload Testing of Diesel Generators.Class III Fee Encl
	ML20062D912
Person / Time
Site:	Farley
Issue date:	08/03/1982
From:	Clayton F; ALABAMA POWER CO.
To:	Varga S; Office of Nuclear Reactor Regulation
Shared Package
ML20062D918	List: ML20062D912; ML20062D921;
References
	NUDOCS 8208060263
	Download: ML20062D912 (9)
	v • d • e

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Malling Address Allbams Power Company 600 North 18th Street Post Office Box 2341 Birmingham, Alabama 35291 Telepheno 205 783-6081 F. L Clayton, Jr. b R n" l' c O y "' AlabamaPower the South ($(1 &WlGC Systern August 3, 1982

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Docket Nos. 50-348 50-364 u

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Director, Nuclear Reactor Regulation U. S. Nuclear Regulatory Commission Washington, D. C. 20555 Attention: Mr. S. A. Varga Joseph M. Farley Nuclear Plant - Units 1 and 2 Diesel Generator Technical Specification Change Request Gentlemen:

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Based on implementation of recently issued amendments to the Joseph M. Farley Nuclear Plant Technical Specifications, a problem has been identified concerning overload testing of the diesel gene _rators. The performance testing to overload conditions of the diesel generators was originally required by Section 4.8.1.1.2.c.7. for a period of two (2) hours. Alabama Power Company requested in an October 28, 1981 submittal that the overload test be omitted and replaced with a 24-hour test at the continuous rating. The NRC imposed a 24-hour overload test in Section 4.8.1.1.2.c.5. of Amendment No. 26 to the Unit 1 Technical Specifications and subsequently imposed the s wa test in Amendment No. 13 to the Unit 2 Technical Specifications. The NRC change requires the diesel generators to be load tested for 24 hours2.777778e-4 days 0.00667 hours 3.968254e-5 weeks 9.132e-6 months at the 2000-hour rating. This change was based on the fact that the estimated load on diesel generators 1-2A and 1C approaches the 2000-hour rating per FSAR Table 8.3-2 events 1, 2, 3 and 4 for two-unit operation.

In order to implement this new test requirement Alabama Power Company contacted the diesel generator manufacturer for assistance. The manufac-turer agreed with the need for a 24-hour test but recommended that the test be conducted at 60-90% of the continuous load rating rather than at the 2000-hour load rating. The manufacturer emphasized that the diesel genera-tors will operate for at least 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months at the 2000-hour rating but stated that load testing at greater than 60-90% of continuous load does not contri-bute to the assurance of dependability or longevity of the diesel genera-tors. Therefore, the 24-hour test at the 2000-hour load rating exposes the diesel generators to an unnecessarily high loading without concomitant gn og benefits. v 8208060263 820803 hl.sh DR ADOCK 05000 0.d ,g

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Mr. S. A. Varga August 3, 1982 Director, Nuclear Reactor Regulation Page 2 U. S. Nuclear Regulatory Commission Since Alabama Power Company is in general agreement with the NRC philosophy of testing the diesel generators at the estimated accident load conditions and since the manufacturer's recommendations are equally impor-tant to assure long-term operability of the diesel generators, a more representative test requirement has been developed to satisfy both points of view and establish the optimal assurance of diesel generator operability.

The proposed Technical Specification change contains the following test program:

1. Represent the initial accident loading conditions by operating the diesel generators at their maximum calculated accident load conditions or the continuous load rating, whichever is greater, for 2 hours2.314815e-5 days 5.555556e-4 hours 3.306878e-6 weeks 7.61e-7 months of the 24-hour test.

2. Represent the long-term loading conditions occurring when one of the nine operating river water pumps is manually tripped (only two river water pumps per unit are needed to satisfy accident analysis assumptions). This is accomplished by operating the diesel generators for the remaining 22 hours2.546296e-4 days 0.00611 hours 3.637566e-5 weeks 8.371e-6 months at the continuous load rating.

3. Following the 24-hour test, reduce load, trip the diesel generator and demonstrate hot restart capability within ten minutes.

The above proposed test procedure represents actual estimated load conditions and satisfies most of the manufacturer's recommendations for preventing excessive testing. The detailed technical and safety evaluation of the proposed test procedure is contained in Attachment 1 and the proposed Technical Specification change is contained in Attachment 2.

In conclusion, the proposed changes to Technical Specification 4.8.1.1.2.c.5 have been made to provide the appropriate testing and surveillance requirements at Joseph M. Farley Nuclear Plant such that the highest assurance of safety is achieved. Alabama Power Company's Plant Operations Review Committee has reviewed these proposed changes to the Technical Specifications and has determined that the changes do not involve an unreviewed safety question as shown in the attached safety evaluation.

The Nuclear Operations Review board is scheduled to review these changes at the next meeting.

This proposed amendment is designated as Class III for Unit I and Class I for Unit 2 in accordance with 10CFR170.22 requirements. Enclosed is a check for $4,400.00 to cover the total amount of fees required.

- - - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ ___ _____ _ ___________ _ _ _ ___________ _ ___ _j

i Mr. S. A. Varga August 3, 1982 Director, Nuclear Reactor Regulation Page 3 ;

U. S. Nucle?.r Regulatory Commission In accordance with 10CFR50.30(c)(1)(1), three signed originals and forty (40) additional copies of the proposed changes are enclosed.

Yours very truly f

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F. L. Clayton, Jr.

FLCJr/GGY:jc-D18 Attachments cc: Mr. R. A. Thomas SWORN TO AND SUBSCRIBED BEFORE ME

, Mr. G. F. Trowbridge THIS [f&f DAY OF /pt auf,1982.

Mr. J. P. O'Reilly 'v Mr. E. A. Reeves / f, p. ,

Mr. W. H. Bradford (]#ew u - 6 . (4t.1 4 , u j9" sr Notary PuBtic My Commission Expires:

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ATTACHMENT 1 Safety Evaluation for Proposed Changes to the FNP-1 and 2 Technical Specifications Section 4.8.1.1.2.c.5.

I. BACKGROUND During the NRC review process of the proposed changes to the J. M.

Farley Nuclear Plant Diesel Generator Technical Specifications Section 3/4.8.1.1 submitted by Alabama Power Company letter dated October 28, 1981, the NRC staff changed paragraph 4.8.1.1.2.c.5. to require the diesel generator 24-hour load tests to be conducted at the 2000-hour rating vice the continuous rating. The NRC staff required this change because the estimated load on diesel generator 1-2A and 1C approaches the 2000-hour rating for FSAR Table 8.3-2 events 1, 2, 3 and 4 for two-unit operation.

The above was reviewed with the diesel generator manufacturer who agreed with the need for a 24-hour load test but recommended that the test be conducted at 60-90% of the continuous load rating. The manufacturer emphasized that the diesel generator will operate for at l least 2000 hours0.0231 days 0.556 hours 0.00331 weeks 7.61e-4 months at the 2000-hour rating but reiterated that load I

tests at loads greater than the 60-90% load range do not contribute to either the dependability or longevity of the diesel generators.

Therefore, the 24-hour load test at the 2000-hour load rating exposes the diesel generators to an unnecessarily high loading without con-comitant beaefits.

II. REFERENCE Technical Specification 4.8.1.1.2.c.5 III. BASES During the FSAR described LOSP events, as many as nine river water pumps are sequenced on as shown in FSAR Table 8.3-2. The requirement for river water during these LOSP events can be met with two river water pumps per unit. For all design basis events, the number of operating river water pumps more than adequately supplies river water needs as follows:

Event 1. Loss of Off-Site Power - Units 1 and 2 (see FSAR Table 8.3-2, sheet 1).

A. For this LOSP event, nine river water pumps are sequenced on as outlined below:

1. D.G.1-2A will automatically energize Unit 1 train ,

A buses IF,1K and 1H, and the required Unit 1 l Train A LOSP loads and river water pumps 8, 9 and 10 will be automatically sequenced on. The estimated load is 4348 KW which is 273 KW greater than the continuous rating of 4075 KW. By removing one river water pump (487 KW) the estimated load is 3861 KW.

ATTACHMENT 1 Safety Evaluation Page 2

2. D.G.1B will automatically energize Unit 1 Train B buses 1G and IL, and the required Unit 1 Train B LOSP loads will be automatically sequenced on. The estimated load is 2977 KW which is 1098 KW less than the continuous rating of 4075 KW.

3. D.G.1C will automatically energize Unit 2 Train A buses 2F, 2K and 2H, and the required Unit 2 Train A LOSP loads and river water pump 6 will be automatically sequenced on. The estimated load is 3092 KW which is 242 KW greater than the continuous rating of 2850 KW. By removing one river water pump (445 KW) the estimated load is 2647 KW.

4. D.G. 2B will automatically energize Unit 2 Train B buses 2G and 2L, and the required Unit 2 Train B LOSP loads will be automatically sequenced on. The estimated load is 2919 KW which is 1156 KW less than the continuous rating of 4075 KW.

5. D.G. 2C will automatically energize Units 1 and 2 Train B buses 1J and 2J and river water pumps 4 and 5 and river water pumps 1, 2 and 3 will be automatically sequenced on. The estimated load is 2523 KW which is 327 KW less than the continuous rating of 2850 KW.

Event 2. Loss of Off-Site Power - Units 1 and 2 concurrent with a loss of coolant accident on Unit 1. (See FSAR Table 8.3.2, sheet 2.)

A. For this event two Unit 1 and four Unit 2 river water pumps are sequenced on to support Unit 2 as outlined below:

1. D.G.1-2A will automatically energize Unit 1 Train A buses IF and 1K, and the required Unit 1 Train A LOCA loads will be automatically sequenced on. The estimated load is 3885 KW which is 190 KW less than the continuous rating of 4075 KW.

l 2. D.G.1B will automatically energize Unit 1 Train B buses 1G and IL, and the required Unit 1 Train B LOCA loads will be automatically sequenced on. The estimated load is 3974 KW which is 101 KW less than the continuous rating of 4075 KW.

3. D.G. 1C (same as 1.A.3).

4. D.G. 2B (same as 1.A.4 except the estimated load is 2936 KW which is 1139 KW less than the continuous rating of 4075 KW).

5. D.G. 2C (same as 1.A.5).

ATTACHMENT 1 Safety Evaluation Page 3 Event 3. Loss of Off-Site Power - Units 1 and 2 concurrent with a loss of coolant accident on Unit 2 (see FSAR Table 8.3-2, sheet 3).

A. For this event, two Unit 1 and three Unit 2 river water pumps are sequenced on to support Unit 1 as outlined below:

1. D.G.1-2A will automatically energize Unit 2 Train A buses 2F and 2K, and the required Unit 2 Train A LOCA loads will be automatically sequenced on.

The estimated load is 3572 KW which is 503 KW less than the continuous rating of 4075 KW.

2. D.G. 1B (same as 1.A.2 except the estimated load is 2994 KW which is 1081 KW less than the continuous rating of 4075 KW).

3. D.G.1C will automatically energize Unit 1 Train A buses IF,1K and 1H, and the required Unit 1 Train A LOSP loads will be automatically sequenced on.

The estimated load is 2896 KW which is 46 KW greater than the continuous rating of 2850 KW.

4. D.G. 2B will automatically energize Unit 2 Train B buses 2G and 2L, and the required Unit 2 Train B LOCA loads will be automatically sequenced on. The estimated load is 3897 KW which is 178 KW less than the continuous rating of 4075 KW.

5. D.G. 2C (same as 1.A.5).

Event 4. Loss of Off-Site Power - Unit 1 (see FSAR Table 8.3-2, sheet 4).

A. For this eYent, five Unit 1 river water pumps are sequenced on in addition to those operating in Unit 2 as outlined below:

1. D.G. 1-2A (same as 1.A.1).

2. D.G. 1B (same as 1.A.2).

3. D.G. 1C is not loaded in this event.

4. D.G. 2B is not required for this Unit 1 event.

ATTACHMENT 1 Safety Evaluation Page 4

5. D.G. 2C will automatically energize Unit 1 Train B bus IJ, and river water pumps 4 and 5 will be automatically sequenced on. The estimated load is 1188 KW which is 1662 KW less than the continuous rating of 2850 KW.

Event 5-7. For these events no diesel generator is loaded beyond its continuous rating.

As shown above for each event, the removal of one river water pump from buses 1H and 2H will reduce the load on diesel generators 1-2A and 1C to less than the continuous rating for all events except the loads for diesel generator 1C during event 3. In this event the loads on diesel generator 1C are only 48 KW above the continuous rating of 2850 KW.

Events 1 and 4 assume a service water pond dam break. Under this condition service water will be automatically recirculated to the service water wet pit such that the loss of up to one train of river water pumps would not require operator action to balance service water supply with demand. This is described in detail in a letter from F.

L. Clayton to A. T. Schwencer and S. A. Varga dated March 24, 1981.

Therefore, operator action to remove one river water pump each from diesel generators 1-2A and 1C will not affect service water supply.

This action, if required, will be performed during the first two hours of a loss of Off-Site power event. If the proposed Technical Specification change is approved, this action would be added to appropriate plant procedures.

An additional change involves clarification of the requirement to demonstrate hot restart capability. The current version of the test requirement states that the diesel generator must be tripped from the 2000-hour load condition and hot restart capability demonstrated within 10 minutes. The requirement to trip from the 2000-hour load condition implies that the diesel can not be unloaded manually before it is tripped. Since the diesel generator is loaded during the test by adjusting the frequency and voltage control circuits against the grid, tripping from such a condition could cause problems with restart due to the diesel generator controls being set for the 2000-hour test load conditions. This is not the condition of a diesel generator following a trip from accident equipment loads. Therefore, the proposed Technical Specification has been changed to accurately reflect the actual test conditions.

Based on the manufacturer's recommendations on load tests and the action outlined above for Loss of Off-Site Power events, Alabama Power Company believes that the proposed Technical Specificaton change is sufficient to demonstrate the dependability of the diesel generators.

ATTACHMENT 1-Safety Evaluation Page 5 IV. CONCLUSION The proposed change to Technical Specification 4.8.1.1.2.c.5. does not involve an unreviewed safety question as defined by 10CFR50.59. This Technical Specification change will not significantly affect the safe operation of Farley Nuclear Plant Units 1 and 2.

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ATTACHMENT 2 Proposed Technical Specification Changes to Section 4.8.1.1.2.c.5.

FNP-1 & 2 1

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ML20062D912

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