ML20063B250

Forwards Proposed Tech Spec Change Deleting River Water Sys Loads from Diesel Generator Automatic Load Sequence. Application for License Amend Will Be Submitted by Dec 1982

ML20063B250
Person / Time
Site:	Farley
Issue date:	08/20/1982
From:	Clayton F ALABAMA POWER CO.
To:	Varga S Office of Nuclear Reactor Regulation
Shared Package
ML20063B252	List: ML20063B250 ML20063B259
References
NUDOCS 8208250309
Download: ML20063B250 (5)

Text

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Malling Address Alabam Power Comp;ny 600 North 18th Stre.t Post Offics Box 2641 Birmingham, Alabama 35291 Telephone 205 783-6081 b

F. L. Clayton, Jr.

Senior Vice President

/MDballld POWCf Flintridge Building IN southern t 4minc W&m August 20, 1982 Docket Nos. 50-348 50-364 Director, Nuclear Regulatory 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:

In a letter dated August 3, 1982, Alabama Power Company requested a permanent change to the diesel generator Technical Specification surveillance requirement (section 4.8.1.1.2.c.5) involving a 24-hour overload test.

That proposal would have changed the loading requirement for the 24-hour test run f rom 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at the 2000-hour rating to 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the 2000-hour rating and 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> at the continuous rating.

Subsequent discussions with the NRC Staff resulted in a request for additional information before NRC approval could be given.

Much of the additional information requested involves another Technical Specification change that Alabama Power Company plans to submit by the end of 1982.

The to-be-submitted change involves deletion of the river water system (RWS) from the Technical Specifications which will require extensive evaluation and justification.

This change would justify deletion of the RWS loads from the diesel generator auto-matic load sequence.

If this change is approved, the automatic 3

loads on each diesel generator will be less than the continuous

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ratings, with the exception of diesel generator 1C which would be i

automatically loaded to approximately 102% of the continuous rating.

g Since Alabama Power Company needs approval by September 30, 1982, of the proposed change to the 24-hour diesel generator test ran, it is respectfully requested that the August 3, 1982, proposed Technical Specification change be modified is shown in Attachment I and approved as a one-time change with the understanding that a permanent change will be requested and comprehensively supported as

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Mr. S. A. Varga August 20, 1982-Director, Nuclear Reactor Regulation Page 2 U. S. Nuclear Regulatory Commission part of the RWS change request.

This one-time change is requested on the basis that: (1) the deletion of the RWS, which eliminates the automatic sequencing of loads in excess of the diesel generator continuous rating, is compatible with -current licensing requirements at several operating nuclear power plants; and (2) the previous overload testing of the Farley diesel generators has established a high degree of -confidence in overload capability that will not be significantly affected by this one-time surveillance requirement change.

River Water System Technical Specification Deletion The deletion of the RWS from the Technical Specifications will eliminate automatically sequencing accident loads on the diesel generators in excess of their continuous rating, which is the primary reason that the existing 24-hour testing requirement involving operation at overload levels (i.e., the 2000-hour rating).

This will also allow the operator to manually load the diesels with significant non-automatic loads and still operate near or below the continuous rating of the diesel generators.

Therefore, this proposed Technical Specification change will negate the primary reason for the existing diesel generator 24-hour surveillance requirement having to be run at overload values.

Although a detailed discussion of the justification for the RWS deletion has not been completed,.an outline of the rationale is as'follows:

1.

The emergency cooling pond is the safety-grade ultimate heat sink for all postulated accident conditions.

The RWS is not needed to meet any NRC design criteria for an ultimate heat sink.

2.

The emergency cooling pond dam was designed, con-structed and tested in accordance with all appli-cable seismic Category I standards to assure seismic integrity.

3.

The Farley Nuclear Plant site is in a low seismic activity region.

Therefore, in the judgement of Alabama Power Company, a backup to the emergency cooling pond is less important than at other licensed nuclear power plant sites that do not have a backup system.

4.-

The NRC has licensed other nuclear power plants with similar emergency cooling ponds (e.g., North Anna, Summer, Arkansas Nuclear One, etc.) without requir-ing a safety-grade backup system for the ultimate heat sink.

4 Mr. S. A. Varga August 20, 1982 Director, Nuclear Reactor Regulation Page 3 U. S. Nuclear Regulatory Commission 5.

Although the RWS pumps will be deleted from the automatic load sequence, if a serious emergency should arise requiring operation of the RWS pumps, they will be capable of being manually loaded onto the' diesel generators and operating procedures will be available for that situation.

Based on the above, Alabama Power Company plans to request approval to delete the RWS from the Technical Specifications by the end of 1982.

Therefore, the concern that the diesel generators could experience an overload condition from automatically sequenced loads during a postulated accident will be eliminated.

Previous Overload Testing of the Diesel Generators The diesel generators at Farley Nuclear Plant ~ have all received extensive reliability testing including overload testing.

Therefore, Alabama Power Company believes that there is a suffi-cient statistical data base of test results on the diesels such that the modification of one data point by this one-time test change would not significantly impact the confidence level in diesel generator reliability. gives a summary of previous overload tests on all five diesel generators including factory performance testing, field pre-operational testing, and inservice testing.

As a minimum, all diesel generators have passed factory overload testing at or above the 300-hour rating and field overload testing at or above the 300-hour rating.

All but diesel generator 1B have been exposed to at least one 24-hour endurance test including an overload to the 300-hour rating.

g3 Additional information on continuous load testing has been included in Attachnent 2 since such testing demonstrates overall load carrying capability of the diesel generators.

As stated in the August 3,1982 letter, the diesel manufacturer recommends load testing at the continuous rating to provide complete assurance of load carrying capability including overload ratings.

It should be noted that the diesel generators are currently tested at least bi-weekly for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the continuous load rating.

Therefore, the previous tests at the continuous load rating provide added assurance of diesel generator operability such that the proposed one-time Technical Specification change does not degrade confidence in diesel generator operability under any postulated accident conditions.

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.Mr.'S. A. Varga August 20, 1982 Director, Nuclear Reactor Regulation Page 4

'U. S. Nuclear Regulatory Commission Diesel Generator Operating Procedures In order to provide assurance that the diesel generators will not be operated in a manner less' conservative than justified by the proposed one-time Technical Specification change, the following operating procedure changes will be made upon approval of the proposed change:

3 1.

The diesel generator manual loading procedure. will be changed to specifically direct the operator not to exceed the continuous rating with manually con-nected loads, except in case of a serious emergency.

2.

The diesel generator emergency operating procedure will be changed to specifically direct the operator to remove the load of at least one RWS pump from each diesel generator 1-2A and 1C within 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> of a loss of off-site power event, unless extreme circumstances dictate otherwise (e.g., loss of the seismic emergency cooling pond dam concurrent with a single failure of one diesel generator train).

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t Conclusion Based on discussions with the diesel generator manufacturer, load testing above the continuous rating does not contribute to the assurance of reliability or the confidence in capability to carry 2000-hour rating loads.

However, Alabama Power Company believes that testing above the continuous rating is justified when the postulated maximum automatically sequence loads are in excess of the continuous rating.

Since the RWS has yet to be eliminated as an automatically sequenced load, the proposed one-time Technical Specification change requires an overload test for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> at the 2000-hour rating and a 22 hour2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> continuous load test for the remainder of the 24-hour endurance test.

The proposed test will provide complete assurance of the diesel generators operability without unnecessarily exposing them to excessive testing that could degrade long term reliability.

In summary the proposed one-time change to Technical Specifi-cation 4.8.1.1.2.c.5 (see Attachment 1) for the Farley Nuclear Plant, Units 1 and 2, is respectfully requested based on the justification contained in this letter and in the August 3, 1982 l ette r.-

A permanent change request concerning the diesel generator endurance test will be submitted by the end of 1982, as part of the permanent change to delete the RWS from the Technical Specifications.

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(T Mr. S. A. Varga August-20, 1982

' Director, Nuclear Reactor Regulation Page 5 U..S. Nuclear. Regulatory Commission

' The Plant Operations Review Conmittee of Alabama Power Company has reviewed this ~ proposed change to the Technical Specifications and has determined that this charge does not involve an unreviewed safety question as shown in the safety evaluation attached to the August 3, 1982 letter.

The Nuclear Operations Review Board is scheduled to review this change at the next meeting.

Your approval of this proposed one-time Technical Specifica-tion change is respectfully requested by September 30,1982, in order to provide for its incorporation into the plant procedures prior to the upcoming scheduled refueling outages.

This proposed amendment is designated as Class III for Unit 1 and Class I for Unit 2 in accordance with 10 CFR 170.22 require-ments.

A check for $4,400.00 to cover the total amount of fees required was enclosed with the August 3, 1982 letter.

In accordance with 10 CFR 50.30(c)(1)(i), three signed originals and forty (40) additional copies of this proposed change are enclosed.

Yours very truly, it

. L. Clayton J r.

r FLCJ r/GGY: jc-D25 SWORN TO AND SUBSCRIBED BEFORE ME Attachment THIS r.ed DAY OF A a m /

1982.

cc:

Mr. R. A. Thomas V

Mr. G. F. Trowbridge

[ d / t./.efi m [

Mr. J. P. O'Reilly

' Notary Public Mr. E. A. Reeves Mr. W. H. Bradford My Commission Expires-Jo k 1 BC

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