ML20067C255

Proposed Tech Spec 3/4.8.1.1 Re Ac Sources Operating & Adding Description of Conditions Necessary for Hot Restart Loss of Offsite Power Test

ML20067C255
Person / Time
Site:	Summer
Issue date:	02/04/1991
From:	SOUTH CAROLINA ELECTRIC & GAS CO.
To:
Shared Package
ML20067C252	List: ML20067C250 ML20067C255
References
NUDOCS 9102120004
Download: ML20067C255 (9)

Text

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f ATTACHMENT 1 MARKED-UP TECHNICAL SPECIFICATION PAGES a

P_a_qq Specification Chance Description 3/4 S-6 3/4.8.1.1 A. C. Sources 1) Deletes 4.8.1.1.2.g.7.d Operating

2) Add description of

, conditions necessary for

-hot restart LOOP test, t

9102120004 910204 PDR ADOCK 05000395

- P- PDR

(LietRICAL POU(R SYSTEMS 4

$U WiltLAN:( REQUIREMENTS (Continuec)

-7. Verifying the EDG operates for at least 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />.

l a) The EDG shall betI a:e: to the ccntinuous ratir.;

(4150 4250 kw'*) f or the time required to rea:n engine temperature equilibrium, at which tima the EDG small te loaded to an indicated target value of 4676 k- (bet cen '

t600 4700 kw"*) and maintained for 2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br />.

i b) During the remaining 22 hours2.546296e-4 days <br />0.00611 hours <br />3.637566e-5 weeks <br />8.371e-6 months <br /> of this test, the EDG shall  ;

be loaded to an Indicated 4150-4250 kw"*.

c) During this test the steady state voltage and frequency

~= shall be maintained at 7200 1 720 volts and 60 1 1.2 Hz.

d) WitWnTMnutes-after.-comph 80 N _perfnm SurvetHanWRe~5ireme.t.ing this-24-hourtfTtI nl W.~8 3.-1;f %b _ l B. Verifying that the auto connected loads to each EDG do not exceed the 2000 hour0.0231 days <br />0.556 hours <br />0.00331 weeks <br />7.61e-4 months <br /> rating of 4548 kw.

9. Verifying the EDG's capability to:

a) Synchronize witn the offsite power source while the l

generator is loaded with its emergency loads upon a '

simulated restoration of offsite power, b) Transfer its loads to the of fsite power _ source, and c) Be restered to its standby status'.

10. Verifying that with the diesel generator operating in a test mode, connected to its bus, a simulated safety injection signal ovttrides the test mode by (1) returning the diesel generator to standby operation and (2) automatica;1y energizes the emt gency loads with offsite power.

11. Verifying that the fuel transfer pump transfers fuel f rom each fuel storage tank to the day tank of each diesel via the installed cross connection lines.

12. Verifying that the automatic load sequence timer is OPERABLE with the interval between each load block within 10% of its design interval.

13. Verifying that the following diesel generator lockout features prevent diesel generator starting only when required:

a. Barring Device Aont i . & il23fl.i

% b.

Remote-local-Maintenance Switch SEE TMSERT I

1his band is reant as guidance to avoid routine overloading of the engine.

l Leads in excess of this band shall not invalidate the test.

SUMMER - Uhli 1 3/48-6 AMEN 0 MENT NO. 22 93

INSERT 1

$R 4.8.1.1.2.g.14 Verifying that within 5 minutes of operating the diesel generator for at least 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> at a load of 4150-4250 KW** the diesel starts on the auto-start signal (Loss of Off-site Power signal), energizes the emergency busses with permanently connected loads within 10 seconds, energizes the auto-connected shutdown loads through the load sequencer, and operates for greater than or equal to 5 minutes while its generator is loaded with the shutdown loads. After energization of these loads, the steady-state voltage and frequency shall be maintained at 7200 1 720 volts and 60 1 1.2 Hz.

+

ATTACllMENT 2 DESCRIPTION OF AMENDMENT REQUEST SAFETY EVALUATION l

Attachment 2 to Document Control Desk letter TSP 890020-0 Page 1 of 2 DESCRIPTION OF AMENDMENT REQUEST This amendment request involves Technical Specification (TS) 3/4.8.1.1, "A.C.

Sources - Operating," and specifically the surveillance requiremen+ (SR) 4.8.1.1.2.g 7. This surveillance requirement directs that the Emergency Diesel Generator (EDG) be run at rated loads for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while maintaining its required voltage and frequency. Also, surveillance requirement 4.8.1.1.2.g.7.d requires that within 5 minutes of completing this test, SR 4.8.1.1.2.g.4.b is to be performed la simulated' loss of off-site power (LOOP) test). SCE&G proposes to delete SR 4.8.1.1.2.g.7 d and to add a new surveillance requirement to run the diesel loaded at 4150 to 4250 KW for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior to initiating the LOOP test.

The surveillance requirements for demonstrating the operability of the EOG are derived from Regulatory Guide 1.108, Revision 1, " Periodic Testing of Diesel Generator Units Used as On-site Electric Power Systems at Nuclear Power Plants," which provides guidelines for monitoring EDG performance and reliability via an assortment of periodic tests.

This amendment request is based on the current requirement to follow the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load run with a LOOP test. Due to the current requirements of SR 4.8,1,1.2.g 7, it would not be prudent during an outage to attempt the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run of EDG until all of the EDG design loads are operable and capable of satisfying the requirements of the LOOP test. Since all of these loads are not typically operable until near the end of the outage, the performance of SR 4.8.1.1.2.g.7 is forced to occur as a critical path item. This relates to a possible 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> critical path extension as a minimum, assuming no complications arise during the surveillance with respect to either the EDG or its design loads. If the LOOP test may be disconnected from the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run, '

as this amendment suggests, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run may be performed earlier in the outage and in parallel with critical path activities. It should also be noted that based on a literai interpretation of the current surveillance requirement, if a delay occurred beyond the 5 minutes allowed for the LOOP test initiation or if the LOOP test should yield unsatisfactory results due to reasons not associated with the diesel generator, then the compelling reaction would be to rerun the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test in its entirety.

SCE&G is therefore requesting this amendment to improve the outage scheduling and prevent unnecessary cycling of the Emergency Diesel Generators.

Attachment 2 to Document Control Desk Letter TSP 890020-0 Page 2 of 2 SAFETY EVALUATION:

This evaluation will demonstrate that there are no safety consequences associated with the requested amendment and that the level of demonstration of ED(. performance and reliability has not diminished.

This amendment request does not decrease the surveillance requirements of 4.8.1.1.2, but does add flexibility to the performance of one particular surveillance without affecting its objectives.

Suryc111ance requirement 4.8.1.1.2.g.7.d corresponds to testing described in Regulatory Guide 1.108, Pusition C.2.a(5), which states the following:

"0cmonstrate functional capability at full load tamperaturs conditions by rerunning the test phase outlined in Regulatory Position C.2.a(1) and (2) above [the LOOP test] immediately following (3) above [the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run)."

Past experience has demonstrated that operation of the EDG under loads of 4150 to 4250 KW results in the EDG reaching a stable full load temperature in less than I hour and that this temperature remlins essentially constant throughout the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run. Therefore, the amendment request to run the EDG at 4150 to 4250 KW for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prict to initiating the LOOP test remains consistent with the purpose of Position C.2.a(5). The amendment request also maintains a consistent level of safety since the conditions under which the LOOP test is performed remains the same as those currently required by 4.8.1.1.2.g.7.d.

It is important to note that the requested amendment is also supported as being safe by the working draft of Revision 3 to Regulatory Guide 1.9,

" Selection, Design, Qualification Testing, and Reliability of Emergency Olesel Generator Units Used as Class lE Onsite Electric Power Systems at Huclear Power Plants," which is currently being reviewed for approval by the NRC. The EDG testing guidance described in Regulatory Guide 1.108 will be superseded by this revision to Regulatory Guide 1.9, which deletes the LOOP test requirement from the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> rtn and instead describes a " Hot Restart" test which can be performed at any time. The " Hot Restart" test described in the Regulatory Guide is very similar to this amendment request.

In conclusion, based on the purpose of Regulatory Guide 1.108, Revision 1, and based on the consistency bei; ween the requested amendment and the current SR 4.8.1.1.2.g.7.d with respect to the surveillance conditions and objectives, there is no increase in safety consequences associated with the requested amendment. This conclusion is also supported by the guidance in the working draft of Regulatory Guide 1.9, Revision 3.

,A-n W

e ATTACilMENT 3 DESCRIPTION OF AMENDMENT REQUEST N0 SIGNIFICANT HAZARDS EVALUATION i

0 Attachment 3 to Document Control Desk letter TSP 880018-0 Page 1 of 2 Dr.SCRIPTION Of AMENDMENT REQUEST This amendment request involves Technical Specification (TS) 3/4.8.1.1, "A.C.

Sources - Operating," and specifically the surveillance requirement (SR) 4.8.1.1.2.g.7. This surveillance requirement directs that the Emergency Diesel Generator (EDG) be run at rated loads for 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> while maintaining its required voltage and frequency. Also, surveillance requirement 4.8.1.1.2.g.7.d requires that within 5 minutes of completing this test, SR 4.8.1.1.2.g.4.b is to be performed la simulated loss of off-site power (LOOP) test). SCE&G proposes to delete SR 4.8.1.1.2.g.7.d and to add a new surveillance requirement to run the diesel loaded at 4150 to 4250 KW for 1 hour1.157407e-5 days <br />2.777778e-4 hours <br />1.653439e-6 weeks <br />3.805e-7 months <br /> prior to initiating the LOOP test.

The surveillance requirements for demonstrating the operability of the EDG are derived from Regulatory Guide 1.108. Revision 1, " Periodic Testing of Diesel Generator Units Used as On-site Electric Power Systems at Nuclear Power Plants," which provides guidelines for monitoring EDG performance and reliability via an assortment of periodic tests.

This amendment request is based on the current requirement to follow the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load run with a LOOP test. Due to the current requirements of SR 4.8.1.1.2.g.7, it would not be prudent during an outage to attempt the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run of E00 until all of the EDG design loads are operable and capable of satisfying the requirements of the LOOP test. Since all of these loads are not typically operable until near the end of the outage, the performance of SR 4.8.1.1.2.g.7 is forced to occur as a critical path item. This relates to a possible 48 hour5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> critical path extension as a minimum, assuming no complications arise during the surveillance with respect to either the EDG or its design loads. If the LOOP test may be disconnected from the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run, as this amendment suggests, the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> run may be performed earlier in the outage and in parallel with critical path activities, it should also be noted that based on a literal interpretation of the current surveillance requirement, if a delay occurred beyond the 5 minutes allowed for the LOOP

-test initiation or if the LOOP test should yield unsatisfactory results due to reasons not associated with the diesel generator, then the compelling reaction would be to rerun the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test in its entirety.

SCE&G is therefore requesting this amendment to improve the outage scheduling and prevent unnecessary cycling of the Emergency Olesel Generators.

i l

1 e Attachment 3 to Document Control Desk Letter TSP 880018-0 Page 2 of 2 No Significant Hazards Determination:

This amendment request has been reviewed with respect to Title 10 of the Code of Federal Regulations (10CFR) part 50.92 and found to contain no significant hazards considerations for the following reasons:

1) The amendment request does not involve a significant increase in the probability or consequences of an accident previously evaluated. The requested change only involves the duration for which the full load temperature conditions are maintained prior to performing the LOOP surveillance. A change of this nature does not affect the performance, reliability, or capabilities of the EDG to fulfill its design functions.

Therefore, this requested amendment has no impact on any accident previously evaluated.

2) The amendment request does not create the possibility of a new or different kind of accident from any accident previously evaluated. The requested change only involves the duration for which the full load temperature conditions are maintained prior to performing the LOOP surveillance. The alteration of the surveillance requirements does not affect the normal operational methods, limits, or configurations with respect to the EDG. Therefore, the possibility of a malfunction or failure of any component or system which would result in a new or different kind of accident remains unaffected.

3) The amendment request does not involve a significant reduction in a margin of safety. The requested change does not alter any cperational limits, practices or functions of the EDG, and the change maintains the technical basis of all of the surveillance objectives equal to that in the current surveillance requirements. Thus, neither the design nor accident analysis bases are impacted by the requested change, and therefore all safety margins remain unaffected.

In conclusion, for the reasons above, SCE&G has determined that the requested amendment to SR 4.8.8.1.1.2.g.7 warrants no significant hazards considerations and meets the requirements of 10CFR50.92.

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